Ethical Sourcing Policy

Podpac Pty Ltd is dedicated to conducting business, and sourcing goods and services ethically and responsibly. We recognise the importance of protecting human rights, promoting fair and safe working conditions, and maintaining high standards of business integrity. We expect our suppliers to uphold these principles throughout their operations and supply chains.

Purpose

This Policy sets out the minimum ethical sourcing expectations for suppliers providing goods and services to Podpac and to support our commitment relating to forced labour, child labour, workplace health and safety, fair working conditions, human rights and ethical business conduct.

Scope and Application

References in this Policy to:

  • ‘Suppliers’ means direct suppliers of goods or services to Podpac Pty Ltd. Suppliers are also expected to communicate and promote the principles of this Policy within their own operations and relevant supply chains, including subcontractors and labour providers.
  • ‘Workers’ means any person performing work for or on behalf of a supplier, including permanent, temporary, casual, contract, migrant, agency and labour-hire workers.

Policy Implementation

Podpac is committed to maintaining responsible and ethical practices throughout our supply chain and will not accept unresolved human rights violations or breaches of this Policy.

Where concerns are identified, Podpac will work with suppliers to understand the circumstances and support appropriate remediation for affected parties. Suppliers will be treated fairly and with consideration of the individual circumstances involved.

Labour Standards and Human Rights

  • Suppliers must not engage in, support or benefit from any form of modern slavery, including slavery, servitude, forced or compulsory labour, bonded labour, debt bondage, human trafficking, deceptive recruitment, forced marriage, or involuntary prison labour.
  • Suppliers shall not use child labour, where a child is defined as a person below the minimum legal age for employment or the age for completing compulsory education under applicable local laws, whichever provides the greater protection.
  • Workers under the age of 18 must not perform hazardous work or other work that may jeopardise their health, safety, education or development, in accordance with applicable laws.
  • Employment must be freely chosen and workers must not be subject to coercion, threats, intimidation or restrictions that prevent them from freely entering or leaving employment.
  • Workers must be free to leave the workplace after completing their working hours and free to leave their employment in accordance with applicable laws and reasonable contractual notice requirements.
  • Workers must not be required to pay recruitment fees, deposits or other inappropriate charges as a condition of obtaining or retaining employment.
  • Workers must be provided with clear and understandable information regarding the terms and conditions of their employment before commencing work.
  • Suppliers must comply with applicable right-to-work and immigration requirements and verify workers’ eligibility to work using lawful processes.

Human Rights and Culture of Respect

  • Suppliers must respect the dignity and internationally recognised human rights of workers and others affected by their operations.
  • Workers must not be subjected to physical, verbal, sexual or psychosocial abuse, harassment, intimidation, coercion, bullying or degrading treatment.
  • Suppliers will take reasonable measures to prevent and address any inappropriate workplace conduct.
  • Suppliers will not unlawfully discriminate in recruitment, employment, remuneration, training, promotion or termination on any protected ground, including race, sex, age, disability, religion, pregnancy, sexual orientation, gender identity or family responsibilities.
  • Suppliers must provide workers with appropriate means to raise workplace, ethical or human rights concerns in good faith without fear of retaliation, discrimination, dismissal or other disadvantage.
  • Where a supplier identifies that it has caused or contributed to an adverse human rights impact, it must take appropriate steps to provide for or cooperate in remediation.

Workplace Health and Safety

  • Suppliers must comply with applicable workplace health and safety laws and provide a safe and healthy working environment.
  • Suppliers will provide and maintain safe plant, equipment, systems of work and workplace facilities and manage health and safety risks so far as is reasonably practicable.
  • Suppliers will provide workers with appropriate information, instruction, training and supervision and suitable personal protective equipment (PPE) where required.
  • Suppliers will maintain appropriate arrangements for emergency preparedness, workplace incidents, occupational injuries and illnesses.
  • Workplace incidents and hazards must be appropriately reported, investigated and addressed to reduce the risk of recurrence.
  • Suppliers will assign clear management responsibility for workplace health, safety and worker wellbeing.

Wages and Benefits

  • Workers must be paid at least the minimum wages, overtime rates and employment benefits required by applicable laws, regulations, employment conditions or collective agreements.
  • Workers must receive all legally required leave, benefits and social security or equivalent employment entitlements.
  • All workers must be provided with written, accessible, and understandable information regarding their wages and employment conditions before commencing employment and about the particulars of their wages for the pay period concerned each time they are paid.
  • Suppliers must not make unlawful or unauthorised deductions from workers’ wage or use wage deductions as an inappropriate disciplinary measure.
  • Suppliers must maintain accurate and complete records of wages and benefits paid to each worker.
  • Suppliers will ensure workers are engaged under lawful and recognised employment arrangements and receive all applicable employment and social security entitlements.
  • Suppliers will not avoid these obligations through inappropriate use of labour-only contracting, subcontracting, home-working arrangements, fixed-term contracts or apprenticeship schemes that do not provide genuine training or employment.

Working Hours

  • Suppliers will ensure working hours comply with applicable laws, regulations and employment conditions.
  • Suppliers will ensure workers do not exceed applicable maximum working hours, including any permitted or reasonable additional hours, and provided with appropriate rest periods and days off.
  • Suppliers will provide workers with all meal and rest breaks required under applicable laws or employment conditions.
  • Suppliers will ensure overtime is reasonable and compensated in accordance with applicable laws and employment conditions.
  • Suppliers will maintain accurate and complete records of workers’ hours, including overtime, as required by applicable laws.

Ethical Business Conduct

  • Suppliers must conduct business lawfully, honestly and with integrity and comply with applicable laws relating to bribery, corruption, fraud, competition and other unethical business practices.
  • Actual or potential conflicts of interest relating to Podpac business must be appropriately disclosed.
  • Suppliers must maintain accurate business, financial and operational records and must not falsify or deliberately misrepresent information relating to goods, services, workers or supply-chain activities.
  • Suppliers must appropriately protect confidential information, intellectual property and personal information obtained through their business relationship with Podpac.

Supply Chain Transparency and Due Diligence

  • Suppliers shall maintain appropriate visibility of their supply chains and take reasonable steps to identify and manage ethical, labour, human rights and modern slavery risks.
  • Suppliers shall provide accurate information on the origin, manufacture and supply of goods or services, including relevant subcontractors, labour providers or production locations, where reasonably requested by Podpac.
  • Suppliers shall communicate appropriate ethical sourcing requirements to relevant parties within their own supply chains.
  • Suppliers shall maintain appropriate records and cooperate with reasonable Podpac requests relating to due diligence, assessments or corrective actions.

Compliance and Monitoring

  • Suppliers shall periodically assess their operations and supply chains for risks relating to this Policy and maintain appropriate controls to address identified risks.
  • Suppliers shall monitor compliance through appropriate reviews, audits or assessments and maintain relevant records where required.
  • Suppliers shall cooperate with reasonable requests from Podpac for information, documentation or verification of compliance.
  • Where non-compliance is identified, suppliers shall take timely corrective action and, where appropriate, notify Podpac of significant issues.

This Policy reflects Podpac values of integrity, trust and responsible business conduct. We expect suppliers to meet the standards outlined in this Policy, comply with applicable legal obligations, and work constructively to address identified risks and support continuous improvement across the supply chain.