At BHP, our purpose is to bring people and resources together to build a better world.

Everywhere we operate, we are committed to doing what is right and doing what we say we will do. We care as much about how results are achieved as the results themselves. That’s why Our Code matters. It helps us deliver on our purpose and make the right decisions every day.

In Our Code, you’ll find clear guidance on how Our Charter and Our values of Do what’s right, Seek better ways and Make a difference can be put into practice. You’ll know how Our Code applies to you and understand what is acceptable – and what’s not – when working with colleagues, suppliers, contractors, customers, governments and communities. And while Our Code can’t describe or anticipate every situation, if you see – or suspect – a breach of Our Code, you’ll know how to raise your concern or seek help.

Operating with integrity is everyone’s responsibility so if you work for us, with us, or on our behalf, Our Code applies to you.

We expect you to:

• read and understand Our Code
• complete annual mandatory training on Our Code and any role-specific training that is assigned to you
• comply with Our Code, the Our Requirements standards, any BHP policies, statements, standards and commitments and any procedures that apply to your role, and all applicable laws of the country in which you’re working
• understand Our Code applies to you at site, in offices, when working remotely, in camp or other BHP-provided accommodation, at BHP functions, when travelling, and at all times when you are representing BHP
• speak up and report any concerns or breaches of Our Code
• contribute to a culture in line with Our Code.

If you are in a leadership role, we also expect you to: 

• lead by example and role model behaviour that’s in line with Our Charter, Our Values and Our Code
• ensure every member of your team understands their responsibilities to comply with Our Code at all times 
• foster an inclusive culture where everyone feels safe to bring their whole selves to work and comfortable to speak up or ask questions without fear of retaliation
• respond to concerns promptly and appropriately, record any concerns in Integrity@BHP or the BHP Protected Disclosure Reporting Channel and maintain confidentiality.

When raising a concern or reporting a breach of Our Code, be open, accurate and provide as much information as you can.

• If you’re an employee or contractor, talk to your line leader, 2Up leader, Employee Relations advisor, HR Business Partner, Ethics and Investigations, Compliance or Legal. You can also raise your concern via Integrity@BHP or the BHP Protected Disclosure Reporting Channel.
• If you’re a community member, former employee, supplier or vendor, you can speak with your BHP contact point, access the community complaints and grievance mechanism or contact Integrity@BHP or the BHP Protected Disclosure Reporting Channel.

We treat every report of a potential breach of Our Code sensitively, respectfully and confidentially.

• Once a concern is raised, it’s assessed and triaged by our Ethics team according to the categories set out in the Business Conduct Global Standard.
• Sometimes, advice, support and guidance may resolve the concern. In some matters, our Ethics Support Service can also offer an alternative resolution option acceptable to the impacted person. If an investigation is warranted (and guided by the wishes of the impacted person where possible), we’ll review in line with the process set out in the Business Conduct Global Standard.
• Depending on the nature of the matter reported and in line with the Business Conduct Global Standard, investigations may be performed by the Central Investigations Team within Ethics and Investigations, Compliance, a leader, HR/Employee Relations or an external investigator.
• If you have any concerns during the process, speak to your line leader, 2Up leader, Ethics and Compliance or Integrity@BHP or the BHP Protected Disclosure Reporting Channel.

Ensuring you can speak up without threats, intimidation, harassment, exclusion or humiliation is critical. We won’t tolerate retaliation or allow any form of punishment, discipline or retaliatory action to be taken against anyone for speaking up, intending to speak up or being suspected of speaking up, or for cooperating with an investigation. You can find more information in our Business Conduct Global Standard. In some circumstances, you may also have legal protection when you speak up. Refer to BHP’s Whistleblower Policy for more information.

Anyone involved in retaliatory behaviour is breaching Our Code and will be subject to disciplinary action. In certain circumstances, retaliation may also breach whistleblower laws and BHP’s Whistleblower Policy. If you believe you or anyone else may be, or have been, retaliated against for speaking up, report to your line leader, 2Up leader, Ethics and Investigations, Compliance, Legal or Integrity@BHP or the BHP Protected Disclosure Reporting Channel.

Any information you provide will be kept in confidence to the fullest extent possible, consistent with law and good business practices. If you’ve disclosed your identity when making a report, this will only be disclosed if we’re compelled to by law, if you’ve consented or if we determine it’s appropriate to refer the matter to emergency services, law enforcement or a regulator. If you’ve chosen to make an anonymous report, we will respect your decision.

Nothing in Our Code, the Our Requirements standards or any other document or procedure prevents you from, or requires approval for, reporting to an appropriate government authority or law enforcement body, or from seeking legal advice in relation to your rights.

Anyone found breaching Our Code can face serious consequences. Depending on the severity of the breach, this could include verbal counselling with a line leader or 2Up leader, a verbal warning, written warning, final written warning and termination of employment. In some cases, conduct that is a breach of Our Code may also be a breach of law and carry civil penalties or criminal charges.