When creating and maintaining data it must be accurate, complete and appropriate. There is never a justification for falsifying records, misrepresenting facts or engaging in any other fraudulent behaviour. All financial and non-financial reports must be evidenced by appropriate source documents, verified for validity, accuracy and completeness, properly authorised and accurately and completely recorded in the relevant accounts, systems and records.
What this means for you
If you are responsible for reporting financial or non-financial information, ensure you follow processes and establish adequate internal controls to achieve truthful, accurate, appropriate, complete, consistent, timely and understandable reports that represent BHP and our business activities. Understand and comply with the Our Requirements standards as they apply to your role, and all applicable financial, regulatory and reporting requirements, laws and regulations in the relevant jurisdiction.
If you have any concerns about the validity of any reporting process or record-keeping activity, or believe you are being asked to create false or misleading information, report immediately to your 2Up, Ethics and Investigations, Compliance or via EthicsPoint.
• Make and keep books, records and accounts which, in reasonable detail, accurately and fairly reflect BHP’s transactions in accordance with all applicable laws, regulations, standards and procedures.
• Speak up immediately if you suspect fraudulent activity and report any actual or suspected irregularities or weaknesses in internal controls, accounting or reporting.
• Cooperate with our internal and external auditors and disclose all pertinent information that could reasonably impact the data verification process and results of an audit.
• Ensure no undisclosed or unrecorded account, fund or asset is established or maintained.
• Ensure work-related expenses are legitimate, reasonable and supported by valid receipts and invoices.
• Return or transfer the custody of all relevant business records if you change roles within the company or if you leave BHP. Do not keep personal copies.
• Falsify any record or make a false or misleading entry including omitting any information.
• Circumvent review and approval procedures for reporting financial or non-financial information.
• Allow others to do anything that would compromise the integrity of BHP’s records or reports.
• Disclose or disseminate confidential information or competitively sensitive information without prior authorisation.
• Misstate your qualifications, experience or achievements.
• Dispose of documents and records without knowing what is being discarded or whether they must be kept for legal reasons.
Q: During my last shift my vehicle collided with another vehicle while going around a bend. We both reacted quickly, there was no damage to either vehicle and neither of us were hurt. Do we have to take time out from our jobs to fill out paperwork and report this as nothing happened?A: We all have a duty of care to report all accidents and near misses. While in this instance no-one was injured, next time it could be more serious. It’s important that all near misses are reported so they can be appropriately investigated and safety measures put in place to prevent a more serious outcome.
Q: During the last environmental monitoring round there were some unusual results. I noted that some individual samples exceeded the limits established by our operation. I think this might be a one-off. Do I have to fill out paperwork and report this at the next round of monitoring?A: Yes. While in this instance there were only a few unusual results, it’s important that reporting processes are followed to ensure that any potential issues are identified and can be appropriately investigated, any necessary measures put in place and the relevant individuals can determine if there is a need for external reporting.
Q: I am responsible for approving expense reports for my team. I have six direct reports and some months I don’t have time to check to make sure receipts are attached but I trust my team. Do I need to review every receipt?A: As a line leader you have an additional duty of care to be a positive and visible role model. Whenever you approve anything in the system — an expense report, service entry sheet, goods receipt or otherwise — always verify that the underlying transaction is appropriate. It is not undermining the trust you have in your team but a requirement that we have receipts for all our expenses. Check the expenses incurred are work related and copies of all receipts have been attached.
Q: I have been asked to provide a written update on the progress of one of our team’s key improvement initiatives. We are behind schedule but I know we will catch up in the next month or two. Do I need to specifically say we are behind schedule?A: All reporting we do across the organisation should be factual and not give the impression that work has been completed when it is has not, even if there is a strong belief the work will be completed soon.
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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, Legal, Employee Relations advisor, HR Business Partner or contact EthicsPoint. Anyone who works with us, on our behalf, or is associated with us, can also access EthicsPoint.
Online: EthicsPoint online
Phone: EthicsPoint Telephone