Modern Slavery Statement 2021 - BHP
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Modern Slavery Statement 2021
Organisational Assessing
structure, business Policies and Due diligence and Consultation and effectiveness and
1 Introduction 2 Our approach 3 and supply chain 4 governance 5 risk management 6 collaboration 7 looking forward
Modern Slavery Statement FY2021
BHP Group Limited. ABN 49 004 028 077. In this Statement, the terms ‘BHP’, the ‘Company’,
Registered in Australia. Registered office: the ‘Group’, ‘our business’, ‘organisation’, ‘we’, ‘us’,
‘our’ and ‘ourselves’ refer to BHP Group Limited,
171 Collins Street, Melbourne, Victoria 3000,
BHP Group Plc and, except where the context
Australia. BHP Group Plc. Registration number
otherwise requires, their respective subsidiaries
3196209. Registered in England and Wales.
as defined in note 13 ‘Related undertakings of the
Registered office: Nova South, 160 Victoria Street
Group’ in section 3.2 of our Annual Report 2021.
London SW1E 5LB United Kingdom. Each of BHP
Those terms do not include non-operated assets.
Group Limited and BHP Group Plc is a member
of the BHP Group. BHP is a Dual Listed Company This Statement covers assets (including those
structure comprising BHP Group Limited and BHP under exploration, projects in development or
Group Plc. The two entities continue to exist as execution phases, sites and closed operations)
separate companies but operate as a combined that have been wholly owned by BHP and
group known as BHP. joint venture assets(1) that are operated by BHP
(referred to in this Statement as ‘operated assets’
The headquarters of BHP Group Limited and the
or ‘operations’) during the period from 1 July 2020
global headquarters of the combined Group are
to 30 June 2021. Our functions are also included.
located in Melbourne, Australia. The headquarters
of BHP Group Plc are located in London, United BHP also holds interests in joint venture assets
Kingdom. Both companies have identical that are not operated by BHP (referred to in this
Boards of Directors and are run by a unified Statement as ‘non-operated joint ventures’ or
management team. Throughout this publication, ‘non-operated assets’). Non-operated assets are
the Boards are referred to collectively as the Board. not included in the BHP Group and, as a result,
Shareholders in each company have equivalent statements regarding our operations, assets and
economic and voting rights in the Group as values apply only to our operated assets, unless
a whole. stated otherwise. Data for non-operated assets
is not presented here. However, this Statement
This publication is the Slavery and Human
includes a description of how we approach risks,
Trafficking Statement (UK) and joint modern
including with respect to modern slavery and
slavery statement (Australia) (together, Statement)
human trafficking, in relation to our interests in
for the financial year ended 30 June 2021.
non-operated assets and other investments.
This Statement is made pursuant to the United
Additional information about how we engage
Kingdom’s Modern Slavery Act (2015) and the
with our non-operated asset partners and
Australian Modern Slavery Act (2018) and has
operator companies at non-operated assets
been approved by the Board on 2 September 2021.
is available at bhp.com/sustainability.
The ‘reporting entities’ (as defined in the Australian
Modern Slavery Act) covered by this joint modern
slavery statement (Australia) are listed in the body
of this Statement.
(1) References in this Statement to a ‘joint venture’ are used for convenience to collectively describe assets that are not wholly owned
by BHP. Such references are not intended to characterise the legal relationship between the owners of the asset.
BHP Modern Slavery Statement 2021 02Organisational Assessing
structure, business Policies and Due diligence and Consultation and effectiveness and
1 Introduction 2 Our approach 3 and supply chain 4 governance 5 risk management 6 collaboration 7 looking forward
Introduction
In this Report:
1 Introduction
At BHP, we recognise that risks of modern slavery
UK and Australian Modern Slavery Act Statement 04 exist throughout our value chain and in our
2 Our approach
Our approach 06 operations and understanding and managing
3
Organisational structure, business and supply chain
Our organisational structure and business 07
these risks requires a collaborative approach with
Non-operated assets and social investments 09 suppliers, our workforce and other stakeholders.
Respecting human rights is one of the foundational
Our supply chain 10
4
Policies and governance
Requirements for suppliers and social investment
Access to remedy
11
12
principles for contributing meaningful social value
5 Due diligence and risk management to society and we expect the businesses we work
with to also meet this commitment.
Due diligence and risk management in our business 13
Due diligence and risk management in our supply chain 13
Ethical Supply Chain and Transparency program 14
Effectiveness review 15 BHP adopts the Australian Modern Slavery Act
definition of modern slavery, including the eight
Maritime 15
Training and culture 15
6 Consultation and collaboration
Collaboration 16
types of serious exploitation (which include human
Consultation 16 trafficking), each of which has a clear definition
in international or Australian law.(2)
7 Assessing effectiveness and looking forward
Assessing effectiveness 17
Looking forward 17
EY Independent Auditors letter 18
(2) We consider these definitions suitable to align with the intended interpretation of slavery and human trafficking under the UK Modern Slavery Act 2015.
BHP Modern Slavery Statement 2021 03Organisational Assessing
structure, business Policies and Due diligence and Consultation and effectiveness and
1 Introduction 2 Our approach 3 and supply chain 4 governance 5 risk management 6 collaboration 7 looking forward
UK and Australian Modern Slavery Act Statement
This is our second Statement in response to the Australian Modern Slavery Act and our sixth Statement under the UK Modern Slavery Act. The Statement outlines the governance
processes, activities conducted and progress we have made throughout our financial year to improve our understanding and management of the risks of modern slavery and human
trafficking in our operations and supply chains.
The sections of the Statement that specifically address what we have done to meet the core mandatory criteria required by the Australian Modern Slavery Act (2018) are outlined below.
The table also shows the Statement’s alignment with recommended reporting criteria for UK Modern Slavery Act statements.
BHP response:
UK Modern Slavery Act Australian Modern Slavery Act
recommended reporting criteria mandatory reporting criteria Section Detail
Organisation’s structure, its business Identify each reporting entity covered by the Organisational structure, business – list of the ‘reporting entities’ (as defined
and its supply chains joint statement and supply chain in the Australian Modern Slavery Act)
covered by this joint modern slavery
statement (Australia)
Describe the structure, operations and supply chains of Organisational structure, business – our Operating Model
each reporting entity covered by the joint statement and supply chain – countries in which we operate
– non-operated joint ventures and
social investments
– our supply chain
Parts of the organisation’s business and supply Describe the risks of modern slavery practices in the Organisational structure, business – modern slavery risks
chains where there is a risk of slavery and human operations and supply chains of each reporting entity and supply chain – human rights risks
trafficking taking place, and the steps it has taken covered by the joint statement and any entities that
Due diligence and risk management – human rights impact assessments
to assess and manage that risk each of those reporting entities owns or controls
– non-operated joint ventures and other
investments: locations and governance
and risk management approach
– taxonomies we procure goods
and services from
– Ethical Supply Chain and
Transparency program
BHP Modern Slavery Statement 2021 04Organisational Assessing
structure, business Policies and Due diligence and Consultation and effectiveness and
1 Introduction 2 Our approach 3 and supply chain 4 governance 5 risk management 6 collaboration 7 looking forward
UK and Australian Modern Slavery Act Statement continued
BHP response:
UK Modern Slavery Act Australian Modern Slavery Act
recommended reporting criteria mandatory reporting criteria Section Detail
Organisation’s policies in relation to slavery and Describe the actions taken by each reporting entity Organisational structure, business – Our Code of Conduct and human
human trafficking; its due diligence processes covered by the joint statement and any entities that and supply chain rights training
in relation to slavery and human trafficking in each of those reporting entities owns or controls – non-operated joint ventures and other
Policies and governance
its business and supply chains to assess and address these risks, including due investments: governance and risk
diligence and remediation processes Due diligence and risk management management approach
– Ethical Supply Chain and
Transparency program
– updates to Minimum requirements
for suppliers
– access to remedy, including remediation
and response plan, EthicsPoint and
complaint and grievance mechanisms
Training about slavery and human trafficking
available to the organisation’s staff – engagement activities with suppliers,
customers, investors
Organisation’s effectiveness in ensuring that slavery Describe how each reporting entity covered by the joint Policies and governance – investigation and analysis of complaints
and human trafficking is not taking place in its statement assesses the effectiveness of actions being and grievances
Due diligence and risk management
business or supply chains, measured against such taken to assess and address modern slavery risks – annual human rights reporting to Board’s
performance indicators as it considers appropriate Assessing effectiveness and Sustainability Committee
looking forward – annual supply chain human rights risk review
– internal audit program
– Group Risk reporting process
– results of the Ethical Supply Chain and
Transparency Program
– Ethical Supply Chain and Transparency
effectiveness review
Describe the process of consultation with each reporting Consultation and collaboration – consultation between the reporting
entity covered by the joint statement and with any entities entities, and between reporting entities
that each of those reporting entity owns or controls and the entities they own or control
Any other relevant information Due diligence and risk – Our Code of Conduct and human
management (training and culture rights training
and collaboration) – further engagement and
Assessing effectiveness and collaboration activities
looking forward – plans for FY2022
– engaging and collaborating with
External consultation
stakeholders e.g. membership of the
and collaboration
Global Business Initiative on Human Rights
BHP Modern Slavery Statement 2021 05Organisational Assessing
structure, business Policies and Due diligence and Consultation and effectiveness and
1 Introduction 2 Our approach 3 and supply chain 4 governance 5 risk management 6 collaboration 7 looking forward
Our approach
We are successful when BHP recognises it is important for us to seek to
understand and to manage the risks of modern
we uphold the values set slavery and human trafficking in our value chain
out in Our Charter, when and our operations. Our approach to managing
these risks is embedded in our Human Rights
our customers, suppliers Policy Statement and the Our Requirements
and the communities standards,(3) and implemented through our
where we operate value management and due diligence systems
across our operated assets.
their relationships with us We take a collaborative approach to considering
and when we truly live our sustainability in our value chain, recognising we
purpose – to bring people must engage with suppliers and other value chain
participants to promote sustainable practices
and resources together to across the full life cycle of our products.
build a better world. Our There are inherent risks of modern slavery
approach to modern slavery and human trafficking in the resources sector.
and human trafficking risks is Responsible sourcing for BHP requires us
to integrate sustainability and human rights
underpinned by these values. considerations into procurement and logistics in
our supply chains (including shipping). Some of
the world’s most vulnerable people work deep
within supply chains and we continue to evolve
and refine our approach to better address the risks.
(3) These describe our mandatory minimum performance
requirements and provide the foundation to develop and
implement management systems at our operated assets.
BHP Modern Slavery Statement 2021 06Organisational Assessing
structure, business Policies and Due diligence and Consultation and effectiveness and
1 Introduction 2 Our approach 3 and supply chain 4 governance 5 risk management 6 collaboration 7 looking forward
Organisational structure, business and supply chain
BHP is a global natural Structure Reporting entities BHP Iron Ore (Jimblebar) Pty Ltd
BHP consists of BHP Group Limited and BHP (Australian Modern Slavery Act)
resources company, Group Plc, operating as a single unified economic The following are the reporting entities covered
BHP Petroleum (North West Shelf) Pty Ltd (formerly
BHP Billiton Petroleum (North West Shelf) Pty Ltd)
operating in global markets. entity, following the completion of the Dual Listed by this joint modern slavery statement (Australia):
BHP Petroleum International Pty Ltd (formerly
We extract, process and Company merger in June 2001. The two entities
continue to exist as separate companies but
BHP Group Limited
BHP Billiton Petroleum International Pty Ltd)
explore for minerals, oil operate as a combined group known as BHP. The Broken Hill Proprietary Company Pty Ltd
BHP Petroleum (Bass Strait) Pty Ltd (formerly
and natural gas with around The headquarters of BHP Group Limited and the
global headquarters of the combined Group are
BHP Lonsdale Investments Pty Ltd BHP Billiton Petroleum (Bass Strait) Pty Ltd)
80,000 employees and located in Melbourne, Australia. The headquarters Dampier Coal (Queensland) Proprietary Limited BHP Petroleum (International Exploration) Pty Ltd
contractors (our workforce), of BHP Group Plc are located in London, United BHP Mitsui Coal Pty Ltd
(formerly BHP Billiton Petroleum (International
Exploration) Pty Ltd)
Kingdom. Both companies have identical Boards
primarily in Australia and of Directors and are run by a unified management
(formerly BHP Billiton Mitsui Coal Pty Ltd)
BHP Nickel West Pty Ltd (formerly BHP Billiton
the Americas. team. Shareholders in each company have BHP Minerals Pty Ltd
Nickel West Pty Ltd)
equivalent economic and voting rights in the (formerly BHP Billiton Minerals Pty Ltd)
Our principal operations and locations are Group as a whole. BHP Olympic Dam Corporation Pty Ltd (formerly
BHP (Towage Services) Pty Ltd
described below. Our products are sold worldwide. BHP Billiton Olympic Dam Corporation Pty Ltd)
In FY2021, BHP organised its business into
The BHP Annual Report 2021, available at bhp.com, three main divisions: Minerals Australia, Minerals BHP Petroleum (Australia) Pty Ltd
provides more information on the structure of Americas and Petroleum, supported by regional or
our workforce. centralised activities, including sales and marketing
led through Singapore and Houston, United States.
Operations and locations Our business model and
BHP’s principal operations comprise: strategy and a description
of BHP’s assets and principal
office locations (including
BHP’s interests in mining
non-operated joint ventures
and petroleum non-operated
assets, which are expressly
addressed in the Non-
Exploration Development Process Sales and Closure and operated assets and other
and acquisition and mining and logistics marketing rehabilitation investments section below,
but not otherwise referenced
With copper and nickel Our aim is to be the industry’s We process and refine ore, strive We seek to maximise value Are considered throughout the
throughout this Statement)
our primary targets. best operator through a to safely manage waste, and through our commercial asset lifecycle, to help minimise
are set out in sections 1.4, 1.6.1,
focus on safety, operational aim to efficiently and sustainably expertise, customer insights our impact and optimise
1.6.2, 1.10 and 1.11 of our Annual
excellence and social value. transport our products to and proactive risk management. post-closure value for all.
Report 2021; BHP locations and
customer markets.
the locations of non-operated
assets are represented on the
map on page 8.
BHP Modern Slavery Statement 2021 07Organisational Assessing
structure, business Policies and Due diligence and Consultation and effectiveness and
1 Introduction 2 Our approach 3 and supply chain 4 governance 5 risk management 6 collaboration 7 looking forward
Organisational structure, business and supply chain continued
BHP locations (includes non-operated operations)
BHP principal office locations
19 Minerals 29 Global Business
Australia office Services
Adelaide, Australia Kuala Lumpur,
Malaysia
Minerals Australia Minerals Americas Petroleum 20 Minerals
Australia office 30 Metals
1 Olympic Dam 4 BHP Mitsubishi 7 Escondida 10 Samarco(1) 14 Australia 16 Trinidad Brisbane, Australia exploration
Australia Alliance Chile Brazil Production Unit and Tobago office
21 Global
Australia Australia Production Unit Lima, Peru
2 Western Australia 8 Pampa Norte 11 Cerrejón headquarters
Trinidad Melbourne, 31 Global Business
Iron Ore 5 BHP Mitsui Coal Chile Columbia 15 Gulf of Mexico
and Tobago Australia Services
Australia Australia Production Unit
9 Antamina (1)
12 Jansen
Gulf of Mexico 17 Algeria Joint Manila, Philippines
3 New South Wales 6 Nickel West Peru Canada 22 Minerals
Joint Interest Interest Unit(1) Australia office 32 Marketing and
Energy Coal Australia
13 Resolution Unit(1) Algeria
Australia Perth, Australia corporate office
Copper US
18 Australia Joint Singapore,
US 23 Minerals
Interest Unit(1) Singapore
Americas office
Australia Saskatoon, Canada 33 Corporate office
London, UK
24 Minerals
23 12
33 Americas office 34 Petroleum office
Santiago, Chile Houston, US
37
36
25 Corporate office 35 Metals
13 28 Shanghai, China exploration office
35
34 17 Tucson, US
25 26 Metals
27
15 exploration office 36 Corporate office
Quito, Ecuador Washington DC,
31 US
16 27 Corporate office
11 29 New Delhi, India 37 Corporate office
32 Toronto, Canada
26 28 Corporate office
Tokyo, Japan
30
9
10
8 14 5
7 2 4
20
24 22 6 1
3
19
21
18
(1) Non-operated joint venture.
BHP Modern Slavery Statement 2021 08Organisational Assessing
structure, business Policies and Due diligence and Consultation and effectiveness and
1 Introduction 2 Our approach 3 and supply chain 4 governance 5 risk management 6 collaboration 7 looking forward
Organisational structure, business and supply chain continued
Risks of modern slavery practices In the oil and gas sector, modern slavery risks Non-operated assets Non-operated petroleum assets
within our operations primarily relate to the conditions on board offshore and social investments In FY2021, our Petroleum non-operated assets
Our operated assets and office locations span supply vessels.(8) In FY2021, our operated assets BHP also holds interests in companies and included Atlantis and Mad Dog (offshore
19 countries and nine of these have either high in this sector were located across seven countries, joint ventures that we do not operate. These are deepwater, Gulf of Mexico), Bass Strait (offshore
or extreme potential for modern slavery risks, two of which have a high risk of modern slavery described in more detail in our Annual Report 2021. and onshore, Victoria, Australia), North West Shelf
according to the Verisk Maplecroft Modern at an industry level.(9) Information about how we engage with our non- (offshore and onshore, Western Australia) and
Slavery Index 2021.(4) operated asset partners and operator companies ROD Integrated Development (onshore, Algeria).
In addition to operated assets, BHP maintains
at non-operated assets is available at bhp.com/ BHP’s percentage interests with respect to
The risks for modern slavery in the mining and corporate offices that are managed by our
sustainability. these investments are described in our Annual
metals sector primarily relate to the labour Property and Workplace function in 16 countries,
Report 2021.
conditions related to artisanal mining, particularly seven of which are located in countries with a Non-operated minerals joint ventures
in areas of conflict.(5) Of the six countries in which high or extreme risk of modern slavery rating.(10) In FY2021, our Minerals non-operated joint The ROD Integrated Development is located in
we operate mining activities, two have a high risk In managing these offices, we recognise the ventures (NOJVs) included Antamina (33.75 per Algeria, a country with a medium risk of modern
of modern slavery at an industry level, none is heightened industry-level risks of modern slavery cent ownership) in Peru, Resolution Copper (45 slavery, according to the Verisk Maplecroft
classified as an area of conflict(6) and we had no within the facilities management sector, in per cent ownership) in the United States, Cerrejón Modern Slavery Index 2021.
reported artisanal or small-scale mining(7) on or particular relating to the lower-skilled sectors within (33.33 per cent ownership) in Colombia(11) and We have processes in place at our Petroleum non-
adjacent to any of our operated assets. While the the industry, for example cleaning services, due Samarco (50 per cent ownership) in Brazil. operated assets within the rights afforded by the
risks of modern slavery in artisanal mining are to the high levels of migrant labour engaged.
We recognise three of the four countries have respective joint operating agreements to engage
not directly relevant for BHP’s own operations The broader human rights that may be impacted in relation to risk identification and management.
a high level of risk of modern slavery within the
or our supply chain, we seek to understand and by BHP’s own operations include rights related to This includes (as permitted by the relevant
mining and metals sectors according to the
monitor the broader human rights risks related workplace health and safety, labour, Indigenous operator and/or joint operating arrangements)
Verisk Maplecroft Modern Slavery Index 2021.
to the resources sector, including the safety and peoples, water and sanitation and those of the review of risk control strategies through field visits,
security risks with respect to artisanal mining. communities that live near our assets as detailed We engage with our NOJV partners and review and analysis of the operator’s performance
in our Human Rights Policy Statement. operator companies through our NOJV team. data, participation in operator audits and sharing
While NOJVs have their own operating and BHP risk management strategies and processes
management standards, we seek within the where appropriate.
limits of the relevant joint venture agreements
to enhance governance processes and influence
operator companies to adopt international
standards, including in respect of human
rights. Subject matter experts from BHP also
provided input and support to relevant NOJV
operators in relation to risk management,
(4) The Verisk Maplecroft Modern Slavery Index assesses the risk to business of exposure to practices of slavery, servitude, trafficking in social and environmental impacts and
persons and forced labour. Verisk Maplecroft Index scores are presented on a scale of 0–10, where 0 represents highest risk and 10 community engagement.
represents lowest risk.
(5) According to Verisk Maplecroft Modern Slavery Index 2021.
(6) As defined by Uppsala Conflict Data Program’s definition of being in active conflict.
(7) BHP uses the International Council for Mining and Metals (ICMM) definition of artisanal and small-scale mining: as a subsistence miner who
is not officially employed by a mining company, but works independently, mining minerals using their own resources. More information can
be found on the ICMM website.
(8) According to Verisk Maplecroft Modern Slavery Index 2021.
(9) According to Verisk Maplecroft Modern Slavery Index 2021.
(10) According to Verisk Maplecroft Modern Slavery Index 2021.
(11) In June 2021, we announced our intended divestment of our interest in Cerrejón to Glencore. Subject to the satisfaction of customary
competition and regulatory requirements, we expect completion to occur in the first half of the 2022 calendar year.
BHP Modern Slavery Statement 2021 09Organisational Assessing
structure, business Policies and Due diligence and Consultation and effectiveness and
1 Introduction 2 Our approach 3 and supply chain 4 governance 5 risk management 6 collaboration 7 looking forward
Organisational structure, business and supply chain continued
Social investments Risks of modern slavery practices Taxonomy risks
We make social investments as voluntary Approximately 95 per cent of our direct suppliers Taxonomy link to BHP
contributions in environmental and community are concentrated in 10 countries(13) (based on Minimum requirements
initiatives in partnership with local communities Taxonomy Example modern slavery risks(16) for suppliers
country of incorporation(14)). Eighty-five per cent of
and in pursuit of our sustainability public targets our direct suppliers are located in three countries:
Bulk materials Migrant worker risks, including bonded labour, – Labour rights
Example: Fuels including biofuel, tyres, retention of passports, and poor working conditions – Conflict minerals
and objectives, including with respect to climate Australia, Chile and the United States. Of our top explosives, emulsion, bulk chemicals and pay, maritime seafarers’ welfare. – Community
change, water stewardship and biodiversity. 10 supplier countries, three are countries that are including sulphurs, acids and reagents. – Environment and health
– Compliance
Our voluntary social investment includes funding rated as high or extreme risk(15) according to the – Remedies
the BHP Foundation, a charitable organisation that Verisk Maplecroft Modern Slavery Index 2021. Non-production consumables Risks to women, children and migrant workers, – Labour rights
works with more than 40 partner organisations Example: Apparel, hardware, including trafficking and forced labour, retention of – Community
We recognise understanding the risk factors of cleaning agents and food stuffs. passports, long work hours below minimum wage, – Environment and health
across 46 countries to address some of the world’s modern slavery and human trafficking within our Biofuels (including palm oil) in lack of freedom of association. – Compliance
most critical sustainable development challenges. supply chain requires assessing the countries and
food/soaps. – Remedies
Manufacturing/processing,
The BHP Foundation’s risk management processes the sectors (taxonomy) from which we procure waste management services.
include human rights as one of the material risk goods and services. In our Ethical Supply Chain Travel and accommodation Risks to women, children and migrant workers, – Labour rights
areas, and was reviewed in FY2021 in consideration and Transparency program, when assessing the Example: Hotel personnel, biofuels including bonded labour, retention of passports, – Environment and health
of the United Nations Guiding Principles on in aviation gasoline. and poor working conditions and pay. – Remedies
taxonomy risk of a supplier we include the country
Business and Human Rights (UNGPs). Conveyor belting and parts Child labour, migrant worker risks, including bonded – Labour rights
of incorporation, and where different, the country Example: Conveyor parts, rollers and labour (especially at source material rubber), – Community
Our supply chain of primary manufacturing facilities. We prioritise belts including source material (rubber) retention of passports, poor working conditions and – Environment and health
and manufacturing. pay, violations of freedom of association, maritime – Compliance
BHP’s global supply network encompasses direct our due diligence on suppliers who are assessed to seafarers’ welfare. – Remedies
suppliers in more than 61 countries. Our operations be high or very high risk based on their combined Tyres, wheels and rims Child labour, migrant worker risks, including bonded – Labour rights
are supported by raw materials, direct materials country and taxonomy risk. The table outlines Example: Tyres including source labour (especially at source material rubber), retention – Community
BHP’s high-risk taxonomies and examples of material (rubber) and manufacturing. of passports, poor working conditions and pay, – Environment and health
(those used in our production cycles, such as violations of freedom of association, maritime – Compliance
trucks and explosives) and indirect materials the modern slavery risks within each. Refer to the seafarers’ welfare. – Remedies
(which are all other materials incidental to our Due diligence and risk management in our supply Technology Migrant worker risks, including bonded labour, – Labour rights
business, including technology hardware and chain section for information on the FY2021 results Example: Computing devices source retention of passports, occupational health and – Conflict minerals
of our supplier assessment program. material (3TGs/conflict minerals) safety, and poor working conditions and pay, source – Remedies
consumables, such as tools, personal protective and manufacturing. materials (3TGs and conflict minerals).
equipment, office supplies and skilled labour and Wear consumables Migrant worker risks, including bonded labour, – Labour rights
services). We made payments to more than 9,000 Example: Mill liners, grinding media retention of passports, occupational health and – Conflict minerals
suppliers in FY2021, with 77 per cent of our spend including source materials (rubber, safety, poor working conditions and pay, maritime – Environment and health
metals) and manufacturing. seafarers’ welfare. – Community
going towards payment for services. The largest – Remedies
spend categories were engineering and
construction, maintenance services, and goods
for maintenance, repair and operations.(12)
Across our supply chain, our key human
rights related risks are in the materials (goods)
supply chain and the maritime transport of our
commodities, with additional high-potential
exposure in our indirect supply chain. We use
a combination of geographic and taxonomy (12) These are broad taxonomies that include suppliers that provide construction, labour, design and manufacturing/fabrication services to BHP.
risk identifiers to assess supplier risk. (13) Australia, Brazil, Canada, Chile, China, Ecuador, Trinidad and Tobago, Singapore, United Kingdom and United States.
(14) We recognise a supplier’s country of incorporation may be different from the country of origin of its goods or services.
(15) Brazil, China and Ecuador.
(16) According to Verisk Maplecroft Modern Slavery Index 2021 and BHP subject matter expertise.
BHP Modern Slavery Statement 2021 10Organisational Assessing
structure, business Policies and Due diligence and Consultation and effectiveness and
1 Introduction 2 Our approach 3 and supply chain 4 governance 5 risk management 6 collaboration 7 looking forward
Policies and governance
Every member of our We continued to conduct activities in FY2021 Requirements for suppliers To support our continuous improvement and
to maintain and increase awareness about and social investment collaboration with suppliers, our Ethical Supply
workforce who works at or Our Code that included: Chain and Transparency Guide is available to
Suppliers
supports our operations is – ongoing strong focus on awareness of Our Code The Our Requirements for Supply standard sets
all direct and indirect suppliers at bhp.com.
The Guide complements the direct engagement
guided by Our Charter, Our requirements from the CEO, Asset Presidents mandatory minimum requirements for suppliers and relationships we have with our suppliers
and General Managers of our operated assets,
Code of Conduct (Our Code) who continued to raise the importance of
of non-traded goods and services, including: through our Procurement teams with the intent
and the Our Requirements culture within BHP in their Group-wide and – registration prior to being set up as a
new supplier
to collaborate with and enhance the capability
of our suppliers in meeting their requirements
standards. asset-level communications
– application of the Minimum requirements under our Minimum requirements for suppliers.
– further improvements in reporting of data
insights from EthicsPoint (our speak-up service, for suppliers Social investment
Contractors working at our operated assets
described below) and sharing lessons from Compliance with the Minimum requirements for BHP aims to use its standard contract templates
are required to comply with our health, safety,
significant investigations with our senior leaders, suppliers is necessary for doing business with for social investment(19), wherever possible,
environmental and community (HSEC) standards.
site management and Integrity Working Group BHP and they are included in our procurement which include:
We are focused on how we can engage with
and encourage our suppliers, agents and service (described in the Access to remedy section standard contract suite, BHP standard voyage – a requirement for the partner organisation/
providers to maintain business practices and on page 12). contract terms(18) and purchase order terms and donation recipient to comply with a tailored
workplace standards that are comparable to Freedom of Association and collective conditions. Previous Statements have provided version of our Minimum requirements for
our own. bargaining at BHP more detail on our standard contracts. Of the suppliers in its activities funded by BHP and
Our Human Rights Policy Statement (HRPS) sets suppliers that are registered in our Global Contract to ensure any subcontractors also do so
The Board reviews and monitors the effectiveness Management System (GCMS), as at 30 June 2021,
of the Group’s systems of financial and non- out our expectations of our people and all third – express acknowledgement of our expectation
parties we work with to respect human rights. over 99 per cent have confirmed they comply with the partner organisation will read, understand
financial risk management and internal controls. the Minimum requirements for suppliers or have
The broad range of skills, experience and In FY2021, we updated the HRPS to provide and adhere to Our Code
a more explicit commitment to labour rights, confirmed they commit to an equivalent or higher
knowledge of the Board assists in providing a standard. We conduct additional due diligence on
diverse view on risk management. The Board’s specifically to operate consistently with the
terms of the International Labour Organization’s those of our suppliers initially screened as high and
Risk and Audit Committee and Sustainability very high risk to test these responses (refer to the
Committee assist the Board by reviewing and (ILO) Declaration on Fundamental Principles and
Rights at Work, including to the four Core Labour Due diligence and risk management in our supply
considering BHP’s risk profile (covering operational, chain section). A very small number of suppliers
strategic and emerging risks) on a biannual basis. Standards;(17) the subject of the ILO Conventions
that have not committed to complying with the
on which the ILO Declaration is based.
Our Code establishes the standard for our Minimum requirements for suppliers (and do not
Our updated HRPS is available at bhp.com.
commitment to working with integrity and have standards that are equivalent to or higher
respect. Our Code sets out standards of behaviour BHP is a party to a number of collective than BHP’s) are proactively followed up. In cases
for our people and outlines the human rights agreements that underpin minimum terms and where suppliers are not able to satisfactorily rectify
commitments applicable to our people, as well conditions of employment for our employees. their non-compliance, they will be ineligible to
as our contractors and suppliers (where under BHP respects the right to freedom of association continue to conduct business with BHP. (17) Freedom of association and the effective recognition of the right
to collective bargaining; the elimination of all forms of forced
relevant contractual obligation). and does not discriminate in the collective We continued our work with suppliers during or compulsory labour; the effective abolition of child labour;
and the elimination of discrimination in respect of employment
bargaining process where employees elect contract negotiations in FY2021, to support an and occupation.
to be represented. understanding of the Minimum requirements (18) The contract terms most commonly used by BHP for
for suppliers and our Ethical Supply Chain and chartering vessels.
(19) Standard contracts are encouraged for all social investment over
Transparency program. We focused on high-risk US$20,000. Due to regulatory requirements, for social investment
suppliers, including those in the bulk materials in Chile, standard contracts are not used; however, all contracts
and tyres, wheels and rims industries. are required to be developed in compliance with the Our
Requirements standards.
BHP Modern Slavery Statement 2021 11Organisational Assessing
structure, business Policies and Due diligence and Consultation and effectiveness and
1 Introduction 2 Our approach 3 and supply chain 4 governance 5 risk management 6 collaboration 7 looking forward
Policies and governance continued
Access to remedy At an informal level, BHP promotes a ‘safe to speak All reports received in EthicsPoint are reviewed and We recognise human rights risks are present in
There are a number of mechanisms available to up’ culture in its workplace encouraging resolution categorised by the Ethics team. Once categorised, organisations of all sizes. We also acknowledge
employees of BHP and our suppliers, as well as through productive working relationships. reports are assigned in accordance with some organisations, including smaller enterprises,
third parties to raise grievances on any topic of internal policy and processes to an investigator, may face challenges with the implementation
At a more formal level, there are documented
importance to them, which may include modern line leader or appropriate team for resolution. of management processes and procedures that
processes in policies, contractual frameworks and
slavery and/or human rights issues. The processes for reporting and investigation are provide adequate access to remedy for workers
industrial instruments for raising and managing
transparent and BHP employees and contractors and other stakeholders. We are committed to
Aligned with the UNGPs, the Our Requirements for grievances and for their escalation.
can access this information via BHP’s intranet. working collaboratively with these suppliers to
Community standard requires that each operated BHP’s ‘Speaking up with confidence’ guidance External stakeholders can access this via the understand their constraints and seek to find
asset has a local complaint and grievance note, embedded in Our Code explains how BHP website. ways to support the provision of complaint and
mechanism. More information on complaint and reporters of Our Code concerns are protected grievance mechanisms. Information on accessing
grievance mechanisms can be found at bhp.com. Reports raised via EthicsPoint provide valuable
under BHP policies. We encourage our employees, EthicsPoint is available for suppliers in the Ethical
insight into culture and organisational learning.
To ensure these mechanisms are culturally everyone who works with us and all those affected Supply Chain and Transparency Guide.
All significant Our Code matters and key trends
appropriate and accessible to all stakeholders, by our business globally to promptly raise a
from investigations are reported to the Board’s Risk Our Human Rights Breach Remediation and
including Indigenous peoples, we established concern about anything they reasonably believe
and Audit Committee. These are then considered Response Plan was not required to be activated
globally consistent principles in FY2021. may be illegal, improper or involve misconduct.
as part of its report-out to the Board as set out in in FY2021. The plan details the coordination of
These principles align with the UNGPs and apply This includes concerns about potential human
the Annual Report 2021 (sections 2.1.10 and 2.1.15). our proposed response and the remediation
to how we develop the complaint and grievance rights violations.
The most serious breaches of Our Code are also steps we take in response to an alleged breach
mechanisms to ensure any relevant social We have mechanisms in place for anyone to raise reported to the Integrity Working Group, which of human rights within our supply chain.
contexts are considered. a query about Our Code, or make a report if they is accountable for oversight of the operational
Our FY2020 Modern Slavery Statement outlined
We also worked to improve the quality of feel Our Code has been breached. effectiveness of the Investigations Framework,
BHP’s approach to the provision of remedy
reporting of community concerns, complaints including oversight of investigations completed
EthicsPoint is our system for reporting misconduct options for seafarers who are on-board vessels
and grievances via the BHP Event Management by the Central Investigations team. The Integrity
and can be used by employees, contractors and undertaking BHP voyages.
System. Complaints, grievances and reports of Working Group is chaired by the Chief Compliance
external stakeholders, including members of
community or human rights issues received by our Officer and comprises of a number of senior
the public, to raise concerns about misconduct
operated assets are required to be logged in our leaders across BHP.
that has either happened to them or they have
Event Management System, which was launched witnessed. Reports can be raised in EthicsPoint There were no incidents of modern slavery
in FY2020. The system includes categories for directly, via an employee or contractor’s line or human trafficking in breach of our policies
community complaints and grievances relating to leader or via the 24-hour, multilingual call service. reported to EthicsPoint during FY2021.
amenity, behaviour, human rights and Indigenous Reporters of misconduct can choose to raise
rights. This allows us to improve our investigation, In FY2021, all suppliers assessed as high or very
their concern anonymously.
management and analysis of issues and impacts high risk and with more than 100 employees
on communities. There were no complaints were asked to provide evidence of a grievance
relating to modern slavery or human trafficking mechanism through the Request for Information
received through these mechanisms in FY2021. (RFI) process under the Ethical Supply Chain and
Transparency (ESCT) due diligence program.
As due diligence is progressively completed,
suppliers that do not have a mechanism in place
are placed on a supplier development plan in
order to rectify.(20)
(20) For more information on supplier due diligence and supplier
development plans, refer to the Ethical Supply Chain and
Transparency program section.
BHP Modern Slavery Statement 2021 12Organisational Assessing
structure, business Policies and Due diligence and Consultation and effectiveness and
1 Introduction 2 Our approach 3 and supply chain 4 governance 5 risk management 6 collaboration 7 looking forward
Due diligence and risk management
We identify, assess and Human rights related risks to communities,
including those related to the environment,
More information on the HRIA methodology
is available at bhp.com/sustainability.
of BHP, and to senior operational leaders, with
summary reports provided to the Sustainability
manage risks that BHP is Indigenous peoples and access to remedy
We undertake regular engagement with
Committee and the Risk and Audit Committee.
exposed to, including human were also reported.
stakeholders to learn about, understand, prevent
In FY2021, IAA conducted a review of Global
Category Management in our Commercial team
rights risks, by applying our In Chile, the most salient human rights related and seek to mitigate the adverse human rights
covering the vendor due diligence process.
risks reported were access to remedy for impacts of our activities, from new country
overarching Risk Framework. employees and contractors, access to remedy for entry to closure. Through the HRIAs, community
Management declared some weaknesses in
this process with a backlog in the review of active
communities where we operate, fair and equitable perception surveys and engagement with
Due diligence and risk management high-risk vendors. Actions to address these gaps
treatment, occupational health and safety, water suppliers, customers and other stakeholders,
in our business have been established.
and the impacts of COVID-19. Additional human including civil society and investors (refer to
The Board’s Risk and Audit Committee monitors rights risks relating to security, cumulative the Due diligence and risk management in our Due diligence and risk management
and, at least annually, will review the effectiveness impacts on communities and working conditions supply chain section), we continue to develop our in our supply chain
of the Group’s systems of risk management and were identified across operated assets in Chile. understanding of the threats to and opportunities
We take a collaborative approach to managing
internal control. The HRIAs also reported the risk of violation of for respecting human rights across the Group.
the risks of modern slavery and human trafficking
labour rights throughout our local and global
More information on BHP’s Risk Framework is provided The Our Requirements standards require we take in the value chain. Our Ethical Supply Chain
supply chain, associated with our variable degree
in our Annual Report 2021, available at bhp.com. a risk-based approach that includes consideration and Transparency team within the Commercial
of visibility across our full local and global supply
of potential human rights, environmental and function works closely with the Sustainability and
We finalised our Human Rights Impact Assessment chains to determine whether suppliers, supplier
community impacts for decisions around major Public Policy team (in External Affairs), Legal and
(HRIA) pilot project in FY2021, which resulted in contractors and the other actors in these local and
transactions, including all major divestments and, Risk, as well as the Ethics and Compliance team,
a globally consistent methodology for HRIAs to global supply chains are adhering to international
where appropriate and are able to be undertaken, to ensure the approach is integrated with BHP’s
be applied across each of our operated assets. human rights and labour standards. The risk of
major acquisitions. These standards also apply broader approach to respecting human rights.
HRIAs were conducted by an external consultant supply chain human rights breach is managed
to new activities in high-risk countries and major In FY2021, we continued our risk-based approach
across Minerals Australia and Minerals Americas, through an existing suite of critical controls, with a
projects. In FY2021, the Our Requirements to assessing our direct suppliers and improving
with self-assessments conducted at each of these plan in place to enhance our supplier due diligence
standard governing the commencement of our understanding of risks within our broader
operated assets. A HRIA was also conducted (refer to the Due diligence and risk management
activities in high-risk countries was updated to value chain.
across the Jansen Potash Project in Canada. in our supply chain section).
improve identification of high-risk countries and
A review of findings and recommendations was Our risk of an actual or perceived failure to prevent
The outcomes of the HRIA pilot are expected strengthen processes for entry and the ongoing
conducted by functional subject matter experts, or mitigate an adverse human rights impact
to strengthen our approach to managing and management of human rights related risks in
including for ethics and compliance, inclusion and linked to BHP’s supply chain (directly or indirectly),
monitoring human rights related risks. In FY2022, these countries. The revised Our Requirements
diversity, tailings, security, procurement, cultural including maritime activities, was reviewed
our operated assets and functions intend to use standard requires the application of appropriate
heritage, Indigenous employment, environment, in FY2021 and remains a material risk to BHP.
a risk-based approach to determine when a HRIA internal and external expertise and endorsement
health, safety and employee relations. The controls to manage this risk are tested annually
needs to be reviewed or conducted. Results of the from the Group Sustainability and Public Policy
for effectiveness and reviewed based on our
In Australia, the most salient human rights related HRIAs are also expected to be better integrated Officer and Chief Compliance Officer prior to
evolving understanding of the risk. These controls,
risks reported in the HRIA include sexual assault and into our existing risk assessment processes to any activities commencing.
which are summarised below, remain unchanged
harassment, mental health and fair and equitable enhance our understanding of the full spectrum
Our Internal Audit and Advisory (IAA) team from FY2020:
treatment (for example, discrimination, inclusion and of identified risks, and where required, develop
evaluates the design and effectiveness of
diversity and equal pay for equal work). These findings additional controls. Social value assessments are – Ethical Supply Chain and Transparency program
our sustainability processes through annual
align with existing risks currently managed across intended to include HRIA results to ensure our (refer to page 14)
internal audit plans. Results are considered in
BHP, through measures including the introduction operated assets have a deep understanding of – Ethical Supply Chain and Transparency Guide
the development of action plans to address
of the sexual assault and harassment support their operating context and external environment (refer to the Requirements for suppliers and
improvements where required. Results are
line and ongoing focus on mental health and as inputs into their business planning. social investment on page 11)
reported to the Executive Leadership Team, which
our commitment to inclusion and diversity. is responsible for the day-to-day management
BHP Modern Slavery Statement 2021 13Organisational Assessing
structure, business Policies and Due diligence and Consultation and effectiveness and
1 Introduction 2 Our approach 3 and supply chain 4 governance 5 risk management 6 collaboration 7 looking forward
Due diligence and risk management continued
– Minimum requirements for suppliers (refer with extended due diligence against our Minimum were rated as having very high or high human gaps include a lack of policy or clear processes
to the Requirements for suppliers and social requirements for suppliers conducted on suppliers rights risk potential after the initial screening, with related to forced, compulsory and migrant labour,
investment on page 11) that initially register as high or very high risk in the the remaining 91 per cent rated as medium or low freedom of association, accommodation facilities,
– Training and culture building (refer to the GCMS. To assess supplier risk, we conduct tailored risk. We are targeting progressive completion of and wages and working conditions. In FY2021,
Training and culture section on page 15) assessments of supplier taxonomy risk in the extended due diligence on all suppliers that initially 13 suppliers completed the remedies required
initial screening, using existing taxonomy metrics registered as very high or high risk across the next under their development plans. Progress through
– Human Rights Breach Remediation and
(including Verisk Maplecroft indices), third-party two years. In FY2021, all such suppliers registered the ESCT program is managed through a newly
Response Plan and complaint and grievance
data analysis and industry expertise for sector- in the GCMS were sent the RFI questionnaire to created dashboard in FY2021.
mechanisms (refer to the Access to remedy
specific risk profiles. commence the extended due diligence process.
section on page 12) Suppliers may be selected to participate in an
Our Statements for previous years provided detail If suppliers have not responded to the RFI request independent third-party audit of their operational
Ethical Supply Chain and
on the GCMS registration component of our due after three attempts, we trigger escalation facilities relevant to BHP. This selection process
Transparency program
diligence process. The FY2020 Statement outlined protocols that can ultimately result in the supplier includes an assessment of the supplier’s
Throughout FY2021, the Ethical Supply Chain
the ESCT process after registration in the GCMS. being blocked until they respond and complete taxonomy risk and due diligence results, as
and Transparency (ESCT) team focused on
In FY2021, we updated our approach to assessing the due diligence. No suppliers had been blocked well as the criticality of a supplier to business
embedding and building the maturity of our
supplier risk to enhance the accuracy of our due to non-responses as at 30 June 2021. continuity where appropriate. Where requested,
ESCT due diligence program.
initial screening. we require a Sedex Members Ethical Trade
Detailed due diligence has been completed on
The program is the primary preventative control Audit (SMETA) to be conducted. After pausing
ESCT program FY2021 results 41 per cent of these suppliers. While no significant
to manage the risk of a human rights breach our audit program in FY2020 due to COVID-19,
There were approximately 7,000 active suppliers human rights breaches have been identified,
within BHP’s supply chain. The program takes we recommenced the program in FY2021.
registered in the GCMS as at 30 June 2021. 85 suppliers require a development plan to
a risk-based approach to assessing suppliers, In FY2021, 15 suppliers with a total of 35 sites (e.g.
Of these suppliers, approximately nine per cent close identified gaps. Key themes of supplier
manufacturing facilities) across 12 countries were
selected for SMETA. The suppliers selected were
Due diligence and third party audit priorities from the following high-risk taxonomies: wear
Taxonomy FY2021 progress consumables and conveyor belting and parts
Bulk materials Detailed due diligence commenced on largest/critical direct suppliers. (e.g. industrial machinery), bulk materials (e.g.
SMETAs – commenced. explosives) and tyres, wheels and rims. Due to
This is a broad, specialised manufacturing taxonomy and we take a risk-based approach, prioritising those commodities with a higher
country of origin risk and excluding maritime freight for which sustainability screening is managed by BHP. COVID-19 restrictions, only eight of the audits were
able to be completed; the remainder have been
Non production consumables Due diligence commenced on largest/critical direct suppliers.
Additional taxonomy review to be conducted to prioritise direct and indirect supplier risks prior to targeted SMETA, in collaboration
postponed and will be scheduled for FY2022.
with direct suppliers in FY2022. From the completed audits, the primary findings
related to safety, hygiene conditions and working
Travel and accommodation Due diligence commenced, however, de-prioritised in FY2021 due to COVID-19 travel restrictions. Will be re-prioritised when travel
recommences with the easing of COVID-19 restrictions. hours. The suppliers with findings have been
Additional taxonomy review to be conducted to prioritise direct and indirect supplier risks prior to targeted SMETA in collaboration placed on supplier development plans and will
with direct suppliers in FY2022. have a follow-up audit scheduled in FY2022 to
Conveyor belting and parts Detailed due diligence commenced on largest/critical direct suppliers. assess remediation of the findings.
SMETAs – commenced
The table shows our due diligence and third-party
Tyres, wheels and rims Detailed due diligence commenced on largest/critical direct suppliers. audit priorities across our high-risk taxonomies
SMETAs – commenced
in FY2021.
Technology Due diligence commenced on largest/critical direct suppliers.
Additional taxonomy review to be conducted to prioritise direct and indirect supplier risks prior to targeted SMETA, in collaboration
with direct suppliers in FY2022
Wear consumables Detailed due diligence commenced on largest/critical direct suppliers.
SMETAs – commenced
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