Skip to content

Our ability to conduct business is directly affected by government decision making, so it’s important we have open and constructive relationships with them.

In this section we'll cover:

We regularly share information and opinions with governments on issues that affect our operations and our industry. This exchange of information and opinions enables informed decision making by both governments and our Company.

Our expectations of you

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.

Our expectations of others who work with us

When you work with BHP please make sure you are familiar with our requirements for engaging with governments. If you are conducting business on behalf of BHP you must not jeopardise any of our government relationships. Ask your primary contact for more information about how we work with governments.

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

Always

  • Talk to Corporate Affairs before you engage with government officials on public policy or issues that could impact BHP’s reputation or licence to operate.
  • Be truthful, accurate and cooperative when dealing with government officials.
  • Comply with all applicable laws and regulations.
  • Consider potential corruption risks when dealing with government officials.
  • Seek approval for involvement in any business-related event or activity organised by, or on behalf of, a political party or candidate and be transparent when undertaking such activities.
  • Discuss with your line leader and 2Up leader and advise in writing if you plan to seek or accept a role in public office and log this plan in the Ethics and Compliance Register, if appropriate. Make it clear that you are not acting on behalf of BHP.

Never

  • Authorise, offer, give or promise anything of value directly or indirectly to a government official to influence official action.
  • Attend an event or activity during work hours or on behalf of BHP which is intended for political fundraising.
  • Attempt to obstruct the lawful collection of information, data, testimony or records by appropriately authorised government or regulatory officials or hinder the lawful and proper provision of such information by another employee.
  • Take retaliatory action against anyone who lawfully and properly cooperates with government agencies.
  • Accept information about a government’s competitive selection of a supplier or competitor’s bid or proposal (unless the government has specifically and lawfully authorised the release of the information).
  • Use, or allow others to use, any BHP information assets or resources for a political campaign, party or candidate, elected official or any of their affiliated organisations.
  • Pay wages or salaries, fringe benefits or remuneration of any kind to a BHP employee working for a party or candidate during normal working hours.

 

Version 2.1, last updated 16 August 2018

scroll up to top of page scroll down to bottom of page
Loading the player...