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.