Supplier Code of Conduct

You are expected to comply with all laws applicable to you and your business, including those related to anti-bribery, anti-corruption, anti-money laundering, modern slavery, sanctions, export and trade controls. You must not directly or indirectly engage in fraud, corrupt activity (including bribery), exploitation, collusion or other criminal activities. You must also ensure your agents, intermediaries and subcontractors do not engage in such activities, directly or indirectly, in relation to any procurement.

We refer allegations of bribery, corruption, money laundering, terrorism financing and other corrupt or criminal activity to the appropriate authorities.

You should conduct your business in a way that shows sound management. You should have appropriate written procedures and systems in place designed to prevent and combat bribery and corruption. This includes promoting a collaborative relationship where purchasers and suppliers work together to resolve issues in a timely, legitimate and respectful manner. This helps to avoid contractual disputes and promotes good working relationships.

You are expected to familiarise yourself with our anti-corruption initiatives and our business ethics approach (link – new website page for Anti-Corruption Initiatives) on our website. You should have in place adequate procedures to prevent an employee, agent or subsidiary from bribing foreign public officials. The Bribery Prevention Network has useful resources to support businesses in understanding and implementing more robust anti-bribery procedures and measures.

You must not misuse or disclose to any unauthorised person any private, confidential, personal or commercially sensitive information you have received as a result of your dealings with us without our prior approval, unless required by law.

You are expected to immediately notify us of any data breach that may have resulted in unauthorised access or disclosure of our personal, confidential or commercially sensitive data (including that of third parties which we hold) or other information received as a result of your dealings with us (complying with any applicable legislative timeframes and obligations).

You are expected to maintain sound administration processes, risk and corrective action systems and resolve serious incidents in a way that deals with the incident expediently and minimises harm.

You must ensure that all conflicts of interest (whether actual, perceived or potential) relevant to your relationship with us are disclosed to us as soon as possible. Gift giving to our employees is generally discouraged and we may decline gifts and benefits you offer to us. If we do accept a gift or benefit offered by you with a value of more than $100 (excl. GST), it will be publicly reported on our website with your name and gift or benefit details to provide public transparency.

You are expected to maintain complete, accurate and proper records in accordance with applicable laws and standards of all financial transactions and information relating to your business activities, ethics, integrity and conduct, labour and human rights, health, safety and environmental practices and engagement of third parties, including agents.

All workers in our supply chain (and yours) are entitled to fairness, dignity and respect. You are expected to provide a fair and ethical workplace that upholds high standards of human rights and has appropriate labour and human rights policies and practices in place.

We are committed to respecting internationally recognised human rights. We expect you to manage your operations in a manner that respects the human rights of individuals, having regard to international human rights norms and obligations set out by the United Nations, the International Labour Organisation and other relevant laws, treaties and international instruments and codes of conduct.

As a reporting entity under the Modern Slavery Act 2018 (Cth), we are required to report on actions we’ve taken to address any risks of modern slavery within our operations and supply chains and maintain responsible and transparent supply chains. Your entity may also be subject to these, or similar, obligations (including under the Modern Slavery Act 2018 (NSW) or similar legislation in other jurisdictions).

You should make all reasonable efforts to ensure your business and any parties in your supply chain are not engaged in modern slavery. You must never use, or knowingly use in your supply chain, child labour, or any form of forced, bonded, indentured, involuntary or illegal labour. You must also respect workers’ freedom of movement and freedom of association rights in accordance with applicable laws.

The Modern Slavery Act 2018 (Cth) defines ‘modern slavery’ as including human trafficking, slavery, servitude, forced marriage, forced labour, debt bondage, deceptive recruiting for labour or services and child labour.

We are committed to ensuring workplace rights and entitlements are respected. You should ensure your operations and supply chain complies with the Fair Work Act 2009 (Cth) (if applicable) and all other applicable workplace laws, regulations and regulatory instruments, in particular with respect to providing fair and appropriate pay, benefits and working conditions. This includes hours of work consistent with the laws of the relevant jurisdiction.

We also expect you to use your best efforts, make reasonable enquiries and have reasonable oversight to ensure these principles are followed and that there is no modern slavery, or other exploitative practices, occurring in any offshore labour, services materials or goods supplied to us.

We value businesses that have policies and practices in place to encourage diversity and ensure equal employment opportunity for all people.

You are expected not to discriminate against any worker based on race, colour, sex, sexual orientation, age, physical or mental disability, marital status, family or carer's responsibilities, pregnancy, religion, political opinion, national extraction or any other status protected by law, including in your hiring and other employment practices. You are also expected to comply with all applicable laws in this regard.

Worker health, safety and wellbeing is important to us. You are expected to comply with all workplace health and safety laws and regulations and to have sound work health and safety management practices. This may include provision of training, proactive engagement with employees and stakeholders and active workplace hazard management. We expect you to commit to providing a workplace free of bullying, harassment, victimisation, abuse, unlawful or inhumane treatment.

Our corporate values include a commitment to uphold best practice environmental and social standards by addressing our environmental footprint (see our Annual Report) and environmental considerations in our transactions (see our website for more information).

You must comply with all applicable laws and regulations relating to the environment, including any environmental management and reporting obligations. We encourage you to be mindful of the environmental impact of your operations and adopt a continuous improvement approach in this regard.

We expect you to monitor your compliance with this Code. We also expect that you will have in place appropriate mechanisms for reporting concerns to us (including in relation to any material failure to comply with this Code or our contractual arrangements) and processes for their resolution. We are committed to working with you where appropriate to implement remediation plans designed to achieve compliance with this Code. Should remedial action not be taken with respect to any material breach within reasonable timeframes, we may reconsider our business relationship with you.

We reserve the right to review compliance with this Code and expect our suppliers will cooperate in good faith and provide information reasonably required by us to perform such a review (including by allowing access to your systems, data, records and information to the extent reasonably required, including in relation to your supply chain and agents).

If you suspect or are aware of serious wrongdoing, you are encouraged to make a Public Interest Disclosure (or to otherwise report the matter to us as an incident where the public interest disclosure mechanism is not available to you, although noting certain legal protections would not apply). Further information is available on our website and on the Commonwealth Ombudsman website