Inside information and insider trading

We don’t engage in insider trading.

Insider trading is when a person trades in financial or commodity markets based on inside information, and it is illegal. This includes buying or selling shares or securities in a company, physical commodities or commodity derivatives.

While working with us, you may have access to inside information – this is information about BHP or another company that is not public and, if made publicly available, a reasonable person would expect to have a positive or negative effect on the price of securities. This includes non-public information about financial or operational performance, significant contracts or strategic decisions.

Inside information and insider trading

  • What it means for you

    We keep inside information confidential and understand the serious consequences that misusing inside information may have personally, for BHP, and on financial and commodity markets. Non-public information is handled with great care and is not shared or discussed improperly. When we hold inside information, we never use it for personal gain or trade in BHP or other companies’ securities, physical commodities or commodity derivatives. We never recommend or suggest that anyone else trade in securities or physical or derivative commodities when holding inside information. 

    Before trading, we always ask ourselves if we have any inside information. If we have inside information and are considering trading in securities or transacting in physical or derivative commodities, we seek advice from our Compliance teams. 

    We never share inside or non-public information with others unless authorised to do so. This includes discussing non-public information in public or with family or friends. 

    BHP takes these responsibilities seriously and has clear policies, procedures and support in place to help our people to make ethical and lawful choices. 

    Maintaining the confidentiality of BHP information and the integrity of securities and commodities markets upholds the credibility of our people, company and industry. 

  • How you make an impact
    You keep inside information strictly confidential, never trade in securities or commodities if you have inside information, follow our policies for securities dealing, seek guidance if needed before you trade in securities or commodities, and speak up immediately about any concerns about insider trading.  
  • Resources
    Securities Dealing Global Standard
Newman person radio

Always

• Maintain the confidentiality of BHP confidential information and take measures to avoid accidentally sharing inside information.

• Seek advice from Group Governance, Ethics and Investigations, Compliance or Legal if you have inside information and are considering dealing in a company’s relevant securities or are transacting in the physical or derivative commodities market and have any doubt.

Someone studying in office

Never

• Trade relevant securities of BHP (or any other potentially impacted company), either directly or indirectly, while you are in possession of inside information.

• Recommend or suggest that anyone else trade in the relevant securities of BHP (or any other potentially impacted company), or transact in potentially impacted financial and physical commodities markets, while you are in possession of inside information.

• Disclose inside information to anyone outside BHP unless you are authorised to do so.

• Discuss confidential information in public or leave confidential information in a public place. If you accidentally share inside information, contact Group Governance, Ethics and Investigations, Compliance or Legal immediately.

Hypothetical scenarios

  • Q: I am part of an Internal BHP Business Continuity Planning team and have just been informed that due to a significant mine site event, one of our main production assets is to be closed. This information has yet to be made public, but when it is, commodity prices are expected to rise. Can I use this information to trade commodity derivatives or purchase shares in a competing producer in the expectation their share price will rise?
    A: This is likely to be inside information about BHP that is not available to the public at this time. As per the requirements of the Securities Dealing Global Standard, unless authorised to do so, you should not transact in physical commodities, commodity derivatives or securities of BHP or other companies whose price may be impacted once the information becomes publicly available. To do so, would be in breach of the Securities Dealing Global Standard, or insider trading laws. 
     

  • Q:  I am a maintenance technician and have heard from a friend in Head Office that our half-year results will be below market expectations. I have been thinking of selling some of my BHP shares to help fund a house renovation and it seems a good opportunity to sell before the half yearly results are announced. Is it ok to sell my shares?

     

    A: This is likely to be inside information about BHP that is not available to the public at this time. As per the requirements of the Securities Dealing Global Standard, you should not transact in securities of BHP or other companies whose securities may be price impacted once the information becomes publicly available. To do so would be in breach of the Securities Dealing Global Standard or insider trading laws. Equally, if you tell your friends and they use this information to deal in BHP or another company’s securities, your friends may also be guilty of breaching insider trading laws.
  • Q:  I overheard my line leader talk about BHP potentially selling one of its big mine sites in another country. I haven’t seen this on the news or heard anybody else talk about it at my site. Can I tell my friends who also work at BHP?
    A: This is likely to be confidential information and may also be inside information about BHP that is not generally available to the public. If you tell your friends and they use this information to deal in BHP securities, you and your friends may be liable for breaching Securities Dealing Global Standard or insider trading laws.
  • Q: I was told I was on the Securities Dealing Restricted List and I can’t remember if I received an email telling me that I am no longer on this list. I would like to sell some shares that I own. Should I check with someone before I sell my shares?

    A: Check with Group Governance as if you are on the Securities Dealing Restricted List, you must seek clearance prior to selling your shares. You will not be given clearance to deal in BHP securities during a closed period. This is the period from the end of BHP’s financial year to the publication of BHP’s full year results announcement, and the end of BHP’s half year to the publication of BHP’s half year results.

     

    If you are not on the Securities Dealing Restricted List, then you will not need clearance prior to selling your shares. However, the general prohibition on insider trading still applies, and if you have inside information, you must not deal in BHP shares until the information is public or no longer material.

  • View more hypothetical scenarios

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How to speak up

If you have questions about Our Code, speak to your line leader, 2Up leader, Ethics and Investigations, Compliance, or Legal. Employee Relations or a HR Business Partner can direct you to the relevant reporting options available. You can also seek further information and resources via BHP’s RespectChat.  Anyone who works with us, on our behalf, or is associated with us, can also raise misconduct concerns via Integrity@BHP or the BHP Protected Disclosure Reporting Channel.

Online: Make a report in either Integrity@BHP or the BHP Protected Disclosure Reporting Channel. 

Phone: You can also contact the BHP Protected Disclosure Reporting Channel by phone. 

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