BHP Billiton – Operating with integrity
Wherever we operate in the world, we strive to work with integrity – doing what is right and doing what we say we will do.
Working with ethics and integrity
We are fully committed to working with integrity and our Code of Business Conduct (the Code) specifically prohibits engaging in unethical behaviour. Like safety, working with integrity – doing what is right and doing what we say we will do – should be the starting point for everything we do. We care as much about how results are achieved as we do about the results themselves.
Our approach
Operating responsibly and ethically involves bringing Our Charter values to life. We deliver on our commitments to our shareholders, employees and host communities by demonstrating these values through our actions, processes, systems and interactions with all stakeholders. We constantly look to learn and develop, to seek out ways in which we can improve how we do our work. Our approach to ethical conduct and regulatory compliance is no different, evolving over the last two decades as our Company has grown and expanded into many locations around the world.
Anti-corruption compliance
Anti-corruption compliance is an important part of our commitment to our communities. If left unchecked, corruption deprives communities of the benefits that should flow from the development of natural resources and undermines government decision making. We are determined to play a significant role in the global fight against corruption in the resources industry. Building on a strong framework with a focus on continuous improvement, we have what we consider to be a world-class anti-corruption compliance program.
Anti-corruption standards and procedures
BHP’s Code of Business Conduct and anti-corruption standard (Group Level Document) clearly prohibit bribery and corruption in all our business dealings (as the Guide did before it). We prohibit making facilitation payments which are payments to government officials to obtain routine services to which BHP is otherwise legally entitled. The obligations for employees and contractors are clear and the Company provides training and support to ensure they are understood. Similarly, senior management are required to incorporate anti-corruption compliance into business key performance indicators that ultimately determine employee remuneration.
Our anti-corruption standard also requires review or approval by the Compliance Function of activities which potentially involve higher risks of exposure to corruption including:
- the provision of gifts, travel, and hospitality (including for government officials) above certain thresholds;
- the offering of commercial sponsorships;
- the offering of community donations or projects;
- acquisitions and divestments.
Compliance Function approval is also required before engaging third parties who interact with others on our behalf (which we refer to as “business partners”) and before entering joint ventures or co-investments. A risk-based system is used to assess business partners and determine due diligence and other compliance requirements prior to approval. All suppliers must comply with various “zero tolerance” requirements, including BHP’s expectations in relation to anti-corruption compliance.
Other standards and procedures include a prohibition of the use of cash throughout the Company (unless approved by the BHP Chief Financial Officer) and the development of a tailored anti-corruption audit plan. These finance-related controls have been facilitated by the progressive launch (through to 2012) of our single master data system and the ability to create sensitive payment accounts.
Anti-corruption risk assessments
All Assets and Functions within BHP are required to conduct regular anti-corruption risk assessments with the Compliance Function focusing their attention on their highest areas of risk. Risk assessments form a critical part of the compliance program, ensuring that resources are focused on the highest areas of risk and that an adequate set of controls has been adopted to mitigate these risks. Anti-corruption risk assessments follow BHP’s standard risk assessment process, including a process for identifying and regularly testing the effectiveness of the controls which are regarded as critical to manage corruption risk.
Anti-corruption training
Thousands of employees across all of our locations undertake anti-corruption training developed by the Compliance Function. Individuals who require anti-corruption training complete either online training or in-person training direct from a member of the Compliance team focusing on the corruption risks they are likely to face. In addition to anti-corruption training as part of annual training on our Code, additional risk-based anti-corruption training was completed by 3,412 employees in FY2024, together with numerous employees of business partners and community partners.
Independent monitoring and audit
The Compliance Function conducts regular monitoring of financial and other data to check the operation of key controls such as the requirement to obtain pre-approval before engaging in higher corruption risk transactions and compliance with training requirements.
A separate independent, internal audit team conducts regular anti-corruption audits to assess implementation of anti-corruption controls and to identify transactions and conduct that is not consistent with BHP’s policies, standards and procedures.
Any breaches of process detected during monitoring or auditing are considered by the Compliance Function to assess whether further investigation is required.
Confidential reporting and investigations
Reporting suspected corruption issues is encouraged at BHP as we encourage our employees to feel safe to speak up. Reports can be made a number of ways including through a global confidential whistle-blower hotline, EthicsPoint. Any retaliation against someone who speaks up and reports an issue is prohibited by our Code.
The Compliance legal team manages investigations into all potential anti-corruption issues, whether these are reported through EthicsPoint or through employees.
Design and continuous improvement
We know that our compliance journey is never over; we will continue to learn and look for better ways to manage this critical area of business. BHP’s Compliance Function regularly reviews the design of the anti-corruption compliance program and uses the results of monitoring, audits and investigations to make appropriate enhancements.
These measures collectively make up our anti-corruption compliance program and contribute to the global fight against corruption.
Climate Risk: Portfolio Analysis Views after Paris
In 2024, we launched our Climate Change: Portfolio Analysis report which described our approach to portfolio evaluation and scenario planning, including the implications of a transition to a lower emissions future for our portfolio. The report has been of considerable interest to stakeholders since it was launched. One area of particular interest was how we monitor ongoing external developments and factor them into strategic planning.
This new document, Views after Paris (PDF 3 MB) describes some of our observations from the past 12 months and their potential portfolio impacts. It also provides further details on some of our key climate change related assumptions and an update on recent actions we have taken related to climate change.
Views after Paris a further demonstration of our commitment to climate change-related disclosures. It describes:
- Our approach to strategic planning
The processes and tools we use to inform decision-making. - Our insights
The latest signals we are seeing in the external environment which indicate how the world is tracking towards a lower emissions outcome. - Portfolio implications
The implications these signals could have for BHP Billiton. - Our actions
- The actions we are taking to manage climate change risk.
Closure planning
In recognition of the potentially significant financial, environmental and social risks associated with future closure of our operations, we consider the entire life cycle of our assets, including closure, in our planning and decision-making.
Our governance framework for mine closure seeks to integrate resource planning and development; health; safety; environmental; community and social considerations; stakeholder engagement; risk; finance; and assurance in the operational design.
Our assets are required to develop a closure plan, including a financial assessment, to minimise closure-related risks over the life of the asset. Our Internal Audit function tests the effectiveness of these plans, with findings reviewed and reported annually to Asset Presidents, and summary reports provided to the Risk and Audit Committee. Information about BHP’s financial provisions related to closure liabilities is available in our Annual Report 2024.
We consider a range of possible closure alternatives for a site, including ongoing management, alternative land uses (that may include re-purposing the site for a beneficial use), divestment and relinquishment. To minimise the potential of adverse environmental impacts following closure, we also apply the Our Requirements for Environment and Climate Change standard to our closed sites. Our closed sites are required to maintain and enact closure management plans with long-term monitoring to verify that controls are effective and performance standards are maintained.
To leverage closure management knowledge and expertise across our global operations, a Resource Engineering Centre of Excellence was established in FY2024. This Centre of Excellence collaboratively engages through our Group-wide closure working group that meets to share best practice and discuss process improvements. We continue to improve our approach to closure planning to minimise closure legacy risks to biodiversity and water resources.
Environmental considerations and mine closure
Properly managing risks to biodiversity and water resources into closure is a significant issue. As a result, we are continuing to improve our approach to closure planning so that we can minimise closure legacies during operations.
Where we have existing closed sites we continue to apply Our Requirements for Environment and Climate Change standard so that impacts are identified and options implemented to minimise the potential of adverse environmental impacts. In addition, closed sites are required to perform long-term monitoring to verify that the controls are effective and that the performance standards are maintained.
Competition law compliance
We are committed to full compliance with competition laws, and the enforcement of competition laws against those third parties who act in an anti-competitive manner towards our Company.
We prohibit all forms of anti-competitive conduct with our competitors, including:
- price fixing and bid-rigging;
- fixing other competitive terms, such as margins or rebates;
- limiting production, or agreeing to reduce or limit production capacity;
- allocating markets, customers, suppliers or geographic territories; and
- boycotting any customer or supplier.
We have also established standards and procedures to ensure that the Compliance and Legal Functions conduct a prior legal review of competition law-sensitive activities.
For example, prior legal review is required before entering into many types of agreements with competitors, and before joining any trade association or industry body involving competitors. Renewals of existing agreements or memberships are also subject to review.
Competition law risk assessments
All Businesses and Marketing are required to conduct periodic competition law risk assessments in consultation with the Compliance and Legal Functions. These follow our standard risk assessment process, including a process for identifying and regularly testing the effectiveness of the controls which are regarded as critical to manage competition law risk.
Competition law training and awareness
Each business and function identifies employees whose roles involve potential competition law risks, for example those having regular interaction with competitors. These employees receive regular training, developed and largely delivered by the Compliance Function. As with anti-corruption, competition law training may be delivered either online or in-person, and is focused on the needs of a business or function.
Steps are taken across BHP to regularly raise awareness of competition law issues. These include periodic messages from senior management emphasising the need for competition law compliance and the importance of working with integrity in our dealings with third parties including competitors.
Confidential reporting and investigations
Employees are supported and encouraged to report suspected competition issues via their manager, through the Legal and Compliance Functions or through EthicsPoint. We also encourage people to report anti-competitive behaviour of competitors, suppliers or customers.
The Compliance legal team manages investigations into all potential competition law issues, whether these are reported through EthicsPoint or by other means.
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