BHP's Code of Conduct is based on Our Charter values. The Code represents our commitment to uphold ethical business practices and meet or exceed applicable legal requirements. We believe that exercising consistent and proper business conduct creates loyalty and trust with our stakeholders.

The Code outlines our approach to corporate participation in political activities. It prohibits attending a political fundraising event or activity on behalf of BHP or during work hours. We maintain a position of impartiality with respect to party politics and do not make political contributions or expenditure/donations for political purposes to any political party, politician, elected official or candidate for public office in any country.

In keeping with local and international anti-corruption laws, we prohibit authorising, offering, giving or promising anything of value directly or indirectly (via a third party) to a government official to influence official action, or to anyone to encourage them to perform their work disloyally or otherwise improperly. We also prohibit facilitation payments, which are payments to government officials for routine government actions. We require third parties acting on our behalf to operate to BHP standards and not violate anti-corruption laws.

In furtherance of the Code, BHP has multiple governing documents known as Our Requirements standards that outline the mandatory minimum standards we expect of those who work for or on behalf of BHP in relation to all key aspects of company operations. Compliance with the Our Requirements standards is subject to rolling internal audit processes.

In particular, our mandatory minimum performance requirements for communications and external engagement provides for consistency in BHP government relations activities. Contact with government is managed centrally to enable company-wide engagement and policy alignment. The Corporate Affairs function must be consulted before anyone engages with government or communicates externally on public policy issues that could impact our reputation, providing consistency and adherence to the Code of Conduct across our activities.

The Chief Legal, Governance and External Affairs Officer is ultimately responsible for the delivery and alignment of our government relations activities as set out in our mandatory minimum performance requirements for communications and external engagement.

In addition to the role performed by Corporate Affairs, giving or offering anything of value to a government official, a person who represents others, or a close relative of a government official or leader above certain thresholds requires pre-approval which is coordinated by our Ethics and Compliance function led by the Chief Compliance Officer.

Through public submissions, opinion pieces and comments in the media, we continually raise issues that are important to us and promote policy reforms that we believe will best serve the interests of our business, shareholders, employees and the communities where we operate. We have made public submissions and comments on a range of topics including tax, industrial relations, human rights, energy policy and trade. BHP’s public policy submissions are generally made public on the company’s website or on the website of the relevant government agency unless the submission contains commercial-in-confidence information.