Everywhere we operate, we are committed to doing what is right and doing what we say we will do. That’s why Our Code matters. It helps us deliver on our purpose and make better decisions every day. 

Our Code: 

• provides clear guidance on how Our Values are put into practice  
• outlines the commitments that guide how we work together safely, respectfully, and ethically  
• helps you make better decisions and know where to go for further information, or help 
• explains how to raise concerns or seek help if you see or suspect a breach of Our Code. 

How to use Our Code

• Our Values and Our Code, supported by Our Requirements, work together to guide your decisions, behaviour, and actions. Our Requirements are the suite of Global Controlled Documents (including Global Standards) that set the mandatory minimum performance requirements for BHP. 
• Our Code outlines what BHP’s commitments mean for you. Each section of Our Code sets out how BHP expects you to act. 
• When local laws or regulations are less strict than Our Code or Our Requirements, it’s important we adhere to BHP’s higher standard of behaviour. 

When you work for us, with us, or on our behalf, Our Code applies to you. Our Code applies when on site, in our offices, working remotely, in camp or other BHP-provided accommodation, at BHP functions, when travelling for work, and when you are representing BHP.  

Our expectations of you: 

• Know Our Code: Read and understand Our Code, staying up-to-date with our supporting resources and training.
• Uphold Our Code and Our Requirements: Comply with Our Code and Our Requirements, including any standards, processes and procedures that apply to your role, and all applicable laws and regulations of the country in which you’re working. 
• Live Our Values: Bring Our Values to life through your daily actions. 
• Make better decisions: Use the Quick Test and guidance from your peers, leaders and other support resources to ensure your decisions align with Our Values.  
• Speak up: Speak up and report any concerns or breaches. 

Breaching Our Code

Breaching Our Code, breaking the law, or otherwise behaving in a way that compromises Our Values can have serious consequences, including removal from site, termination of employment or contract. In some cases, conduct causing a breach of Our Code may also be a breach of law and carry civil or criminal penalties. 

The Quick Test is a tool to help you evaluate different aspects that contribute to making a good decision.  

We use our Quick Test to make safe, responsible, and ethical decisions we can stand behind. All of our decisions should be guided by Our Values. You should consider: 

• Safety: Could this directly or indirectly endanger someone? 
• Media: How would this look in the news? 
• Law: Is this compliant with Our Code, Our Requirements, and applicable laws and regulations?  
• Family: What would I tell my partner, parent, child or friend to do? 
• Feel: What’s my intuition or ‘gut feel’? How would I feel if this was seen, overheard or shared with a colleague, leader or stranger? 

We all share the responsibility to speak up when something doesn’t seem right. Ensuring everyone feels safe to speak up is crucial, which is why we have multiple ways you can voice your concern. 

You can raise your concern with your line leader, or 2UP leader. Alternatively, you can reach out to Ethics and Investigations, Compliance, Legal, an Employee Relations advisor, or an HR Business Partner. Anyone who works with us, on our behalf, or is associated with us, can also raise concerns via Integrity@BHP. 

If you’re a community member, former employee or contractor, supplier or vendor, or you work for a supplier or vendor, you can speak with your BHP contact point, access the community complaints and grievance mechanisms available for each of our operations or contact Integrity@BHP. 

If you don’t feel safe or comfortable using the above channels or if you otherwise prefer, you can report your concern using the BHP Protected Disclosure Reporting Channel or through another option set out in the BHP Whistleblower Policy. Reports may be subject to protections under the BHP Whistleblower Policy. 

Reports can be made anonymously. Anyone can raise concerns at Integrity@BHP or through the BHP Protected Disclosure Reporting Channel. 

We treat every reported concern sensitively, respectfully and confidentially. Our Ethics and Investigations team will assess and triage reported concerns according to the categories set out in the Business Conduct Global Standard. If required, further investigation will be performed by Ethics and Investigations, Compliance, a leader, HR/Employee Relations and/or an external investigator. 

We encourage employees and contractors to speak to their line leader, 2Up leader or Ethics and Investigations, to contact Integrity@BHP or the BHP Protected Disclosure Reporting Channel if they have any queries or issues during this process. 

We encourage an open, inclusive and supportive environment and do not tolerate retaliation. This means we will not allow any form of punishment, discipline or retaliatory action to be taken against a person for speaking up, intending to speak up, being suspected of speaking up, or for cooperating with an investigation. 

We encourage you to report any instance where you believe you or anyone else may be, or have been, retaliated against for speaking up. In some circumstances, you may also have legal protection when you speak up as outlined in the BHP Whistleblower Policy. We keep information reported confidential, consistent with applicable laws and regulations and good business practices, and your identity will only be disclosed if we are otherwise compelled by law, if you’ve consented, or if we determine it’s necessary to refer the matter to emergency services, law enforcement or a regulator. 

If you believe you or anyone else may be, or have been, retaliated against for speaking up, report to your line leader, 2Up leader, Ethics and Investigations, Compliance, Legal or Integrity@BHP or the BHP Protected Disclosure Reporting Channel. 

Nothing in Our Code or otherwise is intended to prevent you from, or requires approval for, reporting to an appropriate government authority or law enforcement body, or from seeking legal advice in relation to your rights.