What this means for you
Always act with integrity and maintain honest, transparent relationships with governments and their agencies, officials and personnel.
- If you are engaging with governments on matters other than of a routine regulatory nature, speak with your Corporate Affairs representative before proceeding.
- Before making a submission to government on behalf of BHP, including responding to government inquiries or papers on proposed legislative reforms, obtain approval from Corporate Affairs.
- Before submitting an official BHP response to an anti-corruption, competition, sanctions, state secrets or financial markets enforcement agency, obtain approval in line with the Our Requirements for Business Conduct standard.
- Before participating in events or activities organised by a political party, politician, elected official or candidate for public office, obtain approval in line with the Our Requirements for Business Conduct standard. Your participation in these events or activities must be for business, related to policy briefing and supported by your line leader, and cannot be related to political fundraising.
- Exercise care in situations where a perception could arise that BHP is sharing information or opinions with a government on behalf of, or in coordination with, a business partner that is associated with a foreign government.
- Notify your line leader or 2Up leader if you wish to participate as an individual in the political process, including running for political office. Record in the Conflict of Interest register.
• Be truthful, accurate and cooperative when dealing with government officials and comply with all laws and regulations.
• Speak to Corporate Affairs before you engage with government officials or their representatives on public policy or issues that could impact BHP’s reputation or licence to operate.
• Speak with Corporate Affairs or Compliance (as required by the Our Requirements Business Conduct standard) before engaging on behalf of BHP with government or regulators regarding government inquiries or regulatory
investigations, and before issuing notifications on behalf of BHP to regulators.
• Consider potential corruption risks when dealing with government officials.
• Seek approval for involvement in any business-related event or activity organised by, or on behalf of, a political party or candidate and be transparent when undertaking such activities.
• Discuss with your line leader and 2Up leader and advise in writing if you plan to seek or accept a role in public office.
• Authorise, offer, give or promise anything of value directly or indirectly to a government official to influence official action.
• Attend an event or activity during work hours or on behalf of BHP which is intended for political fundraising.
• Present information or an opinion to a government on behalf of a business partner that is associated with a foreign government without first talking to Corporate Affairs.
• Attempt to obstruct the lawful collection of information, data, testimony or records by appropriately authorised government or regulatory officials or hinder the lawful and proper provision of such information by another employee.
• Take retaliatory action against anyone who lawfully and properly cooperates with government agencies.
• Accept information about a government’s competitive selection of a supplier or competitor’s bid or proposal (unless the government has specifically and lawfully authorised the release of the information).
• Use, or allow others to use, any BHP information, assets or resources (including donations or sponsorships) for a political campaign, party or candidate, elected official or any of their affiliated organisations.
• Pay wages or salaries, fringe benefits or remuneration of any kind to a BHP employee working for a political party or candidate during normal working hours.
Q: I’m at a social event hosted by a political party and have been asked about BHP’s position on climate change. What should I say?A: Refer them to our website for detailed information on our climate change policy. If you have personal views on climate change, or any other public policy issue, ensure you flag these are your personal views.
Q: I have been invited by a political party to attend an event to discuss policy related to the resource sector in an open and transparent forum hosted by elected officials. The ticket cost is US$260. I know our competitor will be represented at the event. Can I attend and if so, do I need approval?A: You should always seek approvals under the Our Requirements for Business Conduct standard prior to accepting an invitation of this nature. This ensures adequate consideration is given as to whether the ticket costs are or can be perceived as political fundraising. You should also consult with Corporate Affairs to ensure there is no conflict of interest that you, or your line leader, may not be aware of, and ensure you have completed competition law training within the last 15 months.
Q: I am considering running for an elected position on my local city council. The position is only part-time and is unpaid, and I don’t see it conflicting with my duties at BHP. What should I do to determine if I can maintain my employment at BHP while I hold a role as an elected official in public office? If I later need to resign from the public office position, can I get my former position back at BHP?
A: Holding a public office role at the same time as being a BHP employee can lead to conflicts between your duties as a BHP employee and your duties as a public official. Discuss your intentions with your line leader and 2Up leader before running for public office and seek approval via the Conflict of Interest register.
In some circumstances, it might be possible for you to hold an unpaid, part-time role as an elected official if there is no potential for overlap between the role and BHP’s business, and it will not impact your ability to safely perform your BHP role (including having regard to fatigue management considerations). However, if holding any public office role (part-time or full-time) would create an actual, potential or perceived conflict of interest that can’t be managed to BHP’s satisfaction then you may have to resign from your BHP role before commencing the public office role. If you later leave the public office role and want to apply to re-join BHP, you may be able to do so, but your former BHP position might no longer be open.
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