You need to maintain honest relationships with governments and their agencies, officials and personnel. You must apply Our Requirements for Business Conduct to all interactions with governments.
It is important that our engagement with government is consistent and aligned with company policy. If you are engaging with government on matters other than of a routine regulatory nature, you must speak with Corporate Affairs before proceeding and must obtain Corporate Affairs’ approval for any submissions to government on behalf of the Company. This includes responses to government inquiries and submissions or papers on proposed legislative reforms.
Chief Compliance Officer’s approval must also be obtained before submitting an official response on behalf of BHP to an anti-corruption, competition, sanctions, state secrets or financial markets enforcement agency.
All information provided to governments and third parties on behalf of the Company must be accurate and appropriate for the purpose.
Government events and political activities
You may be able to participate in events or activities organised by a political party, politician, elected official or candidate for public office if your involvement is for business, related to policy briefing, and the activity is supported by your line leader. Events or activities cannot be related to political fundraising.
Activities that require registration and approval in advance include:
- payment for tables at functions or events with a clear business purpose which are sponsored by, or associated with, any political party, politician or political candidate;
- sponsoring research by ‘think tanks’ affiliated or linked to political parties;
- involvement with any event organised by, or on behalf, of a political party for which a fee is paid and is not related to, or perceived as, political fundraising.
We recognise employees’ rights and respect their choices to participate as individuals in the political process provided you make it clear that you are not representing BHP.
You must notify your line leader and your 2Up leader if you intend to pursue political office as soon as you decide and document this in writing. You will need to apply for leave if you are running for office. You will also need to apply for leave if you are carrying out the duties of public office during normal working hours. You may need to resign from your position at BHP if you win your candidacy.
Participation, including your time and money, must be made on your own account and your political opinions must not be presented as being those of our Company. You won’t be able to use any information or BHP resources that you have had access to in your role or via your employment during your involvement in the political process. Similarly, you can’t access BHP support in any form while running for office or carrying out activities of public office.
As a line leader of an employee who decides to be involved in the political process, you must speak to Ethics and Compliance for guidance as soon as you are made aware of the employee’s decision.