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We must never jeopardise the trust of communities, customers, suppliers or coworkers by using confidential information for financial or personal benefit.

In this section we'll cover:

Inside information is material information about a company that is not generally available to the public. Whether information is material is generally judged by whether it would affect a reasonable investor’s decision making.

Examples of possible inside information include:

  • the financial performance of BHP against market expectations;
  • entry into or termination of a significant contract;
  • actual or proposed mergers, acquisitions or joint ventures;
  • actual or possible discoveries of, or significant adjustments to, ore bodies or oil reserves.

In the course of your job you may learn confidential information before it is made public, and it’s not an offence to possess inside information. But in many countries it is a criminal offence to buy, sell or otherwise deal in relevant securities while you have inside information. This is called insider trading.

It is also a criminal offence to encourage insider dealing or to disclose inside information with a view to others profiting from it.

Our expectations of you

If you possess inside information, you should not advise or encourage another person (for example, a relative, a friend or family company or trust) to buy, sell or otherwise deal in the relevant securities or pass the information to another person.

It may also be a breach of your obligations of confidentiality to disclose information, whether or not the information is used to deal in the relevant company’s securities.

If you have been placed on a Securities Dealing Restricted List or you are a Person Discharging Managerial Responsibilities in accordance with Our Requirements for Securities Dealings you need to gain approval from a designated Clearance Officer before engaging in any transactions involving BHP securities. If you have been placed on an Insider List, then you must not deal, or encourage others to deal in BHP securities.

If you are an employee participating in any employee share scheme (excluding Shareplus), you must not buy, sell or otherwise deal in BHP securities during any close period, regardless of whether you hold inside information.

Where BHP has a business relationship with another company, you should be careful if you trade in that company’s shares, as the same insider dealing rules apply to all shares. These types of investments may also give rise to an actual or perceived conflict of interest.


Where to go for help
  • Group Governance
  • Legal
  • Your line leader or 2Up leader
  • EthicsPoint

Always

  • Maintain the confidentiality of BHP information.
    • Ask yourself if the market was aware of all the current circumstances, could the proposed dealing be perceived as taking advantage of your position in an inappropriate way?
  • Seek advice from Group Governance or Legal if you are considering dealing in securities and have any doubt.
  • Carefully consider the information you disclose about what you are working on, where you are going on BHP business, who visited the office or site or what you talk about with other BHP employees.
  • Take measures to avoid accidentally sharing inside information. This could involve not talking about confidential information in the elevator and not leaving confidential information on a copy machine.

Never

  • Buy or sell the securities of BHP (or any other company) either directly, through relatives, other persons or entities while you are aware of inside information.
  • Disclose inside information to anyone outside BHP unless it is appropriately authorised, documented and is necessary for the Company’s business activities.
  • Recommend or suggest that anyone else buy, sell or deal in the securities of any company, including BHP, while you have inside information about the company.
  • Spread false information or engage in other activities to manipulate the price of publicly listed securities.
  • Trade in the shares of other companies when you have access to inside information that, if made public, could affect that company’s share price.

Version 2.1, last updated 16 August 2018

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