Anti-Discrimination — Sex/Age/Race/Disability Discrimination Acts (Cth) + AHRC Act complaints + Equal Opportunity Act 1984 (WA)

Cth + WA anti-discrimination — Sex Discrimination Act (non-harassment), Age, Racial and Disability Discrimination Acts, AHRC Act complaints framework, Equal Opportunity Act 1984 (WA)

Requirements: 43
Last reviewed: 21/05/2026
Next review: 21/05/2027
Source: All Cth Acts: current Federal Register compilations as at 2026-05-21 (incorporates Anti-Discrimination and Human Rights Legislation Amendment (Respect at Work) Act 2022 across SDA/ADA/RDA/DDA/AHRCA — civil victimisation pathways and complaint-termination 24-month limit standardised). No further substantive amendments in 2024-2026 verified for these provisions. EOA-WA: current consolidated text on legislation.wa.gov.au at 2026-05-21; no in-force amendments to Parts II / IIAA / IIA / IIB / III / IV / IVA / IVB or to ss.67/161 verified in 2024-2026.

Reconciliation notes

Curated build of the Australian Cth and WA anti-discrimination corpus covering: Sex Discrimination Act 1984 (Cth) non-harassment provisions (harassment + positive duty in Framework 3 sda-positive-duty.md); Age Discrimination Act 2004 (Cth); Racial Discrimination Act 1975 (Cth) including Part IIA racial vilification; Disability Discrimination Act 1992 (Cth) including unjustifiable hardship test; Australian Human Rights Commission Act 1986 (Cth) Part IIB complaint framework; Equal Opportunity Act 1984 (WA) attribute Parts II / IIAA / IIA / IIB / III / IV / IVA / IVB plus victimisation (s.67) and vicarious liability (s.161). Primary anchor policy: GOV-POL-009 (Equal Employment Opportunity). Secondary anchor: GOV-POL-014 (Sexual Harassment Prevention) — for SDA non-harassment sections that GOV-POL-014 also touches via its protected-attribute coverage; main GOV-POL-014 anchoring is in Framework 3. Scope decisions: (a) Westlink modelled as employer / PCBU only — partnership, qualifying-body, registered-organisation, qualifying-educational-body and employment-agency contexts captured only where the section is a single Part 4 / Div 1 / Div 2 employment provision (e.g., ADA s.18 / DDA s.15 / SDA s.14), with related contexts cross-referenced in evidence notes but not separately rowed; (b) WA EOA modelled at one row per attribute Part rather than per attribute-specific employment section — Part-level audit granularity is the right abstraction for a Cth-state cross-reference framework, and the operative employment-discrimination section number is captured in the clause field; (c) victimisation civil pathway captured separately for each Act (SDA s.47A, ADA s.47A, RDA s.18AA, DDA s.58A, EOA-WA s.67); SDA criminal victimisation (s.94) remains in Framework 3; (d) accessorial liability and vicarious liability captured per-Act because they have different defence regimes — but SDA s.105/s.106 stay in Framework 3 (already shipped) and are not re-rowed here. ID prefix convention: SDA-* (sections distinct from Framework 3 — Framework 3 has 28A/28AA/28B/28M/47C/94/105/106; this framework adds 5/5A/5B/5C/6/7/7AA/7A/8A/14/15/16/47A); ADA-* for Age Discrimination Act; RDA-* for Racial Discrimination Act; DDA-* for Disability Discrimination Act; AHRCA-* for AHRC Act 1986 (Framework 3 uses AHRC-PD-* and AHRC-CEP-* — no collision); EOA-WA-* for WA EO Act. Verification status: every cited section number was directly read from the current FRL or legislation.wa.gov.au compilation on 2026-05-21 via WebFetch — the candidate-frameworks.md doc had multiple section-numbering errors at A2 stage (training-data drift); corrections recorded inline in that file's prelude note. Important framework-3 cross-reference: AHRC's positive-duty enforcement powers under SDA s.47C are conferred by AHRC Act 1986 Part 4A ss.35A-35K (not in this framework's scope; backing for Framework 3 AHRC-CEP-01). Total requirements: 43. Applicable: 42. Reference-only: 1 (AHRC President's inquiry/conciliation process under s.46PF — captured as a procedural-awareness row rather than a substantive Westlink duty).

Requirements

Showing 43 of 43 requirements

ID	Clause	Requirement	Applicability	Coverage	Evidence	Gap
SDA-5-01	SDA s.5	Sex discrimination — it is unlawful to discriminate on the ground of sex (direct or indirect). Direct: less favourable treatment because of sex (or a characteristic that appertains generally to persons of that sex). Indirect: imposing a condition, requirement or practice with which a higher proportion of persons of the other sex comply, that is not reasonable in the circumstances, and that the affected person does not or cannot comply with.	Applicable	Full	GOV-POL-009 §Policy Commitments — Protected-attributes paragraph expressly lists sex; merit-based decision commitment operationalises non-discrimination across employment lifecycle.
SDA-5A-01	SDA s.5A	Sexual orientation — it is unlawful to discriminate on the ground of sexual orientation (direct or indirect). Definition covers sexual orientation towards persons of the same sex, the opposite sex, the same and the opposite sex, or otherwise. Inserted by Sex Discrimination Amendment (Sexual Orientation, Gender Identity and Intersex Status) Act 2013.	Applicable	Full	GOV-POL-009 §Policy Commitments — Protected-attributes paragraph expressly lists sexual orientation. Commitment 1 (merit-based decisions) and Commitment 2 (equal access to training/development) apply.
SDA-5B-01	SDA s.5B	Gender identity — it is unlawful to discriminate on the ground of gender identity (direct or indirect). Definition covers gender-related identity, appearance, mannerisms or other gender-related characteristics, with or without regard to the person's designated sex at birth. Inserted by Sex Discrimination Amendment (Sexual Orientation, Gender Identity and Intersex Status) Act 2013.	Applicable	Full	GOV-POL-009 §Policy Commitments — Protected-attributes paragraph expressly lists gender identity.
SDA-5C-01	SDA s.5C	Intersex status — it is unlawful to discriminate on the ground of intersex status (direct or indirect). 'Intersex status' means the status of having physical, hormonal or genetic features that are neither wholly female nor wholly male, or a combination of female and male, or neither female nor male. Inserted by Sex Discrimination Amendment (Sexual Orientation, Gender Identity and Intersex Status) Act 2013.	Applicable	Full	GOV-POL-009 §Policy Commitments — Protected-attributes paragraph expressly lists intersex status.
SDA-6-01	SDA s.6	Marital or relationship status — it is unlawful to discriminate on the ground of marital or relationship status (direct or indirect). 'Relationship status' covers de facto relationships including same-sex relationships.	Applicable	Full	GOV-POL-009 §Policy Commitments — Protected-attributes paragraph expressly lists marital or relationship status.
SDA-7-01	SDA s.7	Pregnancy or potential pregnancy — it is unlawful to discriminate on the ground of pregnancy or potential pregnancy (direct or indirect). Single section covering both grounds since the Sex Discrimination Amendment (Pregnancy and Work) Act 2003 consolidated them.	Applicable	Full	GOV-POL-009 §Policy Commitments — Protected-attributes paragraph expressly lists pregnancy or potential pregnancy.
SDA-7AA-01	SDA s.7AA	Breastfeeding — it is unlawful to discriminate on the ground of breastfeeding (direct or indirect). 'Breastfeeding' includes the act of expressing milk and an attendant condition. Inserted by Sex and Age Discrimination Legislation Amendment Act 2011.	Applicable	Partial	GOV-POL-009 §Policy Commitments — Protected-attributes paragraph references pregnancy and family responsibilities; breastfeeding not separately named but is implied by SDA protected-attributes coverage.	Low GOV-POL-009 protected-attributes paragraph does not separately name breastfeeding — consider explicit inclusion alongside pregnancy and family responsibilities in the next minor revision to remove ambiguity. Operational practicalities (lactation breaks, suitable space, refrigeration for stored milk) sit at procedure level.
SDA-7A-01	SDA s.7A	Family responsibilities — it is unlawful for an employer to discriminate against an employee on the ground of the employee's family responsibilities (in the context of terminating employment or imposing detrimental change). Note: SDA family-responsibilities protection is narrower than the FW Act / state equivalents — it specifically applies to dismissal-style adverse action by an employer.	Applicable	Full	GOV-POL-009 §Policy Commitments — Protected-attributes paragraph expressly lists family or carer's responsibilities. External-complaint pathway notes that workers can lodge with FWC under FW Act Part 3-1 (broader protection) or AHRC under SDA s.7A.
SDA-8A-01	SDA s.8A	Workplace environment that is hostile for 2 or more reasons — where a workplace environment is hostile on the ground of sex (per s.28M) AND on one or more other prohibited grounds (sexual orientation, gender identity, intersex status, marital/relationship status, pregnancy, breastfeeding, family responsibilities), the conduct is unlawful on each applicable ground. Inserted by the Anti-Discrimination and Human Rights Legislation Amendment (Respect at Work) Act 2022 — Respect@Work multi-attribute provision.	Applicable	Partial	GOV-POL-009 §Policy Commitments — Protected-attributes paragraph covers each underlying ground individually; multi-attribute hostile-environment risk not separately named. GOV-POL-014 §Organisational Context — Risk factors (male-dominated settings, isolated work, alcohol at events) are common to multi-attribute hostile environments; GOV-POL-014 Commitment 4 (Risk Management) addresses these.	Low Neither GOV-POL-009 nor GOV-POL-014 explicitly addresses the s.8A multi-attribute hostile-environment ground (e.g., a workplace hostile to a person on the basis of both sex AND sexual orientation). Consider adding a note in GOV-POL-014's hostile-environment commentary or GOV-POL-009's protected-attributes paragraph that hostile-environment risk is assessed cumulatively across multiple protected attributes.
SDA-14-01	SDA s.14	Discrimination in employment or in superannuation — it is unlawful for an employer to discriminate against an employee or job applicant on any SDA ground in: terms or conditions of employment, opportunities for promotion/transfer/training, access to benefits, dismissal, or other detrimental treatment. Section covers superannuation arrangements in the same way as employment.	Applicable	Full	GOV-POL-009 §Scope — Scope covers recruitment, selection, terms and conditions, training, development, performance management, promotion, transfer and termination — comprehensive employment lifecycle coverage. GOV-POL-009 §Policy Commitments — Commitment 1 (merit-based decisions) and Commitment 2 (equal access to training and development) operationalise s.14 prohibitions.
SDA-15-01	SDA s.15	Discrimination against commission agents — it is unlawful for a principal to discriminate against a commission agent or a person seeking to become a commission agent on any SDA ground, in the same terms as s.14 (employment-equivalent prohibitions).	Applicable	Partial	GOV-POL-009 §Scope — Scope extends to contractors; commission-agent relationships are uncommon for Westlink but the scope clause is broad enough to capture them.	Low Commission-agent arrangements are uncommon at Westlink (typical engagements are employees, labour-hire workers, or contract workers); s.15 is captured for completeness but practical exposure is low. No remediation required unless Westlink's business model shifts to use commission agents.
SDA-16-01	SDA s.16	Discrimination against contract workers — it is unlawful for a principal to discriminate against a contract worker on any SDA ground, in the same terms as s.14. Captures labour-hire and engaged contractors when the principal organisation is making the discriminatory decision.	Applicable	Full	GOV-POL-009 §Scope — Scope expressly extends to contractors and labour hire workers — captures the s.16 relationship.
SDA-47A-01	SDA s.47A	Victimisation (civil pathway) — it is unlawful to subject or threaten to subject another person to any detriment because they have made or proposed to make a complaint, given evidence/information, brought or proposed proceedings, asserted SDA rights, or refused to do something that would be unlawful under the Act — or because the first person believes the other has done or may do those things. Civil unlawful conduct is distinct from the criminal offence in s.94 (in Framework 3 sda-positive-duty.md SDA-94-01); civil pathway clarified by the Anti-Discrimination and Human Rights Legislation Amendment (Respect at Work) Act 2022.	Applicable	Full	GOV-POL-009 §Policy Commitments — Commitment 4 expressly commits to investigating complaints and protecting complainants and witnesses from victimisation. GOV-POL-014 §Policy Commitments — Closing paragraph of Policy Commitments prohibits victimisation/reprisal as a separate breach of the Sex Discrimination Act.
ADA-14-01	ADA s.14	Discrimination on the ground of age — direct discrimination. A person directly discriminates against another person on the ground of age if, because of the other's age (or a characteristic that appertains generally to persons of that age, or is generally imputed), the first treats or proposes to treat the other less favourably than in the same or materially similar circumstances they would treat someone of a different age.	Applicable	Full	GOV-POL-009 §Policy Commitments — Protected-attributes paragraph expressly lists age; merit-based decision commitment applies.
ADA-15-01	ADA s.15	Discrimination on the ground of age — indirect discrimination. Indirect age discrimination occurs where a person imposes (or proposes to impose) a condition, requirement or practice that has, or is likely to have, the effect of disadvantaging persons of the other's age, and the condition is not reasonable in the circumstances.	Applicable	Partial	GOV-POL-009 §Policy Commitments — Commitment 1 (merit-based decisions on genuine requirements of the position) implicitly addresses indirect discrimination — selection criteria must be defensible against age-based disparate impact.	Medium Indirect discrimination (an unreasonable condition with disparate impact) is not explicitly addressed; the merit / genuine-occupational-requirement commitment only implicitly engages the reasonableness test.
ADA-18-01	ADA s.18	Discrimination in employment — it is unlawful for an employer to discriminate on the ground of age against an employee or job applicant in: arrangements for determining who should be offered employment, terms or conditions, opportunities for promotion/transfer/training, dismissal, or any other detriment. (Part 4 Division 2 of the ADA contains parallel prohibitions for commission agents, contract workers, partnerships, qualifying bodies, registered organisations and employment agencies — captured by reference rather than as separate rows.)	Applicable	Full	GOV-POL-009 §Scope — Scope covers the employment lifecycle and extends to contractors and labour hire workers — captures the s.18 employment prohibition and the s.20 contract-worker parallel. GOV-POL-009 §Policy Commitments — Commitment 1 (merit-based decisions) and Commitment 2 (equal access) operationalise s.18.
ADA-47A-01	ADA s.47A	Victimisation — it is unlawful to subject or threaten to subject another person to any detriment because they have made a complaint, given evidence, brought proceedings, asserted rights, or refused to do an unlawful act under the ADA. Drafted as an unlawful civil-conduct provision, parallel to SDA s.47A.	Applicable	Full	GOV-POL-009 §Policy Commitments — Commitment 4 (investigation and protection from victimisation) covers victimisation across all federal anti-discrimination Acts.
ADA-56-01	ADA s.56	Liability of persons involved in unlawful acts — a person who causes, instructs, induces, aids or permits another to do an unlawful act under the ADA is taken also to have done the act. Accessorial liability extends to managers, supervisors and third parties; no 'all reasonable steps' defence in this section.	Applicable	Partial	GOV-POL-009 §Responsibilities — Managers and Supervisors row obliges them to take prompt action on any discriminatory conduct observed or reported — operationalises the duty not to permit unlawful conduct.	Low GOV-POL-009 does not explicitly flag personal-liability consequences for supervisors who turn a blind eye to age discrimination (cf. parallel concern for SDA s.105 in Framework 3). Consider adding to manager training material that toleration of discriminatory conduct attracts personal accessorial liability across all federal anti-discrimination Acts.
RDA-10-01	RDA s.10	Rights to equality before the law — if, by reason of a law of the Commonwealth/State/Territory, persons of a particular race, colour or national or ethnic origin do not enjoy a right that is enjoyed by persons of another race/colour/origin (or enjoy it to a more limited extent), then by force of this section they shall enjoy that right to the same extent. RDA's central general prohibition; operates as the substantive non-discrimination rule across all areas. (Note: RDA does NOT have a separate s.5/s.6 direct-vs-indirect structure like SDA/ADA/DDA — s.10 is the operative test.)	Applicable	Full	GOV-POL-009 §Policy Commitments — Protected-attributes paragraph lists race, colour, national extraction, ethnic origin, social origin — comprehensive RDA coverage.
RDA-15-01	RDA s.15	Employment — it is unlawful for an employer (or person acting on behalf of an employer) to refuse or fail to employ a person, to dismiss or refuse to retain a person, or to discriminate against a person in the terms or conditions of employment, opportunities, training, or other employment-related benefits, by reason of race, colour, national or ethnic origin. Parallel prohibitions for commission agents, contract workers and partnerships sit at ss.16-17 (captured by reference).	Applicable	Full	GOV-POL-009 §Scope — Scope covers employment lifecycle and contractors — captures s.15 employment prohibition. GOV-POL-009 §Policy Commitments — Commitment 1 (merit-based decisions) and Commitment 2 (equal access) operationalise s.15.
RDA-18C-01	RDA s.18C	Offensive behaviour because of race, colour or national or ethnic origin — it is unlawful for a person to do an act, otherwise than in private, that is reasonably likely in all the circumstances to offend, insult, humiliate or intimidate another person or a group of people, and which is done because of the race, colour or national or ethnic origin of the other person or of some or all of the people in the group. Section 18D provides exemptions for: artistic work; academic, artistic or scientific publication, discussion or debate; and fair and accurate reporting/comment done reasonably and in good faith on a matter of public interest. (Applicable to workplace conduct — workplaces and work-related communications are 'otherwise than in private'.)	Applicable	Partial	GOV-POL-009 §Policy Commitments — Protected-attributes coverage and merit-based decisions implicitly cover racial-vilification conduct; Westlink's Workplace Behaviour Policy (GOV-POL-006) is the operational anchor for offensive-conduct prohibition. GOV-POL-006 — Workplace Behaviour Policy — operational standard for respectful-conduct expectations and prohibition on offensive behaviour.	Low GOV-POL-009 does not separately address racial vilification under s.18C; coverage relies on the cross-reference to GOV-POL-006 Workplace Behaviour Policy. Consider adding an explicit note in GOV-POL-009's protected-attributes paragraph that race-based offensive behaviour is unlawful under s.18C and is addressed through GOV-POL-006.
RDA-18AA-01	RDA s.18AA	Victimisation — it is unlawful to subject or threaten to subject another person to any detriment because they have made or propose to make an RDA complaint, given evidence/information, brought proceedings, asserted RDA rights, or refused to do an unlawful act. Parallel to SDA s.47A and ADA s.47A civil victimisation pathways. (Older RDA numbering had this at s.27; current FRL compilation uses s.18AA.)	Applicable	Full	GOV-POL-009 §Policy Commitments — Commitment 4 (investigation and protection from victimisation) covers victimisation across all federal anti-discrimination Acts.
RDA-18A-01	RDA s.18A and s.18E	Vicarious liability — RDA has two parallel vicarious liability provisions: s.18A (Part II — vicarious liability for racial discrimination by employees/agents in connection with employment/agency) and s.18E (Part IIA — vicarious liability for racial vilification by employees/agents). Both contain a defence where the employer/principal proves it took all reasonable steps to prevent the conduct.	Applicable	Partial	GOV-POL-009 §Policy Commitments — Commitment 5 (workforce awareness training) operationalises the 'all reasonable steps' defence — training records evidence reasonable steps. GOV-POL-009 §Responsibilities — Responsibilities table cascade (CEO, QHSE Manager, Managers/Supervisors, Workers) provides supervisory layer engaged in prevention.	Medium GOV-POL-009 does not explicitly identify itself as evidence supporting an RDA 'all reasonable steps' defence under s.18A/s.18E. For vicarious-liability audit defensibility, the policy + training records package should be cross-referenced explicitly. Same gap applies across all four federal anti-discrimination Acts.
DDA-5-01	DDA s.5	Direct disability discrimination — a person discriminates against another on the ground of disability if, because of the disability, the person treats or proposes to treat the other less favourably than in the same or materially similar circumstances they would treat someone without the disability. Includes the failure to make reasonable adjustments where required to avoid less favourable treatment.	Applicable	Full	GOV-POL-009 §Policy Commitments — Protected-attributes paragraph expressly lists physical or mental disability (past, present, or imputed). Commitment 3 (reasonable adjustments) operationalises the s.5 reasonable-adjustment limb. GOV-POL-010 §Policy Commitments — Flexible working and reasonable adjustments commitment — DDA s.5 disability discrimination.
DDA-6-01	DDA s.6	Indirect disability discrimination — occurs where a person requires a person with disability to comply with a requirement or condition that has, or is likely to have, the effect of disadvantaging persons with the disability, and the requirement is not reasonable having regard to the circumstances of the case. Includes the failure to make reasonable adjustments where the adjustment would have prevented the disadvantage.	Applicable	Full	GOV-POL-009 §Policy Commitments — Commitment 3 (reasonable adjustments unless unjustifiable hardship) directly addresses the indirect discrimination test.
DDA-11-01	DDA s.11	Unjustifiable hardship — for purposes of the Act, in determining whether a hardship that would be imposed on a person is unjustifiable, all relevant circumstances of the particular case must be taken into account, including: (a) the nature of the benefit or detriment likely to accrue or be suffered by any person; (b) the effect of the disability of any person concerned; (c) the financial circumstances and estimated amount of expenditure required; and (d) the availability of financial and other assistance. Section 21B (employment-context exception) and s.11 together define the unjustifiable-hardship defence.	Applicable	Partial	GOV-POL-009 §Policy Commitments — Commitment 3 expressly references unjustifiable hardship as the limit of the reasonable-adjustment obligation.	Medium GOV-POL-009 references unjustifiable hardship at policy level but does not document the decision-making framework for unjustifiable-hardship determinations (factors weighing, sign-off authority, record-keeping). Consider documenting this in a reasonable-adjustments procedure cross-referenced from the policy.
DDA-15-01	DDA s.15	Discrimination in employment — it is unlawful for an employer to discriminate against an employee or job applicant on the ground of disability in: arrangements for offering employment, terms or conditions, opportunities for promotion/transfer/training, dismissal, or any other detriment. Parallel prohibitions in ss.16-17 for commission agents and contract workers (captured by reference).	Applicable	Full	GOV-POL-009 §Scope — Scope covers employment lifecycle and contractors — captures s.15-17 employment-context coverage. GOV-POL-009 §Policy Commitments — Commitments 1, 2 and 3 operationalise s.15.
DDA-58A-01	DDA s.58A	Victimisation — it is unlawful to subject or threaten to subject another to any detriment because of acts in connection with a DDA complaint, evidence, proceedings, rights assertion or refusal to engage in unlawful conduct. Civil-pathway victimisation parallel to SDA s.47A, ADA s.47A, RDA s.18AA.	Applicable	Full	GOV-POL-009 §Policy Commitments — Commitment 4 (protection of complainants and witnesses from victimisation) covers victimisation across all federal anti-discrimination Acts.
DDA-122-01	DDA s.122 + s.123	Accessorial and vicarious liability — DDA has two related liability provisions. s.122 'Liability of persons involved in unlawful acts': a person who causes, instructs, induces, aids or permits another to do an unlawful act under the DDA is taken also to have done the act (accessorial liability; no all-reasonable-steps defence). s.123 'Conduct by directors, employees and agents': attributes the conduct of directors, employees or agents to the body corporate where the conduct was within actual or apparent authority — vicarious-liability mechanism. The reasonable-steps defence pathway is engaged through the broader DDA framework rather than a single subsection.	Applicable	Partial	GOV-POL-009 §Responsibilities — Responsibilities table cascade establishes supervisory layer engaged in prevention — supports vicarious-liability defence; managers/supervisors operationalise non-toleration duty to avoid accessorial liability.	Medium GOV-POL-009 does not separately address DDA accessorial liability or vicarious liability defence. Same gap pattern as RDA-18A-01 and the SDA s.105/s.106 noted in Framework 3 — supervisor training materials should flag personal accessorial liability.
AHRCA-46P-01	AHRC Act 1986 (Cth) Part IIB s.46P	Lodging a complaint — a written complaint may be lodged with the AHRC alleging unlawful discrimination under SDA, ADA, RDA or DDA. Complaint may be lodged by an aggrieved person, by a person on behalf of one or more aggrieved persons, or by a trade union. AHRC is the single federal entry point for unlawful discrimination complaints across the four anti-discrimination Acts.	Applicable	Full	GOV-POL-009 §Policy Commitments — Closing paragraph expressly notes workers may lodge a complaint with the Australian Human Rights Commission as an external pathway.
AHRCA-46PF-01	AHRC Act 1986 (Cth) Part IIB s.46PF	Inquiry by President — the President of the AHRC must inquire into a complaint lodged under s.46P, including by attempting conciliation between parties. Inquiry powers include obtaining information and documents, and convening compulsory conferences. Conciliation is a structured process that may resolve the matter without formal determination.	Reference only	Referenced-only	GOV-POL-009 §Policy Commitments — Reference row — process is AHRC's, not a duty on Westlink. Captures Westlink's awareness that an inquiry/conciliation pathway exists once a worker has lodged a complaint.	Reference-only row. Westlink's duty is to respond cooperatively to AHRC information requests and to attend conciliation in good faith if convened — operational responsibility rather than policy commitment. No coverage rating applies.
AHRCA-46PH-01	AHRC Act 1986 (Cth) Part IIB s.46PH	Termination of complaint — the President may terminate a complaint on specified grounds including: complaint is trivial, vexatious, misconceived or lacking in substance; subject matter already adequately dealt with; another more appropriate remedy is available; conciliation is no longer reasonable; or the complaint was lodged more than 24 months after the alleged unlawful conduct (24-month time limit standardised across all four anti-discrimination Acts by the Anti-Discrimination and Human Rights Legislation Amendment (Respect at Work) Act 2022).	Applicable	Full	GOV-POL-009 §Policy Commitments — Awareness of the 24-month limit informs how promptly internal grievance pathways must be communicated to workers; GOV-POL-011 grievance procedure addresses internal timeliness.
AHRCA-46PO-01	AHRC Act 1986 (Cth) Part IIB s.46PO	Application to court — where the President terminates a complaint, the complainant (or another affected person) may apply to the Federal Court or Federal Circuit and Family Court for a determination of the alleged unlawful discrimination. The court may make any orders it sees fit including damages, declarations and injunctions.	Applicable	Full	GOV-POL-009 §Policy Commitments — Closing paragraph notes external complaint pathway covers AHRC and FWC — workers' right to escalate to court via the AHRC pathway is implicit in the AHRC reference.
EOA-WA-Pt-II-01	EOA-WA Part II + s.11	Discrimination on the ground of sex, marital status, pregnancy or breast-feeding (Part II) — it is unlawful to discriminate on any of these grounds in employment (s.11 Discrimination in employment) and parallel contexts (commission agents, contract workers, partnerships, qualifying bodies, education, accommodation, goods and services). Direct and indirect discrimination both covered. Operates concurrently with Cth SDA — concurrent jurisdiction with double-recovery limits.	Applicable	Full	GOV-POL-009 §Policy Commitments — Protected-attributes paragraph expressly lists sex, marital status, pregnancy; family responsibility/carer's responsibilities also listed. Breastfeeding implicit in pregnancy coverage. GOV-POL-006 §Definitions — Definition — discrimination (protected attributes)
EOA-WA-Pt-IIAA-01	EOA-WA Part IIAA	Discrimination on the ground of gender history — it is unlawful to discriminate against a person on the basis of gender history (the WA term for transgender history). Captures persons identified as belonging to a gender opposite to their designated sex at birth and persons whose appearance has been altered to reflect gender identity. Employment and parallel-context prohibitions mirror Part II structure.	Applicable	Full	GOV-POL-009 §Policy Commitments — Protected-attributes paragraph expressly lists gender identity — captures the gender-history equivalent. GOV-POL-006 §Definitions — Definition — discrimination (protected attributes)
EOA-WA-Pt-IIA-01	EOA-WA Part IIA	Discrimination on the ground of family responsibility or family status — it is unlawful to discriminate in employment and parallel contexts on the basis of family responsibility (responsibilities to care for or support immediate family, including dependents) or family status (current/previous/proposed family relationship). Broader than SDA s.7A (which covers family responsibilities in dismissal contexts only).	Applicable	Full	GOV-POL-009 §Policy Commitments — Protected-attributes paragraph expressly lists family or carer's responsibilities — covers both family responsibility and family status grounds. GOV-POL-006 §Definitions — Definition — discrimination (protected attributes)
EOA-WA-Pt-IIB-01	EOA-WA Part IIB	Discrimination on the ground of sexual orientation — it is unlawful to discriminate in employment and parallel contexts on the basis of sexual orientation. WA Act prohibits same conduct as SDA s.5A; concurrent jurisdiction applies.	Applicable	Full	GOV-POL-009 §Policy Commitments — Protected-attributes paragraph expressly lists sexual orientation. GOV-POL-006 §Definitions — Definition — discrimination (protected attributes)
EOA-WA-Pt-III-01	EOA-WA Part III	Discrimination on the ground of race — it is unlawful to discriminate in employment and parallel contexts on the basis of race. WA prohibition is concurrent with RDA s.10 + s.15. Includes racial harassment in workplace conduct.	Applicable	Full	GOV-POL-009 §Policy Commitments — Protected-attributes paragraph expressly lists race, colour, national extraction, ethnic origin, social origin — covers EOA-WA race ground. GOV-POL-006 §Definitions — Definition — discrimination (protected attributes)
EOA-WA-Pt-IV-01	EOA-WA Part IV	Discrimination on the ground of religious or political conviction — it is unlawful to discriminate in employment and parallel contexts on the basis of religious belief, religious activity, political conviction, or political activity. WA-specific (no Cth equivalent in the four federal anti-discrimination Acts — Fair Work Act Part 3-1 provides parallel protections at federal level via adverse-action provisions).	Applicable	Full	GOV-POL-009 §Policy Commitments — Protected-attributes paragraph expressly lists religious belief or activity, political opinion, or trade union membership. GOV-POL-006 §Definitions — Definition — discrimination (protected attributes)
EOA-WA-Pt-IVA-01	EOA-WA Part IVA	Discrimination on the ground of impairment — it is unlawful to discriminate in employment and parallel contexts on the basis of impairment (covers physical, intellectual, psychiatric, sensory, neurological impairments and presence of disease-causing organisms; covers past, present and imputed impairment). WA equivalent of DDA s.5/s.6 disability discrimination; reasonable-adjustment obligation mirrors DDA structure.	Applicable	Full	GOV-POL-009 §Policy Commitments — Protected-attributes paragraph expressly lists physical or mental disability (past, present, or imputed) — covers WA impairment ground. Commitment 3 (reasonable adjustments) applies. GOV-POL-006 §Definitions — Definition — discrimination (protected attributes)
EOA-WA-Pt-IVB-01	EOA-WA Part IVB	Discrimination on the ground of age — it is unlawful to discriminate in employment and parallel contexts on the basis of age. WA prohibition runs concurrently with ADA — concurrent-jurisdiction provisions apply.	Applicable	Full	GOV-POL-009 §Policy Commitments — Protected-attributes paragraph expressly lists age. GOV-POL-006 §Definitions — Definition — discrimination (protected attributes)
EOA-WA-67-01	EOA-WA s.67	Victimisation — it is unlawful to subject or threaten to subject another person to any detriment because they have made or proposed to make a complaint under the EOA-WA, given evidence/information, alleged a contravention, or otherwise asserted rights under the Act. WA-specific victimisation provision; civil-unlawful conduct. Parallels SDA s.47A, ADA s.47A, RDA s.18AA, DDA s.58A federally.	Applicable	Full	GOV-POL-009 §Policy Commitments — Commitment 4 (protecting complainants and witnesses from victimisation) covers EOA-WA victimisation. GOV-POL-006 §Policy Commitments — Commitment — disciplinary action and victimisation protection
EOA-WA-161-01	EOA-WA s.161	Vicarious liability — an act done by an employee or agent in connection with their employment or agency is, for the purposes of the Act, taken to have been done by the employer or principal as well. Defence: employer/principal proves it took such steps as were reasonably practicable to prevent the contravention. WA parallel to the various federal vicarious-liability provisions.	Applicable	Partial	GOV-POL-009 §Policy Commitments — Commitment 5 (worker awareness through induction and refresher training) provides foundation of 'reasonably practicable steps' evidence. GOV-POL-009 §Responsibilities — Responsibilities table cascade evidences supervisory layer engaged in prevention.	Medium WA EOA reasonable-steps defence operates on slightly different language ('reasonably practicable' vs federal 'all reasonable steps') but is operationally equivalent. Same gap pattern as the federal vicarious-liability rows — explicit cross-reference between policy commitments and the s.161 defence framework would strengthen audit defensibility.

Source document

Cth + WA anti-discrimination — Sex Discrimination Act (non-harassment), Age, Racial and Disability Discrimination Acts, AHRC Act complaints framework, Equal Opportunity Act 1984 (WA)

43 normative shall-statements extracted from Anti-Discrimination — Sex/Age/Race/Disability Discrimination Acts (Cth) + AHRC Act complaints + Equal Opportunity Act 1984 (WA) (source: Sex Discrimination Act 1984 (Cth) current FRL compilation (C2004A02868); Age Discrimination Act 2004 (Cth) current compilation (C2004A01302); Racial Discrimination Act 1975 (Cth) current compilation (C2004A00274); Disability Discrimination Act 1992 (Cth) current compilation (C2004A04426); Australian Human Rights Commission Act 1986 (Cth) current compilation (C2004A03366); Equal Opportunity Act 1984 (WA) current consolidated text (legislation.wa.gov.au)). The frontmatter requirements array is the source of truth — this body is rendered by scripts/render_compliance.py.

Coverage summary

Coverage	Count
✅ Full	32
🟡 Partial	10
🟠 Ref-only	1
🔴 Gap	0
— N/A	0

Gap severity distribution

Severity	Count
🔴 Critical	0
🟠 High	0
🟡 Medium	5
🟢 Low	5

Requirements

Clause ADA s

ID	Coverage	Evidence	Gap	Notes
ADA-14-01	✅ Full	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments)
ADA-15-01	🟡 Partial	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments)	🟡 Medium	Indirect discrimination (an unreasonable condition with disparate impact) is not explicitly addressed; the merit / genuine-occupational-requirement commitment only implicitly engages the reasonableness test.
ADA-18-01	✅ Full	GOV-POL-009 §Scope [GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments)
ADA-47A-01	✅ Full	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments)
ADA-56-01	🟡 Partial	GOV-POL-009 §Responsibilities	🟢 Low	GOV-POL-009 does not explicitly flag personal-liability consequences for supervisors who turn a blind eye to age discrimination (cf. parallel concern for SDA s.105 in Framework 3). Consider adding to manager training material that toleration of discriminatory conduct attracts personal accessorial liability across all federal anti-discrimination Acts.

Clause AHRC Act 1986 (Cth) Part IIB s

ID	Coverage	Evidence	Notes
AHRCA-46P-01	✅ Full	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments)
AHRCA-46PF-01	🟠 Ref-only	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments)	Reference-only row. Westlink’s duty is to respond cooperatively to AHRC information requests and to attend conciliation in good faith if convened — operational responsibility rather than policy commitment. No coverage rating applies.
AHRCA-46PH-01	✅ Full	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments)
AHRCA-46PO-01	✅ Full	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments)

Clause DDA s

ID	Coverage	Evidence	Gap	Notes
DDA-5-01	✅ Full	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments) [GOV-POL-010 §Policy Commitments](/wms/GOV-POL-010#sPolicy Commitments)
DDA-6-01	✅ Full	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments)
DDA-11-01	🟡 Partial	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments)	🟡 Medium	GOV-POL-009 references unjustifiable hardship at policy level but does not document the decision-making framework for unjustifiable-hardship determinations (factors weighing, sign-off authority, record-keeping). Consider documenting this in a reasonable-adjustments procedure cross-referenced from the policy.
DDA-15-01	✅ Full	GOV-POL-009 §Scope [GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments)
DDA-58A-01	✅ Full	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments)
DDA-122-01	🟡 Partial	GOV-POL-009 §Responsibilities	🟡 Medium	GOV-POL-009 does not separately address DDA accessorial liability or vicarious liability defence. Same gap pattern as RDA-18A-01 and the SDA s.105/s.106 noted in Framework 3 — supervisor training materials should flag personal accessorial liability.

Clause EOA-WA Part II + s

ID	Coverage	Evidence	Gap	Notes
EOA-WA-Pt-II-01	✅ Full	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments) GOV-POL-006 §Definitions

Clause EOA-WA Part IIA

ID	Coverage	Evidence	Gap	Notes
EOA-WA-Pt-IIA-01	✅ Full	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments) GOV-POL-006 §Definitions

Clause EOA-WA Part IIAA

ID	Coverage	Evidence	Gap	Notes
EOA-WA-Pt-IIAA-01	✅ Full	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments) GOV-POL-006 §Definitions

Clause EOA-WA Part IIB

ID	Coverage	Evidence	Gap	Notes
EOA-WA-Pt-IIB-01	✅ Full	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments) GOV-POL-006 §Definitions

Clause EOA-WA Part III

ID	Coverage	Evidence	Gap	Notes
EOA-WA-Pt-III-01	✅ Full	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments) GOV-POL-006 §Definitions

Clause EOA-WA Part IV

ID	Coverage	Evidence	Gap	Notes
EOA-WA-Pt-IV-01	✅ Full	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments) GOV-POL-006 §Definitions

Clause EOA-WA Part IVA

ID	Coverage	Evidence	Gap	Notes
EOA-WA-Pt-IVA-01	✅ Full	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments) GOV-POL-006 §Definitions

Clause EOA-WA Part IVB

ID	Coverage	Evidence	Gap	Notes
EOA-WA-Pt-IVB-01	✅ Full	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments) GOV-POL-006 §Definitions

Clause EOA-WA s

ID	Coverage	Evidence	Gap	Notes
EOA-WA-67-01	✅ Full	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments) [GOV-POL-006 §Policy Commitments](/wms/GOV-POL-006#sPolicy Commitments)
EOA-WA-161-01	🟡 Partial	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments) GOV-POL-009 §Responsibilities	🟡 Medium	WA EOA reasonable-steps defence operates on slightly different language (‘reasonably practicable’ vs federal ‘all reasonable steps’) but is operationally equivalent. Same gap pattern as the federal vicarious-liability rows — explicit cross-reference between policy commitments and the s.161 defence framework would strengthen audit defensibility.

Clause RDA s

ID	Coverage	Evidence	Gap	Notes
RDA-10-01	✅ Full	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments)
RDA-15-01	✅ Full	GOV-POL-009 §Scope [GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments)
RDA-18C-01	🟡 Partial	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments) GOV-POL-006	🟢 Low	GOV-POL-009 does not separately address racial vilification under s.18C; coverage relies on the cross-reference to GOV-POL-006 Workplace Behaviour Policy. Consider adding an explicit note in GOV-POL-009’s protected-attributes paragraph that race-based offensive behaviour is unlawful under s.18C and is addressed through GOV-POL-006.
RDA-18AA-01	✅ Full	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments)
RDA-18A-01	🟡 Partial	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments) GOV-POL-009 §Responsibilities	🟡 Medium	GOV-POL-009 does not explicitly identify itself as evidence supporting an RDA ‘all reasonable steps’ defence under s.18A/s.18E. For vicarious-liability audit defensibility, the policy + training records package should be cross-referenced explicitly. Same gap applies across all four federal anti-discrimination Acts.

Clause SDA s

ID	Coverage	Evidence	Gap	Notes
SDA-5-01	✅ Full	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments)
SDA-5A-01	✅ Full	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments)
SDA-5B-01	✅ Full	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments)
SDA-5C-01	✅ Full	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments)
SDA-6-01	✅ Full	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments)
SDA-7-01	✅ Full	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments)
SDA-7AA-01	🟡 Partial	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments)	🟢 Low	GOV-POL-009 protected-attributes paragraph does not separately name breastfeeding — consider explicit inclusion alongside pregnancy and family responsibilities in the next minor revision to remove ambiguity. Operational practicalities (lactation breaks, suitable space, refrigeration for stored milk) sit at procedure level.
SDA-7A-01	✅ Full	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments)
SDA-8A-01	🟡 Partial	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments) [GOV-POL-014 §Organisational Context](/wms/GOV-POL-014#sOrganisational Context)	🟢 Low	Neither GOV-POL-009 nor GOV-POL-014 explicitly addresses the s.8A multi-attribute hostile-environment ground (e.g., a workplace hostile to a person on the basis of both sex AND sexual orientation). Consider adding a note in GOV-POL-014’s hostile-environment commentary or GOV-POL-009’s protected-attributes paragraph that hostile-environment risk is assessed cumulatively across multiple protected attributes.
SDA-14-01	✅ Full	GOV-POL-009 §Scope [GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments)
SDA-15-01	🟡 Partial	GOV-POL-009 §Scope	🟢 Low	Commission-agent arrangements are uncommon at Westlink (typical engagements are employees, labour-hire workers, or contract workers); s.15 is captured for completeness but practical exposure is low. No remediation required unless Westlink’s business model shifts to use commission agents.
SDA-16-01	✅ Full	GOV-POL-009 §Scope
SDA-47A-01	✅ Full	[GOV-POL-009 §Policy Commitments](/wms/GOV-POL-009#sPolicy Commitments) [GOV-POL-014 §Policy Commitments](/wms/GOV-POL-014#sPolicy Commitments)

Rendered from frontmatter by scripts/render_compliance.py. Source extraction: scripts/extract_iso9001_requirements.py. Evidence population: scripts/populate_iso9001_evidence.py. Validate: scripts/compliance_validate.py.