1. Purpose
This document outlines the commitment of Partnered Health (the Company) to an ethical, sustainable, and socially responsible procurement process, and the expectations of the same high standards of its suppliers.
2. Scope
This policy applies to all suppliers and Managers at the Company’s facilities and business units within Australia and New Zealand.
3. Policy
The Company views its suppliers as partners, and cares about the way in which they do business when providing goods or services to the Company.
The Supplier Code of Conduct (Code) describes the minimum expectations in the areas of:
(a) Integrity, ethics, and conduct.
(b) Conflict of interest.
(c) Corporate supply chain and governance.
(d) Labour and human rights.
(e) Workplace, health, and safety.
(f) Environmental management.
(b) Conflict of interest.
(c) Corporate supply chain and governance.
(d) Labour and human rights.
(e) Workplace, health, and safety.
(f) Environmental management.
It is an expectation of the Company that suppliers communicate our Code to their related entities, suppliers and subcontractors who support them in supplying goods and services to the Company, so that they are aware of, understand and comply with the Code. It is a further expectation that Managers communicate this policy to any suppliers who do not form part of the procurement process.
4. Procedure
The Company will work with its suppliers to meet and exceed minimum expectations as outlined in this Code and continuously strives to improve the standard of its business practices. Supplier means any entity that supplies goods or services to the Company.
The Code applies to all supply chain partners, including, vendors, contractors, and, importantly, the healthcare providers that deliver services required by our patients, candidates, and clients. This Code applies to the Company’s suppliers’ workers, irrespective of the nature of the contractual relationship – this means that it applies to workers who are engaged informally, on short-term contracts, and on a part time or casual basis.
Where the Code refers to the law it means the laws in the jurisdiction that apply where the services are performed, or the goods procured. Importantly, it is an expectation under this Code that all suppliers operate in full compliance with all laws, rules, and regulations of the jurisdictions in which they conduct business.
The expectations outlined in the Code are not intended to supersede or alter any supplier’s regulatory and contractual obligations. All existing and new suppliers must commit to this Code. Suppliers should check their respective contracts, agreements, and purchase orders with the Company as they may contain additional obligations or higher standards than those set out in this Code.
The Code applies to all supply chain partners, including, vendors, contractors, and, importantly, the healthcare providers that deliver services required by our patients, candidates, and clients. This Code applies to the Company’s suppliers’ workers, irrespective of the nature of the contractual relationship – this means that it applies to workers who are engaged informally, on short-term contracts, and on a part time or casual basis.
Where the Code refers to the law it means the laws in the jurisdiction that apply where the services are performed, or the goods procured. Importantly, it is an expectation under this Code that all suppliers operate in full compliance with all laws, rules, and regulations of the jurisdictions in which they conduct business.
The expectations outlined in the Code are not intended to supersede or alter any supplier’s regulatory and contractual obligations. All existing and new suppliers must commit to this Code. Suppliers should check their respective contracts, agreements, and purchase orders with the Company as they may contain additional obligations or higher standards than those set out in this Code.
Reporting Misconduct, Unethical Behaviour or Suspected Corruption
If a supplier considers that it, or another supplier in its supply chain, has deviated from or breached their obligations under this Code, they must report the concern to the Company within five (5) business days to:
Corrective Action Process
Suppliers are expected to self-assess their compliance with the Code and take timely action to correct any deficiencies or breaches reported or identified by an audit, assessment, inspection, investigation, or review.
Suppliers are encouraged to raise any concerns, discuss, and seek clarification accordingly to any elements of the Code with the Procurement Manager or the primary State contact in relation to the goods or services they are providing. If requested by the Company, suppliers must provide evidence and confirmation of their compliance with the Code, including the provision of documents and records that support their compliance. Suppliers are to support the Company in reviewing compliance with the Code.
Suppliers are encouraged to raise any concerns, discuss, and seek clarification accordingly to any elements of the Code with the Procurement Manager or the primary State contact in relation to the goods or services they are providing. If requested by the Company, suppliers must provide evidence and confirmation of their compliance with the Code, including the provision of documents and records that support their compliance. Suppliers are to support the Company in reviewing compliance with the Code.
Integrity, Ethics and Conduct
The Company expects high standards of ethical conduct and compliance with all applicable laws. Suppliers are expected to be ethical in their business activities, including relationships, practices, sourcing, and operations.
(a) Business Integrity
Suppliers are expected to comply with all anti bribery, anticorruption, anti money laundering and modern slavery laws. Suppliers must not engage in, either directly or indirectly, fraudulent, corrupt, exploitative, or collusive activities.
(b) Record Keeping
Suppliers are expected to maintain adequate records that accurately record all financial transactions and information regarding its business activities, labour, health and safety and environmental practices in accordance with applicable laws, policies, and procedures. Disclosure of information is expected to be undertaken without falsification or misrepresentation.
(c) Professional Conduct
Suppliers are expected to conduct themselves in a manner that is fair, professional and that will not bring the Company into disrepute.
(d) Confidentiality
Suppliers must not improperly use any private, confidential, or commercially sensitive information in its possession relating to or in connection with its dealings with the Company.
Conflicts of Interest
The Company believes that all business activities should be undertaken with impartiality and any conflict of interest should be raised and managed. Suppliers are to declare to the Procurement Manager any situation that raises an actual, potential, or perceived conflict of interest related to or in connection with its dealings with the Company.
Suppliers are to avoid financial, business, or other relationships which may compromise the performance of their duties under their business arrangement with the Company. Any conflicts of interest that cannot be avoided are expected to be declared and managed appropriately.
Suppliers are to avoid financial, business, or other relationships which may compromise the performance of their duties under their business arrangement with the Company. Any conflicts of interest that cannot be avoided are expected to be declared and managed appropriately.
Corporate and Supply Chain Governance
Commitment to sound corporate management, supply chain governance, risk and corrective action systems are key to a reliable supply chain for the Company. Suppliers are required to maintain sound processes to this effect.
(a)Risk Assessment and Management
Suppliers should develop and maintain a process to identify, manage and control relevant risks associated with their operations, including worker engagement practices. These include supply chain risks and risks relating to labour and human rights, modern slavery, health and safety, business ethics, and corporate governance.
(b) Critical Incident Management
Suppliers should:
(i) Identify and assess potential critical incident, emergency situations and business continuity risks.
(ii) Develop and implement emergency plans and response procedures that minimise harm to life, environment, and property, while minimising disruption to business continuity.
(c) Audits and assessments
To ensure compliance with this Code and Commonwealth Workplace Laws, suppliers are required to:
(i) Perform periodic evaluations of their operations and the operations of their subcontractors.
(ii) Cooperate openly and honestly with any audit, assessment or review initiated by the Company or a Regulator.
Labour and Human Rights
The Company believes that all workers in its supply chains deserve to be treated with dignity, respect and in a manner, which complies with Commonwealth Workplace Laws.
Commonwealth Workplace Laws means the Fair Work Act 2009 (Cth), the Fair Work (Transitional Provisions and Consequential Amendments) Act 2009 (Cth), the Fair Work Regulations 2009 (Cth), the Fair Work (Transitional Provisions and Consequential Amendments) Regulations 2009 (Cth); the Superannuation Act 1976 (Cth) and laws covering discrimination and bullying in employment or occupation including the Age Discrimination Act 2004 (Cth), Disability Discrimination Act 1992 (Cth), Racial Discrimination Act 1975 (Cth), Sex Discrimination Act 1984 (Cth) and the Australian Human Rights Commission Act 1986 (Cth).
The Company acknowledges that some workers may be vulnerable workers, with considering factors such as their age, experience, and immigration status, and that it is particularly important to ensure such workers are made aware of their rights under Commonwealth Workplace Laws to mitigate against their risk of exploitation.
Suppliers must engage their workers lawfully and integrate appropriate labour and human rights policies and practices into their business and broader supply chains.
Commonwealth Workplace Laws means the Fair Work Act 2009 (Cth), the Fair Work (Transitional Provisions and Consequential Amendments) Act 2009 (Cth), the Fair Work Regulations 2009 (Cth), the Fair Work (Transitional Provisions and Consequential Amendments) Regulations 2009 (Cth); the Superannuation Act 1976 (Cth) and laws covering discrimination and bullying in employment or occupation including the Age Discrimination Act 2004 (Cth), Disability Discrimination Act 1992 (Cth), Racial Discrimination Act 1975 (Cth), Sex Discrimination Act 1984 (Cth) and the Australian Human Rights Commission Act 1986 (Cth).
The Company acknowledges that some workers may be vulnerable workers, with considering factors such as their age, experience, and immigration status, and that it is particularly important to ensure such workers are made aware of their rights under Commonwealth Workplace Laws to mitigate against their risk of exploitation.
Suppliers must engage their workers lawfully and integrate appropriate labour and human rights policies and practices into their business and broader supply chains.
(a) Anti-Discrimination
Subject to applicable laws, suppliers must not discriminate against any worker based on age, disability, ethnicity, gender, marital status, political affiliation, race, religion, sexual orientation, gender identity, union membership, or any other status protected by law, in hiring, employment or other worker engagement practices.
(b) Anti-Harassment
Suppliers must commit to a work environment free from bullying, harassment, victimisation, and abuse. Suppliers are not to bully workers or threaten workers with, or subject them to, unlawful or inhumane treatment. This includes, but is not limited to, abuse and harassment which can be verbal, physical, sexual, or psychological.
(c) Human Rights
Suppliers must provide services in a manner consistent with any applicable human rights obligations.
Suppliers must prevent involuntary and underage labour by ensuring:
(i) That all work is undertaken without coercion.
(ii) They are not used for any form of forced, bonded, or indentured labour.
(iii) Engaged workers are the applicable minimum legal age.
Suppliers must use temporary and outsourced labour within the limits of the law by ensuring:
(i) All reasonable endeavours are used to ensure that any third-party subcontractors, including labour services providers it uses, undertake to comply with applicable law as well as the provisions of this Code.
(ii) That they do not and will not attempt to disguise an employment relationship as an independent contracting arrangement.
(iii) Be responsible for the implementation of supply chain governance systems and processes to ensure workers are lawfully engaged by the engaging entities within its supply chain/s, whether directly or through third-party organisations.
(d) Working Hours, Wages and Benefits
Suppliers must:
(i) Follow all applicable laws and regulations with respect to wages, working hours and workers compensation insurance.
(ii) Ensure that all workers receive their legally mandated minimum wages, benefits, superannuation, leave entitlements and time off for legally recognised holidays.
(iii) Pay workers’ wages as required under applicable laws in a timely manner and not be expected to use wage deductions as a disciplinary measure. All overtime is expected to be reasonable and paid at the rate and in accordance with the applicable laws.
(e) Freedom of association and collective bargaining
Suppliers are expected to freely allow workers to associate with others, form, and join (or refrain from joining) industrial organisations or associations of their choice and bargain collectively, or engage in any lawful industrial activity without interference, discrimination, retaliation, or harassment.
Workplace Health and Safety
Worker health, safety, and wellbeing is important to the Company. Suppliers are expected to provide a healthy and safe work environment for all workers, and to integrate sound health and safety management practices into their businesses.
Suppliers must comply with all applicable laws relating to workplace health and safety. They are expected to manage occupational health and safety hazards and provide workers with job-related training. Suppliers are to consult with their workers in relation to the provision of information and training.
Suppliers must comply with all applicable laws relating to workplace health and safety. They are expected to manage occupational health and safety hazards and provide workers with job-related training. Suppliers are to consult with their workers in relation to the provision of information and training.
Environmental Management
The Company is committed to promoting environmental responsibility. Suppliers are expected to minimise the environmental impact of their operations and maintain environmentally responsible policies and practices.
Suppliers must comply with all applicable laws and regulations relating to the environment, including any management, and reporting obligations. Suppliers are expected to manage the environmental impact of their operations by:
Suppliers must comply with all applicable laws and regulations relating to the environment, including any management, and reporting obligations. Suppliers are expected to manage the environmental impact of their operations by:
(a) Ensuring the safe storage, transportation and disposal of hazardous substances including hazardous waste.
(b) Maintaining policies and practices for the efficient use of energy, water, and natural resource consumption.
Maintaining policies and practices that reduce the risk of pollution, loss of biodiversity, deforestation, damage to ecosystems and greenhouse gas emissions.
This document is uncontrolled when printed. The current version of this policy is available on Flare in the Library.
If you require any clarification of this policy, email matthew.barry@partneredhealth.com.au
This document is uncontrolled when printed. The current version of this policy is available on Flare in the Library.
If you require any clarification of this policy, email matthew.barry@partneredhealth.com.au
Version History
| Version No | Issue Date | Description of Changes |
|---|---|---|
| 1. | April 2021 | Published for consultation |
| 2. | February 2022 | Adapted for Partnered Health |