Page 59 - Annual Report 2020

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Mental health Economic transparency is not our only focus. We also have a strong
We prioritised focus on the mental health of our people in 2015 record of supporting robust reporting on climate change issues.
and are making good progress with the implementation of our We were one of the first companies to report in accordance with
Group-wide Mental Health Framework. the recommendations of the Financial Stability Board’s Task Force Strategic Report
on Climate-related Financial Disclosures in our Annual Report.
In the second half of FY2020, activity focused on support for our
workforce during the COVID-19 pandemic. Our Resilience Program Anti-corruption
was reinforced with a program refresher and, in response to the Our commitment to anti-corruption is embodied in Our Charter
COVID-19 pandemic, we progressed virtual delivery by developing and Our Code. We have a specific anti-corruption procedure that
podcasts and videos to supplement the peer-led program. sets out mandatory requirements to identify and manage the
COVID-19 specific examples were developed for discussion during risk of anti-corruption laws being breached. Our anti-corruption
delivery of the program. We have provided additional support processes require review or approval by our Ethics and Compliance
through employee assistance programs for our workforce and function of activities that potentially involve higher risks of exposure
their families and have increased access to counselling to assist to corruption. We prohibit authorising, offering, giving or promising Governance at BHP
in addressing the impacts of the pandemic. As part of our Risk anything of value directly or indirectly to a government official
Framework, we have set a key risk indicator (KRI) for mental health to influence official action, or to anyone to encourage them to
using annual Engagement and Perception Survey (EPS) outcomes. perform their work disloyally or otherwise improperly. We also
Our annual EPS was not held during FY2020; instead we have been prohibit facilitation payments, which are payments to government
running a weekly COVID-19 wellbeing survey with more than officials for routine government actions. We require our people
55,000 responses being received. We also conduct annual mental to take care that third parties acting on our behalf do not violate
health maturity curve assessments in our operated assets, which anti-corruption laws. A breach of these requirements can result
include pillars such as culture, capacity, prevention and recovery in disciplinary action, including dismissal or termination of
to assess year-on-year progress against those pillars and provide contractual relationships.
focus for future action.
Our Ethics and Compliance function has a mandate to design
and govern BHP’s compliance frameworks for key compliance risks, Remuneration Report
For more information on health visit bhp.com/sustainability. including anti-bribery and corruption. The function is independent
of our assets and regions, and reports to the Chief External Affairs
Officer. The Chief Compliance Officer previously provided a report
1.7.5 Ethics and business conduct twice a year to the RAC on ethics and compliance issues. Since
March 2020, the Chief Compliance Officer reports quarterly to
Our conduct the RAC and meets separately with the Committee Chair.
Every day, BHP works to deliver the resources that are the building The Ethics and Compliance function also participates in all risk
blocks of an ever-changing world. While what we achieve is assessments in respect of operated assets or functions considered
important, so is how we achieve it. to carry material anti-corruption compliance risks. To date,
We know consistent ethical behaviour cultivates a culture of 33 risk assessments have been completed with input from Ethics Directors’ Report
inclusion, care and trust, which ultimately results in improved and Compliance.
performance by BHP. It also strengthens our relationships with Our anti-corruption compliance program is designed to meet
the communities where we work and helps protect the social value the requirements of the US Foreign Corrupt Practices Act, the
we deliver. UK Bribery Act, the Australian Criminal Code and applicable laws
How we work is guided by the core values in Our Charter. of all places where we do business. These laws are consistent
They are: Sustainability, Integrity, Respect, Performance, Simplicity with the standards of the OECD Convention on Combating Bribery
and Accountability. Our Code of Conduct (Our Code) brings our of Foreign Public Officials in International Business Transactions.
core values to life, reminds us why they are important and helps We regularly review our anti-corruption compliance program
us understand what it means to work with those values as our to make any changes required by regulatory developments
guiding principle. and otherwise to reflect best practice aligned with regulatory Financial Statements
Acting in accordance with Our Code is a requirement for BHP requirements. Among other activities in FY2020, we conducted
a review of the design and risk weighting of key anti-corruption
employees. Our Code is accessible to all our people and external
stakeholders at bhp.com. We deliver annual training to help our compliance processes, with a particular focus on third party risk
management and related controls embedded in our contracting
workforce understand Our Code and the standards of behaviour
that are acceptable at BHP. processes. Regular calibration of our compliance processes
enables us to ensure optimal resource allocation to areas
Transparency and accountability presenting the highest corruption risks to our business.
BHP’s existence is premised on trust and public acceptance In addition to anti-corruption training as part of annual training
because our mines and petroleum assets have long lifespans and on Our Code, additional risk-based anti-corruption training was
cannot be moved across jurisdictions in response to a breakdown completed by 3,244 employees and contractors in FY2020,
in trust, changing societal expectations or regulatory requirements. as well as employees of business partners and community partners. Additional information
That is why long-term social value is so important to us. Our tax In recognition of the impacts on our workforce of COVID-19
and royalty payments help governments fund healthcare, disruptions, the end of the time period for relevant employees
education, infrastructure and other essential services. Conversely, to complete the additional risk-based anti-corruption training
any instances of corruption and poor governance of natural was extended from 30 June 2020 to 31 August 2020.
resources can divert funding from provision of those essential
services and diminish the contribution of the resources sector. More information on ethics and business conduct is available
We continue to support and contribute to global transparency at bhp.com/sustainability.
and anti-corruption initiatives, including through our work in
partnership with Transparency International, our representation
on the Board of the Extractive Industries Transparency Initiative,
our financial support for and Steering Committee membership Shareholder information
of the Bribery Prevention Network (in Australia) and through our
funding to support the work of the BHP Foundation, including
its Natural Resources Governance Global Signature Program.

(1) CMDLD is the name given to the lung diseases related to exposure to coal mine dust and includes coal workers’ pneumoconiosis, silicosis, mixed dust pneumoconiosis
and chronic obstructive pulmonary disease.

BHP Annual Report 2020 57