Refuse to participate in corruption or bribery

We stand against bribery and corruption in all forms.

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We do not engage in or tolerate any form of bribery or corruption.

Refuse to participate in corruption or bribery
What it means for you

BHP is committed to transparent and ethical business practices. Everyone who works for us, with us, or on our behalf – including partners and suppliers – must comply with anti-corruption laws, and no one has authority to waive this requirement. 

 

We do not offer, give, or promise anything of value (directly or through a partner or supplier) to influence anyone in their role, or to encourage them to perform their work disloyally or improperly. 

 

We do not make payments of any size to government officials to facilitate routine services that are legally available (known as facilitation payments). However, payments made in response to an imminent threat to the health or safety of an employee, contractor or someone accompanying them are not facilitation payments. These situations and payments must be reported to Compliance as soon as possible.

 

Managing bribery and corruption risk is a shared responsibility. We speak up and immediately report any concerns about bribery or corruption risks. BHP fully supports our employees, contractors, suppliers and partners who refuse to pay bribes or engage in unethical practices. 

How you make an impact
You understand and comply with our Business Conduct Global Standard, refuse any request that you think may be corrupt (and support partners or suppliers who also refuse these requests) and immediately report any concerns. 
Resources
Business Conduct Global Standard  
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Always

• Immediately report any corruption concerns.

• Understand the identity, role and interests of the person or business who you are dealing with (including the beneficial ownership of companies).

• Gain pre-approval before offering or giving anything of value, according to the thresholds in the Our Requirements for Business Conduct standard, or for commercial sponsorships and community donations or projects.

• Provide accurate and complete information when seeking pre-approvals.

• Record all transactions accurately and in reasonable detail to reflect their true nature.

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Never

• Offer, promise, give or approve anything of value of any kind to a government official (including a political party, elected official or candidate for public office or a person who holds or performs the duties of an appointment, office or position created by tradition, custom or convention) to influence official action.

• Award business to a company owned by a government official, their relatives or associates in exchange for a benefit to you or BHP.

• Offer, promise, give or approve schemes or arrangements which give an improper benefit to anyone.

• Establish a hidden or incorrectly recorded fund for prohibited payments.

• Use personal funds, divide payments into smaller amounts to avoid approval thresholds, or hide activity which would otherwise need pre-approval.

• Use a supplier if you are concerned they will engage in corrupt or improper conduct on our behalf.

• Deal with a party that refuses to disclose its true identity (including details of company beneficial ownership).

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Hypothetical scenarios
Q: I have recently arrived in a new city on an assignment. I've obtained approval to join a business association which has good access to local officials. They've now asked if BHP can sponsor a table at their annual dinner for $1,000 per head. The profits from the event will fund the association's annual golf event for local officials. What should I do?
A: As the association has indicated the funds will be used for a golf event – which is something of value for local officials – pre-approval is required under the Our Requirements for Business Conduct standard. Our Compliance team can advise you on what arrangements would be appropriate.
Q: I speak regularly with a government official who is responsible for making decisions that will affect BHP. His son has recently graduated with first class honours from university at a location where we have an office and wants to find a job so he can stay in the country. The official has enquired if BHP has any jobs and whether I can do anything to help his son.
A: A job is something of value and the son is a close relative of an influential government official. Given the official is currently making decisions which will affect BHP, this could be used or misinterpreted as a form of bribery and could constitute a breach of anti-corruption laws. The official’s son can apply for advertised jobs and his application will be assessed on its merits in the same manner as any other job application. For further guidance, contact our Compliance team.
Q: A vendor I regularly work with offers to send me to a three-day course at their educational centre on topics relevant to my role. I’d like to attend because I think it will benefit BHP, help me stay on top of trends in the industry and increase my ability to perform my role. The vendor is hosting the course regardless of whether I attend, and my attendance will not be an additional cost to the vendor. Can I accept the offer?
A: If attending the course will in any way compromise (or might reasonably be seen by someone else as compromising) your ability to perform your duties loyally to BHP, or might prevent you from working with the vendor without bias in the future, you should not accept the offer. If BHP is currently in a tender with the vendor offering the course, you should also not accept the offer. Otherwise, estimate the value of the course and record the offer in the Gifts and Entertainment register, seeking your line leader’s approval to attend. If you are approved to attend, book and pay for any travel expenses following our business travel expense guidelines.
View more hypothetical scenarios

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