SEC Comment Letter 0000000000-23-003670 to BHP Group Ltd (BHP, BHPLF) (CIK 0000811809) (BHP)
BHP Group Ltd (BHP, BHPLF) (CIK 0000811809)
Date: April 12, 2023 · CIK: 0000811809 · Accession: 0000000000-23-003670
AI Filing Summary & Sentiment
File numbers found in text: 001-09526
Letter
United States securities and exchange commission logo April 12, 2023 David Lamont Chief Financial Officer BHP Group Ltd 171 Collins Street Melbourne, Victoria 3000 Australia Re:BHP Group Ltd Form 20-F for the Fiscal Year Ended June 30, 2022 Filed September 6, 2022 File No. 001-09526 Dear David Lamont: We have reviewed your April 6, 2023 response to our comment letter and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may haven additional comments. Unless we note otherwise, our references to prior comments are to comments in our March 10, 2023 letter. Form 20-F for the Fiscal Year Ended June 30, 2022 Exhibits Exhibit 96, page 263 1.We note your response to comment 2 and we do not concur with your assessment. In order to meet the requirements in Item 601(b)(96)(iii)(B)(19)(ii) of Regulation S-K, please revise to include the entire discounted cash flow analysis in each of your respective technical report summary reports.
FirstName LastNameDavid Lamont Comapany NameBHP Group Ltd April 12, 2023 Page 2 FirstName LastName David Lamont BHP Group Ltd April 12, 2023 Page 2 You may contact John Coleman at 202-551-3610 or Craig Arakawa at 202-551-3650 if you have questions regarding comments. Sincerely, Division of Corporation Finance Office of Energy & Transportation
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United States securities and exchange commission logo
April 12, 2023
David Lamont
Chief Financial Officer
BHP Group Ltd
171 Collins Street
Melbourne, Victoria 3000
Australia
Re:BHP Group Ltd
Form 20-F for the Fiscal Year Ended June 30, 2022
Filed September 6, 2022
File No. 001-09526
Dear David Lamont:
We have reviewed your April 6, 2023 response to our comment letter and have the
following comments. In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may haven additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
March 10, 2023 letter.
Form 20-F for the Fiscal Year Ended June 30, 2022
Exhibits
Exhibit 96, page 263
1.We note your response to comment 2 and we do not concur with your assessment. In
order to meet the requirements in Item 601(b)(96)(iii)(B)(19)(ii) of Regulation S-K, please
revise to include the entire discounted cash flow analysis in each of your respective
technical report summary reports.
FirstName LastNameDavid Lamont
Comapany NameBHP Group Ltd
April 12, 2023 Page 2
FirstName LastName
David Lamont
BHP Group Ltd
April 12, 2023
Page 2
You may contact John Coleman at 202-551-3610 or Craig Arakawa at 202-551-3650 if
you have questions regarding comments.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation