Our approach to prevent sexual harassment 

Sexual harassment has been defined as a health and safety risk at BHP since CY2018. Since this time, we have engaged our workforce and external experts as we address harmful behaviours with a risk-based approach. In FY2025, we integrated sexual harassment into a broader focus on psychosocial harm risk. 

Priority focus areas have included achieving and maintaining gender balance, creating a safe and respectful workplace, building accountability and capability of leaders, upskilling our workforce to be active bystanders, enhancing our policies, processes and controls, and providing person-centred and trauma-informed response and support.  

BHP’s strategy to eliminate sexual harassment is underpinned by the Australian Human Rights Commission Guidelines for Complying with the Positive Duty under the Sex Discrimination Act 1984 (Cth). In developing our strategy, we sought guidance from external experts such as Kristen Hilton and Kate Jenkins AO, along with Queensland University of Technology. The strategy seeks to enable prevention by addressing the drivers and risk factors of sexual harassment and enhance our response to incidents and support for impacted persons. 

Going forward, BHP’s focus remains on: 

• initiatives that maintain gender balance across our operations 
• implementing our enhanced suite of sexual harassment prevention controls, which incorporate organisational learnings and third-party expert recommendations 
• engaging and empowering our entire workforce to take action as active bystanders and enhancing their capabilities 
• encouraging increased incident reporting and enhancing our approach to supporting impacted persons so they can thrive at BHP 

Reports of sexual harassment 

There was a 3 per cent increase of reports of sexual harassment from 417 in FY2024 to 429 in FY2025 and a 6 per cent decrease of reports of racial harassment from 109 in FY2024 to 103 in FY2025.¹ These behaviours are unacceptable and BHP is continuing to work towards eliminating them. In FY2025, 53 per cent of sexual harassment reports and 52 per cent of racial harassment reports received into BHP’s misconduct reporting channels were logged by managers or leaders on behalf of the workforce. 

During FY2025, 102 cases of sexual harassment² and 24 cases of racial harassment were established following investigation across BHP’s global operations, including conduct on-site, off-site and in offices.³  

100 individuals responsible for sexual harassment and 20 responsible for racial harassment had their employment terminated (or were removed from site if a contractor) or resigned. 

Of the 102 established sexual harassment cases: 

Leadership

BHP is focused on leaders understanding the need to prevent sexual harassment at BHP and being visibly committed to safe, respectful and inclusive workplaces through setting clear expectations and role modelling respectful behaviours.  

Our position on sexual harassment is reinforced through regular senior leadership communications. These include messages from our CEO, Executive Leadership Team and on-site signage regarding our expectations and avenues for support.  

Respectful behaviour and sexual harassment prevention and response training is provided to BHP line leaders, aimed at setting clear expectations about appropriate conduct, supporting leaders to respond appropriately and drive consistent disciplinary outcomes. 

Risk management

Psychosocial harm risk assessments identify scenarios in which psychosocial hazards like sexual, racial or gendered harassment may arise, their potential causes and the controls we can implement to prevent and reduce the risk of harm as far a reasonably practicable.  

Some of our embedded psychosocial risk preventative and mitigating controls include: 

• mandatory training in Our Code of Conduct for employees and contractors, with a focus on enacting and maintaining respectful behaviours  
• setting clear cultural expectations and leadership responsibilities   
• enhanced security at accommodation villages  
• alcohol management policies   
• data transparency and action  
• person-centred response and support  
• accessible and confidential reporting options and investigations, including multiple resolution options  
• appropriate and proportionate disciplinary action

During FY2025, we moved to a new global Employee Assistance Program (EAP) provider, Converge International. Converge International provides a dedicated panel of psychologists who are trained in trauma-informed practices, each with more than five years of experience working with individuals impacted by sexual harassment. 

The new EAP provider also offers a broader range of holistic support services, including nutritional, career, financial and legal counselling. This has enabled us to introduce specialist helplines, such as for domestic violence, Indigenous employee support and LGBT+ hotlines.  

Culture 

We are committed to fostering a positive culture that is safe, respectful and inclusive for all employees and contractors, and supports gender equality and diversity at all levels and across all areas. We define gender balance as a minimum 40 per cent women and 40 per cent men, in line with the definitions used by entities such as the International Labour Organization. Gender balance is recognised as a protective factor in relation to sexual harassment.

BHP expects suppliers and contractors in our ecosystem to have shared values around preventing sexual harassment and sex-based discrimination in our industry and communities. Third-party contractors are expected to comply with Our Code of Conduct and have access to Integrity@BHP, Support Service and other related care and medical/psychological treatment pathways. Contractors are also embedded in many aspects of BHP’s way of working, including routines such as toolbox talks and safety shares, perception surveys and required training.

Knowledge of sexual harassment prevention and response 

Since FY2018, we have continued to develop a sustained program of work designed to increase the capability of our workforce to identify and call out disrespectful behaviour, including sexual harassment, racism and bullying.  

Responsibility for managing psychosocial risk (including sexual harassment and racial harassment) is shared within BHP. The Group Health team is accountable for: 

• performing second-line assurance of BHP’s performance against this risk 
• engaging with industry to share and learn best practice 
• supporting our operated assets and functions to progress improvements to control psychosocial risk 

Support and reporting 

BHP prioritises the wellbeing, psychological safety and needs of people affected by sexual harassment, unlawful sex-based discrimination and victimisation. We established our global Support Service in FY2022 to provide dedicated, end-to-end case coordination for anyone impacted by sexual harassment, which is designed to assist with appropriate support and information. The Support Service can also provide resolution options when an investigation is not preferred by the impacted person or cannot proceed. 

We encourage our workforce to report any concerns relating to disrespectful behaviours. We provide centralised and confidential reporting tools and mandatory reporting requirements for line leaders who are informed of serious concerns. We do not tolerate any form of retaliation for raising a concern. We ceased using non-disclosure agreements (NDAs) or imposing confidentiality obligations on complainants in respect of their experiences in settlement agreements relating to sexual harassment in March 2019. We do not enforce any NDAs or confidentiality obligations on complainants of sexual harassment in historical agreements. 

Reports of sexual harassment and racial harassment are investigated by our specialised Response and Investigations team, which is a business unit independent of our operations. This team includes personnel trained in responding with a trauma-informed and person-centred approach. 

Measuring 

Senior leadership and the Risk and Audit Committee of the Board receive reports with de-identified data on the number of complaints, nature of complaints, investigations and other resolution pathways, outcomes and timelines. 

We also remain committed to working with others in the industry and beyond to address sexual harassment risks. BHP is a member of the Minerals Council of Australia’s Safe, Healthy and Respectful Workplaces Committee and the Chamber of Minerals and Energy Western Australia’s Psychosocial Safety Working Group. Both groups aim to build industry capability and capacity through sharing knowledge and developing shared resources. 

Footnotes:

^{1 FY2024 and FY2025 data includes all former OZ Minerals Australian assets and OZ Minerals Brazil assets.   
2 Sexual harassment is, as defined in the Sex Discrimination Act 1984 (Cth), an unwelcome sexual advance, unwelcome request for sexual favours or other unwelcome conduct of a sexual nature, in circumstances where a reasonable person, having regard to all the circumstances, would have anticipated the possibility that the person harassed would be offended, humiliated and/or intimidated. Sexual harassment encompasses a range of conduct, including displaying sexually graphic images, sexually suggestive comments, suggestive or inappropriate looks, gestures or staring, non-consensual touching or acts of a sexual nature and sexual assault. We note the definition of sexual harassment may vary in different jurisdictions. 
3 This figure includes cases opened in FY2025 or earlier and closed in FY2025.}