Avoid conflicts of interest

We make decisions that are in the best interest of BHP.

A conflict of interest happens when your personal interests or situation interferes with your ability to make impartial decisions in your role at BHP. Conflicts can come from a range of circumstances, such as your personal relationships, an outside role or affiliation, your investments – anything that might sway your judgement. Conflicts can also arise during a normal business relationship due to a change in circumstances. Conflicts of interest can be damaging for you, our business, and stakeholder relationships because they undermine trust in our integrity. For these reasons, it’s important we limit, report and manage conflicts of interest.

Avoid conflicts of interest

  • What it means for you

    We act in the best interest of BHP by declaring and following instructions to manage conflicts, including the perception of a conflict, consistent with Our Requirements.

     

    This means you must declare any actual, potential, or perceived conflict of interest in the Conflict of Interest Register, or to your BHP contact if you are a supplier. Examples of conflicts, or potential conflicts, you must declare include: 

    • awarding BHP business opportunities to a company owned by you or a close friend or relative 
    • holding outside jobs or affiliations, including directorships 
    • intending to participate as an individual in the political process, e.g. running for political office 
    • being in a close personal relationship with someone in your reporting line, including as a close relative, or in a romantic or intimate relationship. 

    Receiving gifts, services or offers of travel or accommodation from external parties can also be an actual, potential or perceived conflict of interest. We follow Our Requirements to manage these risks and ask for advice if uncertain.

  • How you make an impact  
    You remain alert for actual, potential or perceived conflicts of interest and disclose them in the Conflict of Interests Register. You seek advice if you’re unsure whether a situation represents a conflict of interest. 
  • Resources
    Conflict of Interest Register
    Business Conduct Global Standard
People computer

Always

• Excuse yourself from any decision-making process where you have an interest that could influence your ability to make an objective decision.

• Report all actual, potential or perceived conflicts of interest
in the Conflict of Interest register.

Person presenting

Never

• Hire, promote or directly supervise a close relative, or use businesses of close relatives unless this has been specifically authorised via the Conflict of Interest register.

• Appoint or award business to any party that you are personally or financially associated with.

• Misuse BHP resources (including information) or your position of influence at BHP to promote or assist an external activity or party.

• Interfere in the fair and transparent operation of bid or tender activities.

• Accept gifts, hospitality, entertainment or other favours or benefits from anyone you are evaluating in a bid or tender with BHP.

Hypothetical scenarios

  • Q: My partner’s consultancy specialises in an area that BHP needs advice. Can I recommend their business?

     

    A: You can make the team aware of your partner’s connection to the business, however, you should be completely transparent about your interest so Procurement’s processes can be independently applied. Discuss the recommendation with your line leader, ensure the details are registered in the Conflict of Interest register and that a suitable plan to manage this potential conflict of interest is put in place.
  • Q: My regular contact from an important supplier has invited me to a music concert where their company has booked a hospitality room. They tell me they won’t be there but offer me a second ticket to bring a friend or partner. Should I go to the concert?
    A: You should check the tickets are of a modest and reasonable value. You may need to estimate the value based on equivalent ticket prices and consider if the invitation will include a reasonable degree of business relationship-building. If your contact is not attending and it is not clear who will be your host, you should decline the invitation. Your line leader should also be able to advise on the appropriateness of attending. Register the offer in the Gifts and Entertainment register and if intending to accept the offer, check the Our Requirements for Business Conduct standard for any pre-approval requirements.

     

  • View more hypothetical scenarios

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How to speak up

If you have questions about Our Code, speak to your line leader, 2Up leader, Ethics and Investigations, Compliance, or Legal. Employee Relations or a HR Business Partner can direct you to the relevant reporting options available. You can also seek further information and resources via BHP’s RespectChat.  Anyone who works with us, on our behalf, or is associated with us, can also raise misconduct concerns via Integrity@BHP or the BHP Protected Disclosure Reporting Channel.

Online: Make a report in either Integrity@BHP or the BHP Protected Disclosure Reporting Channel. 

Phone: You can also contact the BHP Protected Disclosure Reporting Channel by phone. 

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