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As a publicly listed company, we are required to disclose information in a timely, accurate, consistent, complete and fair manner so investors can make informed decisions.

We also need to apply Our Charter values to informal interactions when communicating about BHP.

In this section we'll cover:

To make sure we provide timely and accurate information to investors, our public disclosures are carefully managed and must only be made by authorised spokespersons. Any public communication that can be attributed to BHP, or to one of our employees, may be seen as a public disclosure.

All of the following are considered public disclosures:

  • regulatory filings, such as annual reports, news releases, briefings on profit and business performance;
  • interviews, speeches, presentations articles and reports;
  • Company information on digital communications channels, like websites and social media.

Communicating on social media

Social media is a big part of most of our lives. BHP views social media activity in the same way we view any kind of interaction: through the lens of Our Charter values and Our Code.

Your activity on social media can reach more people than ever before. While using social media may feel casual and spontaneous, activity is permanently retained and can be traced back to you. We want you to be able to make good decisions and avoid activity that could result in negative consequences for you, such as criticism by external parties, personal information theft or disciplinary action by the Company.

What should I consider?

If you are active on social media, please use your common sense and judgment and consider the following:

  • Is my activity in line with Our Charter values and Our Code?
  • Can the Quick Test help you decide what to do next?
  • Is my activity appropriate, given my role? If your role or your interactions with external parties mean you could be perceived as a BHP spokesperson, it’s best to state the views are your own when commenting about our Company, our industry or topics of relevance to us.
  • Are my comments accurate and not misleading?
  • Is the information sensitive or confidential? Could I be putting BHP or myself at risk if this information became public? Would I be comfortable if the media republished this information?
  • Am I comfortable that my social media activity could be viewed by many people around the world, traced back to me and permanently retained?
  • Do I have a right to use the information, including the text, images, footage or any logos, or do I need permission? Consider individual rights to personal information and privacy, confidentiality obligations, approval rights and intellectual property rights such as copyright.
  • Is social media the appropriate forum or should I speak with my line leader, 2Up, Human Resources or in EthicsPoint?
  • Could my social media activities be used as part of identity theft? For example, someone may be able to reset your online passwords by gathering answers to your security questions, such as ‘What is your favourite movie?’ and ‘What school did you go to?’

If you think you possess, or have released, material information that has not been disclosed to the public, you must immediately report it to Investor Relations, a Disclosure Officer or Governance. Disclosure Officers should also be alerted to information that may require future disclosure to the stock exchanges. A list of Disclosure Officers is available from Group Governance.

Our expectations of you

When you communicate externally, you should always act in accordance with Our Requirements for Market Disclosure, Our Charter values and Our Code.

If you are an authorised spokesperson or work in a team responsible for market disclosure, you must immediately release, through the relevant exchanges, any information or major developments which could have a material effect on the share price, or where an investor is likely to use that information to make investment decisions.

If you have prepared external communication materials, you must have them approved by Corporate Affairs.

It’s important you feel empowered to speak positively about BHP when asked by relatives and friends. To be able to do so, it’s important you understand the distinction between information about the Company that should be shared, and material information which can only be communicated by authorised spokespeople.

Our expectations of others who work with us

This section applies equally to those who work with us. If you have any questions or need further information please speak to your primary contact.

Where to go for help
  • Corporate Affairs
  • Investor Relations
  • Disclosure Officer
  • Governance and Company Secretariat
  • Your line leader or 2Up leader
  • EthicsPoint


  • Follow the rules relating to who can make public statements on behalf of BHP.
  • Ensure all public communication is complete, fair, accurate, timely and clear.
  • Obtain all relevant approvals prior to publicly releasing material.
  • Report media and investment inquiries promptly to Corporate Affairs or Investor Relations.
  • Report the loss or theft of BHP information (for example, your computer or briefcase) to your line leader immediately.
  • Advise your line leader or 2Up leader if you are attending an informal external event, such as a trade meeting or professional networking event.
  • Get approval from your Business to present an external speech or participate in an external panel discussion.
  • Send a copy of your speech or presentation, along with a completed ‘Speeches and presentations template’ (available in Our Requirements for Communications, Community and External Engagement), to Corporate Affairs for review and feedback.


  • Disclose information to the public unless you are specifically authorised to do so.
  • Divulge confidential information unless you are an authorised spokesperson. If you are unsure about the degree of confidentiality assigned to information, contact Corporate Affairs.
  • Say anything that may disclose confidential information or cause harm to our reputation.
  • Conceal facts or omit information that may be relevant to a disclosure.
  • Use BHP trademarks or branding unless you are specifically authorised to do so.

Version 2.1, last updated 16 August 2018

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