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Our commitment to operating with integrity is part of who we are and what we do every day. We prohibit bribery and corruption in all our business.

In this section we'll cover:

How we go about our business matters. Corruption misallocates resources, reinforces poverty, undermines the integrity of government and community decision making, and results in waste of the opportunities that arise from resource development.

Compliance with anti-corruption laws is essential to protect BHP’s reputation and to preserve our licence to operate. All our employees, contractors, directors (executive and non-executive) of our Boards, and third parties we deal with, including our suppliers, are required to comply with anti-corruption laws. No one has the authority to waive this requirement. Criminal penalties could result where anti-corruption laws are not respected.

Any concerns regarding corruption must be reported immediately.


Our expectations of you

Our Requirements for Business Conduct provides guidance about managing corruption risk.

You must not authorise, offer, give or promise anything of value, directly or indirectly (for example, through a third party), to anyone to influence them in their role, or to encourage them to perform their work disloyally or improperly.

You should never make facilitation payments which are payments to government officials for routine services that are legally available. However, a payment made in the face of a threat to the health or safety of a person is not a facilitation payment. You should always act in a manner that best protects your health and safety. If you do make a health and safety payment, report it to Ethics and Compliance as soon as possible.  

You must get pre-approval before:

  • offering anything of value to an external person;
  • engaging a supplier who will interact with others on our behalf;
  • offering to undertake a community donation or project;
  • offering to sponsor an event.

When you offer or provide anything of value to an external person, the item must:

  • only be offered or provided for a legitimate business purpose;
  • not be offered or provided to improperly influence or reward action;
  • be legal under local laws;
  • be of appropriate value and nature considering local customs and law, the position of the recipient and the circumstances;
  • not be capable of causing reputational damage to BHP.

Our expectations of others who work with us

We expect everyone who works with us to share our commitment to integrity in all business dealings and in providing services to us.

Where to go for help
  • Ethics and Compliance
  • Legal
  • Your line leader or 2Up leader
  • Human Resources
  • EthicsPoint


  • Record all transactions accurately and in reasonable detail to reflect their true nature.
  • Understand the role and interests of the person who you are dealing with.
  • Provide accurate and complete information when seeking pre-approval.
  • Get pre-approval before offering or giving anything of value, a commercial sponsorship or a community donation or project.
  • Act in the best interests of your health and safety.
  • Immediately report any corruption concerns.


  • Offer, promise, give or approve anything of value (including a daily allowance or per diem, cash or cash equivalent) of any kind to a government official to influence official action, including facilitation payments without prior authorisation from Ethics and Compliance. This also applies to a political party, elected official or candidate for public office.
  • Offer, promise, give or approve schemes which give an improper benefit to anyone.
  • Establish a hidden or incorrectly recorded fund for prohibited payments.
  • Use personal funds, divide payments, 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.

Version 2.1, last updated 16 August 2018

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