Always
• Follow BHP due diligence requirements for suppliers, customers, vessels and any other third parties with whom we transact.
• Obtain any necessary export control licences or approvals before proceeding with a transaction.
• Understand the intermediate and ultimate destinations of goods, software, technology and other items or associated technical assistance we provide to third parties, and the source (including country of origin and country of export) of goods, services and other items that third parties are providing to us.
• Understand whether your customer is on-selling BHP commodities. Obtain assurances that such goods are not being on-sold to sanctioned parties, countries or territories.
• Investigate any trade controls red flag in a transaction and do not proceed with the transaction until the issue has been resolved.
• Promptly notify Compliance of any suspected boycott requests received, and any third-party or government inquiries or communications related to compliance with trade control laws and regulations and await guidance on how to proceed.
