TEXT-EXTRACT 2 filename2.txt 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. David Lamont FirstName BHP GroupLastNameDavid Lamont Ltd Comapany April NameBHP Group Ltd 12, 2023 April 212, 2023 Page 2 Page FirstName LastName 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