Trade controls
Our business involves international trade. We respect the international trade laws that govern these transactions and comply with all applicable export controls and sanctions.
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Our expectations of youBHP screens suppliers and customers to block transactions with sanctioned countries and sanctioned parties. If you are involved in international transactions or may interact with individuals or entities who are subject to sanctions, you need to comply with our screening procedures. Check with Ethics and Compliance before proceeding as sanctions programs are subject to frequent change. Examples of countries affected by comprehensive sanctions at time of publication included Crimea (Region of the Ukraine), Cuba, Iran, North Korea and Syria. If you become aware of any activity involving BHP and any of these countries or their citizens, you must contact Ethics and Compliance immediately.
Before sending technical information, software or equipment across international borders, check that you are legally allowed to do so. Seek assistance from Ethics and Compliance and allow enough time to obtain any licences that may be required.
If you are asked to withhold goods or services from a party because of their race, religion, gender, national origin or nationality, contact Ethics and Compliance about how to respond. -
Our expectations of others who work with usWhen you work on behalf of BHP, we expect that you will respect all international trade laws of the countries in which we operate.
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Where to go for help
- Ethics and Compliance
- Legal
- Your line leader or 2Up leader
- EthicsPoint
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Tools and resources
Guidance
Always
- Make sure that accurate and complete information is provided to government authorities, including on import and export declarations.
- Know your counterparty and follow Finance approval processes.
- Understand the routes that are being used to transfer information, goods and services between locations, and identify borders that are being crossed.
- Understand whether your counterparty is on-selling goods and get assurances to avoid on-selling to a sanctioned party.
- Understand whether your counterparty is using BHP products to produce goods destined for a sanctioned party or country – your counterparty may not be subject to the same sanctions programs.
- Get the necessary approvals and licenses before proceeding with a transaction.
- Understand whether your nationality or citizenship affects your ability to be involved in an international transaction.
Never
- Undertake any business activity with a party who has been identified as sanctioned in our screening or from a sanctioned country without prior approval from Ethics and Compliance.
- Proceed with a business transaction if there is any doubt about whether the transaction might breach trade controls laws without prior approval from Ethics and Compliance.
- Allow a transaction to proceed with a counterparty that is intended to conceal the identity of the true counterparty.
Example questions and answers
Working with other countries
Question: I am an Australian employee working in Singapore and have a US green card. I hear that some companies are starting to investigate opportunities for marketing our products in Iran and would like to do some exploratory work. I thought that I would call the Iranian trade promotion agency to start the ball rolling.-
Show AnswerSome countries have relaxed their sanctions against Iran and this has allowed companies from those countries to enter the Iranian market. However, Iran is still the subject of comprehensive sanctions in the United States. You must seek advice from Ethics and Compliance before taking any steps, especially as you have a personal connection with the United States.
Signing documents
Question: I have been involved in the engineering design for a development project in Chile and am interested in purchasing drones from the US to conduct testing at site. I have also received a document from a French vendor for my signature confirming that BHP will comply with export control requirements following receipt of a part.-
Show AnswerThe technology utilised by drones may be subject to export controls restrictions. You must understand the nature of documents that you sign at a vendor’s request. In this case, BHP may be assuming significant ongoing obligations under export controls laws. In both instances, you must always contact Ethics and Compliance to get necessary approvals and licences before proceeding.
Related Sections
Report a concern
In person: Speak to your line leader, 2Up leaders or Human Resources representative
Email: Ethics.Team@bhp.com
Online: EthicsPoint Online
Phone: EthicsPoint Telephone
Mail
BHP Business Conduct,
GPO Box 86,
Melbourne,
Victoria 3001, Australia
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Version 2.1, last updated 16 August 2018
