Sex Discrimination Act 1984 (Cth) — Positive Duty + AHRC Seven Standards

Sex Discrimination Act 1984 — workplace sexual harassment, sex-based harassment, hostile environment, positive duty (s.47C) and AHRC Seven Standards

Requirements: 18
Last reviewed: 21/05/2026
Next review: 21/05/2027
Source: SDA current Federal Register compilation at 2026-05-21. No amendments to ss 28A, 28AA, 28B, 28M, 47C, 94, 105 or 106 verified in 2024-2026. AHRC Guidelines: 2023 first edition (unchanged through 2026). AHRC Compliance and Enforcement Policy: 4 December 2025.

Reconciliation notes

Curated build covering the Sex Discrimination Act 1984 (Cth) workplace harassment regime (Part II Division 3 ss 28A-28M) and the positive duty regime (Part IIA s.47C), together with the AHRC's Seven Standards from the 2023 Guidelines for Complying with the Positive Duty. AHRC compliance and enforcement powers under the AHRC Act 1986 commenced on 12 December 2023 — the duty has had 'teeth' since that date, with powers to inquire, make findings, issue compliance notices enforceable in federal court, and enter into enforceable undertakings. Scope decisions: (a) Westlink is an employer / PCBU, not a partnership, educational institution, accommodation/services provider, qualifying body or Commonwealth law administrator — s.28C through s.28L non-work contexts therefore omitted (not Applicable; not separately captured as rows to avoid noise); (b) s.28B captured as the comprehensive workplace prohibition (the section covers employer/employee, commission agent/principal, contract worker/principal, partnership relationships); (c) the positive duty in s.47C is decomposed into three rows — s.47C(1) duty, s.47C(2) the six categories of measures that must be addressed, and s.47C(6) the 'reasonable and proportionate' factors — because each is a distinct audit anchor with different evidence demands; (d) AHRC Seven Standards captured as 7 normative rows per AHRC's own audit framework (treated as separately auditable in compliance reviews); sub-actions and indicators not separately decomposed (deferred unless a later audit-readiness review demands finer granularity); (e) note that candidate-frameworks.md originally cited s.105 as 'vicarious liability' — verification revealed s.105 is accessorial liability (no 'all reasonable steps' defence) and s.106 is the vicarious liability provision (with 'all reasonable steps' defence in s.106(2)); both captured here. Primary anchor policy: GOV-POL-014 (Sexual Harassment Prevention) — directly structured around the seven AHRC standards. Secondary anchor: GOV-POL-009 (Equal Employment Opportunity) — for s.47C extension beyond sexual harassment to all sex discrimination. Cross-references to ISO 45001 cl.6.1.2 psychosocial risk, cl.5.4 consultation, and cl.7.3 awareness retained in evidence notes rather than as separate requirements (existing iso-45001-2018.md framework owns those clause anchors). Total requirements: 18. Applicable: 17. Reference only: 1 (AHRC Enforcement Policy as regulator's published approach). Coverage on applicable rows pending Phase C wiring of GOV-POL-014 and GOV-POL-009 — captured here against current GOV-POL-014 rev 3 commitments to give a defensible baseline.

Requirements

Showing 18 of 18 requirements

ID	Clause	Requirement	Applicability	Coverage	Evidence	Gap
SDA-28A-01	SDA s.28A	Sexual harassment is defined as: a person makes an unwelcome sexual advance, an unwelcome request for sexual favours, or engages in other unwelcome conduct of a sexual nature in relation to another person, in circumstances in which a reasonable person, having regard to all the circumstances, would have anticipated the possibility that the second person would be offended, humiliated or intimidated. 'Conduct of a sexual nature' includes physical intimacy, statements of a sexual nature made in the person's presence, and other conduct of a sexual nature directed at the person.	Applicable	Full	GOV-POL-014 §Purpose — Policy adopts statutory definitions by reference (commitment to a workplace free from sexual harassment 'as defined by the SDA'); zero-tolerance language operationalises the s.28A test. GOV-POL-006 §Definitions — Definition — sexual harassment
SDA-28AA-01	SDA s.28AA	Sex-based harassment is defined as: a person subjects another person to unwelcome conduct of a demeaning nature in relation to the second person, because of the second person's sex (or a characteristic that appertains or is generally imputed to persons of that sex), in circumstances in which a reasonable person would have anticipated the possibility of offence, humiliation or intimidation. Inserted by the Sex Discrimination and Fair Work (Respect at Work) Amendment Act 2021; threshold lowered by the Anti-Discrimination and Human Rights Legislation Amendment (Respect at Work) Act 2022 (removed 'seriously' from 'demeaning').	Applicable	Partial	GOV-POL-014 §Policy Commitments — Zero-tolerance commitment expressly covers sexual harassment 'in any form' — captures sex-based harassment without requiring sexual-nature conduct; respectful-behaviour expectations in Commitment 2 (Culture) directly address the demeaning-conduct standard.	Medium Zero-tolerance 'in any form' and the respectful-behaviour commitment notionally capture sex-based harassment, but the s.28AA demeaning-conduct-because-of-sex definition is not stated in the body.
SDA-28B-01	SDA s.28B	It is unlawful for an employer to sexually harass an employee or a person seeking employment; for an employee to sexually harass a fellow employee or job applicant of the same employer; for a commission agent or contract worker (or person seeking such status) to sexually harass another commission agent, contract worker, employee or job applicant of the same principal; and for a partner in a partnership to sexually harass another partner or applicant. The s.28A definition applies. This is the operative workplace prohibition.	Applicable	Full	GOV-POL-014 §Scope — Policy expressly extends to directors, workers, contractors, labour hire workers, volunteers and visitors — covers each relationship class within s.28B. GOV-POL-014 §Policy Commitments — Commitment 6 (Reporting and Response) commits to multiple accessible reporting channels, prompt and impartial investigation, and consequences up to termination — gives effect to the unlawful-conduct prohibition operationally.
SDA-28M-01	SDA s.28M	A person must not, in a workplace, subject another person to a workplace environment that is hostile on the ground of sex. Conduct in a workplace is unlawful where it subjects another person to a hostile workplace environment on the ground of sex and a reasonable person would have anticipated the possibility of an environment in which a person of the second person's sex would be offended, humiliated or intimidated. Factors include sex of people in the workplace, nature and seriousness of the conduct, whether the conduct was continuous or repetitive, and the role/influence/authority of the person engaging in the conduct. Inserted by the Anti-Discrimination and Human Rights Legislation Amendment (Respect at Work) Act 2022.	Applicable	Partial	GOV-POL-014 §Organisational Context — Policy identifies male-dominated operational settings, isolated/remote environments, and alcohol at work events as elevated risk factors per AHRC guidance — directly addresses hostile-environment risk factors at the organisational-context level. GOV-POL-014 §Policy Commitments — Commitment 4 (Risk Management) commits to assessing workforce demographics, power imbalances, isolated work environments and alcohol risk factors.	Low Hostile workplace environment is a separate unlawful-conduct ground introduced by Respect@Work; GOV-POL-014 addresses the underlying risk factors but does not explicitly name 'hostile workplace environment on the ground of sex' as a standalone form of unlawful conduct. Consider adding an explicit reference to s.28M in the policy Purpose statement and to the Policy Commitments preamble alongside the existing s.47C reference, so that hostile-environment and harassment are visibly distinguished.
SDA-47C-01	SDA s.47C(1)	A person conducting a business or undertaking (PCBU) must take reasonable and proportionate measures to eliminate, as far as possible: (a) sex discrimination in a work context; (b) sexual harassment in connection with work (s.28B and related provisions); (c) sex-based harassment in connection with work (s.28AA and related provisions); (d) conduct creating a hostile workplace environment on the ground of sex (s.28M); and (e) acts of victimisation under the Act. The duty extends to workers and to other persons at the place where work is carried out or who may otherwise be affected by the work (clients, customers, visitors).	Applicable	Full	GOV-POL-014 §Purpose — Policy Purpose expressly gives effect to s.47C and commits Westlink to take reasonable and proportionate measures to eliminate sexual harassment, sex discrimination and related unlawful conduct as far as possible. GOV-POL-014 §Scope — Scope extends to all workers, contractors, labour hire, volunteers and visitors and to all work-related settings (offices, sites, vehicles, client premises, work travel, social functions and digital communications) — covers s.47C's worker and 'other persons affected' scope. GOV-POL-006 §Policy Commitments — Commitment — positive duty re sexual harassment
SDA-47C-02	SDA s.47C(2)	Reasonable and proportionate measures under s.47C(1) must address (without limitation): (a) prevention of the relevant unlawful conduct; (b) coordination, monitoring and review of the implementation and effectiveness of preventative measures; (c) measures fostering a culture that does not tolerate the relevant unlawful conduct, and measures ensuring workers and others are aware of rights and obligations; (d) support for people who experience or witness the relevant conduct; (e) complaint-handling and reporting processes ensuring complaints are dealt with in a fair, timely and effective way; and (f) measures ensuring appropriate consequences or corrective action if the relevant conduct occurs or if there is a failure to comply with prevention policies or procedures.	Applicable	Full	GOV-POL-014 §Policy Commitments — Policy commitments are structured around the seven AHRC Standards which operationalise the s.47C(2) categories: Leadership + Culture (47C(2)(c)), Knowledge (47C(2)(c)), Risk Management (47C(2)(a) prevention), Support (47C(2)(d)), Reporting and Response (47C(2)(e)), Monitoring and Evaluation (47C(2)(b) coordination/review). Accountability and consequences (47C(2)(f)) addressed via Reporting and Response commitment ('substantiated complaints result in appropriate action up to and including termination') and the Responsibilities table. GOV-POL-014 §Responsibilities — Three-column responsibilities table assigns CEO, QHSE Manager, Managers/Supervisors and All Workers/Contractors with discrete obligations covering each s.47C(2) category. GOV-POL-006 §Policy Commitments — Commitment — positive duty re sexual harassment
SDA-47C-03	SDA s.47C(6)	Whether measures are 'reasonable and proportionate' is assessed taking into account all relevant circumstances, including (non-exhaustively): (a) the size, nature and circumstances of the PCBU's business or undertaking; (b) the PCBU's resources; (c) the practicability and cost of the measures; (d) the likelihood that the relevant unlawful conduct might occur; (e) the nature and extent of the potential harm that could result; and (f) any other relevant matters. These factors guide what is reasonable and proportionate for that particular organisation.	Applicable	Partial	GOV-POL-014 §Organisational Context — Organisational Context section identifies operational scale (heavy haulage, project logistics, maritime services across Australia), workforce profile (workers in isolated/remote environments, vessels, male-dominated operational settings) and elevated-risk factors — provides the size, nature, likelihood and potential-harm context to which 'reasonable and proportionate' is calibrated.	Medium GOV-POL-014 establishes the contextual factors but does not contain an explicit reasonable-and-proportionate justification record (e.g., a documented assessment that the chosen measures are calibrated to Westlink's size, resources and risk profile). For audit defensibility, consider maintaining a positive-duty action plan or annual self-assessment document that explicitly addresses each s.47C(6) factor; AHRC's 2023 Guidelines and 2025 Enforcement Policy both contemplate this as evidence of compliance.
SDA-94-01	SDA s.94	A person must not subject, or threaten to subject, another person to any detriment because the other person has made or proposes to make a complaint (under the SDA, the AHRC Act 1986 or related anti-discrimination laws), brought or proposes to bring proceedings, given or proposes to give evidence or information in such proceedings, asserted rights under the Act, or refused to do something that would be unlawful — or because the first person believes the other person has done or may do any of those things. Victimisation is a criminal offence and unlawful for the purposes of the SDA and AHRC Act 1986 (civil complaint pathway).	Applicable	Full	GOV-POL-014 §Policy Commitments — Closing paragraph of Policy Commitments expressly prohibits victimisation or reprisal against any person who makes a complaint, provides information or is involved in a complaint process — names this as a separate breach of policy and the Sex Discrimination Act.
SDA-105-01	SDA s.105	A person who causes, instructs, induces, aids or permits another person to do an act that is unlawful under SDA Part II Divisions 1, 2 or 3 (sex discrimination, sexual harassment, sex-based harassment, hostile workplace environment) is taken, for the purposes of the Act, to have done the act themselves. Accessorial liability extends responsibility to managers, supervisors, colleagues or third parties who knowingly assist or allow unlawful discriminatory conduct. No 'all reasonable steps' defence (that defence sits in s.106 vicarious liability).	Applicable	Partial	GOV-POL-014 §Responsibilities — Managers and Supervisors row obliges them to model respectful behaviour, respond promptly to reports, ensure team training, and escalate appropriately — operationalises the duty not to instruct, induce, aid or permit unlawful conduct.	Low GOV-POL-014 obliges managers and supervisors to respond and escalate but does not explicitly state that turning a blind eye to or tolerating unlawful conduct attracts personal liability under s.105 accessorial liability. For supervisor training and policy reinforcement, consider adding a sentence to the Responsibilities table notes flagging the personal-liability consequence.
SDA-106-01	SDA s.106	If an employee or agent does an act in connection with their employment or agency that would be unlawful under SDA Part II Divisions 1, 2 or 3, the employer/principal is also taken to have done the act — s.106(1). The employer/principal is not liable if it proves it took all reasonable steps to prevent the employee or agent from doing the act or acts of that kind — s.106(2). 'All reasonable steps' is the statutory defence; in practice, evidence of an effective positive-duty action plan (s.47C compliance) supports the s.106(2) defence.	Applicable	Partial	GOV-POL-014 §Policy Commitments — The seven-standard positive-duty action plan structured into the Policy Commitments is the substantive 'all reasonable steps' evidence — leadership, culture, knowledge (training), risk management, support, reporting/response, monitoring. Treated as the PCBU's reasonable-and-proportionate measures under s.47C, which simultaneously supports the s.106(2) defence. GOV-POL-014 §Responsibilities — Responsibilities table operationalises positive duty across CEO, QHSE Manager, Managers/Supervisors and All Workers — evidence of supervisory layer engaged in prevention.	Medium GOV-POL-014 does not explicitly identify itself as evidence supporting a s.106(2) all-reasonable-steps defence. For audit defensibility, the positive-duty action plan (s.47C) should be cross-referenced to s.106(2) — for example via an addendum or in the policy Review section noting that the action plan is the organisation's record of reasonable steps for vicarious liability purposes.
AHRC-PD-01	AHRC Guidelines for Complying with the Positive Duty (2023) — Standard 1 Leadership	Leadership — senior leaders are responsible for compliance with the positive duty. They understand their obligations, ensure measures are developed, implemented, monitored and continuously improved, and are publicly committed to safe, respectful and inclusive workplaces. Leaders set expectations, allocate adequate resources and hold themselves and others accountable.	Applicable	Full	GOV-POL-014 §Policy Commitments — Commitment 1 (Leadership) — CEO and senior managers set behavioural expectations, allocate resources, hold themselves accountable for positive duty compliance. GOV-POL-014 §Responsibilities — CEO row: accountable for the policy and positive duty compliance; allocates resources for prevention; sets leadership example.
AHRC-PD-02	AHRC Guidelines for Complying with the Positive Duty (2023) — Standard 2 Culture	Culture — workplaces foster a culture that is safe, respectful and inclusive, that values diversity and gender equality, and where everyone knows and understands their rights and responsibilities. Power imbalances are addressed and behavioural expectations communicated and reinforced.	Applicable	Full	GOV-POL-014 §Policy Commitments — Commitment 2 (Culture) — fosters culture of respect, safety and inclusion where sexual harassment is not tolerated; workers expected to model respectful behaviour and challenge inappropriate conduct.
AHRC-PD-03	AHRC Guidelines for Complying with the Positive Duty (2023) — Standard 3 Knowledge	Knowledge — duty holders develop, communicate and implement a policy on respectful behaviour and on the prohibited unlawful conduct, and provide training and ongoing communication so workers understand expected behaviour, can identify unlawful conduct, and know how to report and respond. Training is targeted to roles (workers, managers, leaders).	Applicable	Partial	GOV-POL-014 §Policy Commitments — Commitment 3 (Knowledge) — all workers and contractors receive training at induction and through regular refresher programs covering identification of unlawful conduct, bystander intervention and reporting channels. GOV-POL-014 §Review — Policy communicated to all workers at induction and available on the WMS.	Medium GOV-POL-014 commits to induction and refresher training but does not specify frequency, target audiences (worker vs manager vs leader), or training content standard. AHRC's guidance distinguishes role-targeted training as a positive-duty standard. Consider documenting the training programme (frequency, audience, content) in a procedure cross-referenced from the policy, or in the training register.
AHRC-PD-04	AHRC Guidelines for Complying with the Positive Duty (2023) — Standard 4 Risk management	Risk management — duty holders recognise that the unlawful conduct is a workplace health and safety risk and take a risk-based approach to its prevention. Identify and assess risks of the unlawful conduct occurring, taking into account factors such as power imbalances, workforce demographics, alcohol at work, customer/client behaviour, isolated work and after-hours work. Implement and review controls; integrate into the WHS management system.	Applicable	Full	GOV-POL-014 §Policy Commitments — Commitment 4 (Risk Management) — risks identified, assessed and controlled through WMS risk framework; risk factors including power imbalances, isolated work environments, alcohol at work events and workforce demographics are evaluated and mitigated. GOV-POL-014 §Organisational Context — Operational risk profile expressly captured (isolated/remote environments, vessels, male-dominated settings) — driving the risk-based approach. QHSE-MAN-001 §6.1.2 — Sexual harassment and sex-based harassment treated as psychosocial hazards under the WMS, integrated into the WHS risk assessment process (ISO 45001 cl.6.1.2 anchor).
AHRC-PD-05	AHRC Guidelines for Complying with the Positive Duty (2023) — Standard 5 Support	Support — duty holders ensure appropriate support is available to workers and others who experience or witness the relevant unlawful conduct, including support that is independent of whether the person makes a formal complaint. Support may include access to employee assistance programs, time off, reasonable workplace adjustments, and external referral pathways.	Applicable	Full	GOV-POL-014 §Policy Commitments — Commitment 5 (Support) — appropriate support including access to Employee Assistance Program, reasonable workplace adjustments, and referral to external services, regardless of whether a formal complaint is made.
AHRC-PD-06	AHRC Guidelines for Complying with the Positive Duty (2023) — Standard 6 Reporting and response	Reporting and response — duty holders ensure there are appropriate reporting options (formal and informal, multiple and accessible) and respond to reports in a way that is consistent, timely, fair, transparent and supports the person who has been harmed. Responses are trauma-informed and consider the safety of all parties. Outcomes are communicated and the policy is enforced through proportionate consequences.	Applicable	Partial	GOV-POL-014 §Policy Commitments — Commitment 6 (Reporting and Response) — multiple accessible reporting channels; reports treated confidentially and investigated promptly, impartially and with procedural fairness; substantiated complaints result in appropriate action up to termination.	Medium GOV-POL-014 commits to multiple accessible reporting channels but does not enumerate the channels (e.g., direct manager, QHSE Manager, CEO, anonymous channel, external regulator). AHRC guidance recommends explicit listing for accessibility. Consider augmenting the policy with a Reporting Channels appendix or table, or documenting the channels in a complaint-handling procedure. Also relevant: confirm timeframes for acknowledgement, investigation and outcome communication.
AHRC-PD-07	AHRC Guidelines for Complying with the Positive Duty (2023) — Standard 7 Monitoring and evaluation	Monitoring and evaluation — duty holders collect appropriate data on the prevalence, nature and outcomes of the relevant unlawful conduct, and use it to monitor and evaluate compliance with the positive duty. Data covers reports received, complaint outcomes, training participation and culture indicators. Findings are reported to leadership and inform continual improvement.	Applicable	Partial	GOV-POL-014 §Policy Commitments — Commitment 7 (Monitoring and Evaluation) — monitors effectiveness of prevention measures through data on reports, outcomes, training completion and workplace culture; findings reported to senior management and used to drive continual improvement. GOV-POL-014 §Review — Annual review against the seven AHRC standards as part of management review cycle, or after any sexual harassment complaint, legislative change or AHRC guidance update.	Medium GOV-POL-014 commits to data-driven monitoring but does not specify the data set, reporting cadence or evidence-of-evaluation record. AHRC Standard 7 contemplates documented monitoring (KPIs, dashboards, periodic review records). Consider adding a quarterly or annual positive-duty assurance report — input to QHSE-PRO-001 monitoring or to management review — capturing reports received, outcomes, training completion, and culture indicators.
AHRC-CEP-01	AHRC Positive Duty Compliance and Enforcement Policy (4 December 2025)	AHRC's published approach to monitoring and enforcing compliance with the positive duty under s.47C. AHRC has co-regulatory powers under the AHRC Act 1986 to: inquire into a duty holder's compliance with the positive duty; make findings of non-compliance; issue compliance notices; apply to federal courts to enforce compliance notices; and enter into enforceable undertakings with duty holders. Enforcement powers commenced 12 December 2023 (one year after the s.47C duty itself commenced on 12 December 2022).	Reference only	Referenced-only	GOV-POL-014 §Review — Policy review trigger includes 'update to AHRC guidance' — captures changes in AHRC's published compliance and enforcement approach.	Reference-only row. AHRC's enforcement powers are the regulator's mechanism, not a duty on Westlink — but the Enforcement Policy informs how Westlink should prepare its s.47C evidence trail (compliance notice timelines, enforceable undertaking content). No coverage rating applies; treat as awareness material informing the audit-readiness posture for s.47C-01 through SDA-47C-03 and AHRC-PD-01 through AHRC-PD-07.

Source document

Sex Discrimination Act 1984 — workplace sexual harassment, sex-based harassment, hostile environment, positive duty (s.47C) and AHRC Seven Standards

18 normative shall-statements extracted from Sex Discrimination Act 1984 (Cth) — Positive Duty + AHRC Seven Standards (source: Sex Discrimination Act 1984 (Cth) — current compilation on legislation.gov.au (incorporates Anti-Discrimination and Human Rights Legislation Amendment (Respect at Work) Act 2022); AHRC Guidelines for Complying with the Positive Duty under the Sex Discrimination Act 1984 (Cth) (2023); AHRC Positive Duty Compliance and Enforcement Policy (4 December 2025)). The frontmatter requirements array is the source of truth — this body is rendered by scripts/render_compliance.py.

Coverage summary

Coverage	Count
✅ Full	9
🟡 Partial	8
🟠 Ref-only	1
🔴 Gap	0
— N/A	0

Gap severity distribution

Severity	Count
🔴 Critical	0
🟠 High	0
🟡 Medium	6
🟢 Low	2

Requirements

Clause AHRC Guidelines for Complying with the Positive Duty (2023) — Standard 1 Leadership

ID	Coverage	Evidence	Gap	Notes
AHRC-PD-01	✅ Full	[GOV-POL-014 §Policy Commitments](/wms/GOV-POL-014#sPolicy Commitments) GOV-POL-014 §Responsibilities

Clause AHRC Guidelines for Complying with the Positive Duty (2023) — Standard 2 Culture

ID	Coverage	Evidence	Gap	Notes
AHRC-PD-02	✅ Full	[GOV-POL-014 §Policy Commitments](/wms/GOV-POL-014#sPolicy Commitments)

Clause AHRC Guidelines for Complying with the Positive Duty (2023) — Standard 3 Knowledge

ID	Coverage	Evidence	Gap	Notes
AHRC-PD-03	🟡 Partial	[GOV-POL-014 §Policy Commitments](/wms/GOV-POL-014#sPolicy Commitments) GOV-POL-014 §Review	🟡 Medium	GOV-POL-014 commits to induction and refresher training but does not specify frequency, target audiences (worker vs manager vs leader), or training content standard. AHRC’s guidance distinguishes role-targeted training as a positive-duty standard. Consider documenting the training programme (frequency, audience, content) in a procedure cross-referenced from the policy, or in the training register.

Clause AHRC Guidelines for Complying with the Positive Duty (2023) — Standard 4 Risk management

ID	Coverage	Evidence	Gap	Notes
AHRC-PD-04	✅ Full	[GOV-POL-014 §Policy Commitments](/wms/GOV-POL-014#sPolicy Commitments) [GOV-POL-014 §Organisational Context](/wms/GOV-POL-014#sOrganisational Context) QHSE-MAN-001 §‘6.1.2’

Clause AHRC Guidelines for Complying with the Positive Duty (2023) — Standard 5 Support

ID	Coverage	Evidence	Gap	Notes
AHRC-PD-05	✅ Full	[GOV-POL-014 §Policy Commitments](/wms/GOV-POL-014#sPolicy Commitments)

Clause AHRC Guidelines for Complying with the Positive Duty (2023) — Standard 6 Reporting and response

ID	Coverage	Evidence	Gap	Notes
AHRC-PD-06	🟡 Partial	[GOV-POL-014 §Policy Commitments](/wms/GOV-POL-014#sPolicy Commitments)	🟡 Medium	GOV-POL-014 commits to multiple accessible reporting channels but does not enumerate the channels (e.g., direct manager, QHSE Manager, CEO, anonymous channel, external regulator). AHRC guidance recommends explicit listing for accessibility. Consider augmenting the policy with a Reporting Channels appendix or table, or documenting the channels in a complaint-handling procedure. Also relevant: confirm timeframes for acknowledgement, investigation and outcome communication.

Clause AHRC Guidelines for Complying with the Positive Duty (2023) — Standard 7 Monitoring and evaluation

ID	Coverage	Evidence	Gap	Notes
AHRC-PD-07	🟡 Partial	[GOV-POL-014 §Policy Commitments](/wms/GOV-POL-014#sPolicy Commitments) GOV-POL-014 §Review	🟡 Medium	GOV-POL-014 commits to data-driven monitoring but does not specify the data set, reporting cadence or evidence-of-evaluation record. AHRC Standard 7 contemplates documented monitoring (KPIs, dashboards, periodic review records). Consider adding a quarterly or annual positive-duty assurance report — input to QHSE-PRO-001 monitoring or to management review — capturing reports received, outcomes, training completion, and culture indicators.

Clause AHRC Positive Duty Compliance and Enforcement Policy (4 December 2025)

ID	Coverage	Evidence	Gap	Notes
AHRC-CEP-01	🟠 Ref-only	GOV-POL-014 §Review		Reference-only row. AHRC’s enforcement powers are the regulator’s mechanism, not a duty on Westlink — but the Enforcement Policy informs how Westlink should prepare its s.47C evidence trail (compliance notice timelines, enforceable undertaking content). No coverage rating applies; treat as awareness material informing the audit-readiness posture for s.47C-01 through SDA-47C-03 and AHRC-PD-01 through AHRC-PD-07.

Clause SDA s

ID	Coverage	Evidence	Gap	Notes
SDA-28A-01	✅ Full	GOV-POL-014 §Purpose GOV-POL-006 §Definitions
SDA-28AA-01	🟡 Partial	[GOV-POL-014 §Policy Commitments](/wms/GOV-POL-014#sPolicy Commitments)	🟡 Medium	Zero-tolerance ‘in any form’ and the respectful-behaviour commitment notionally capture sex-based harassment, but the s.28AA demeaning-conduct-because-of-sex definition is not stated in the body.
SDA-28B-01	✅ Full	GOV-POL-014 §Scope [GOV-POL-014 §Policy Commitments](/wms/GOV-POL-014#sPolicy Commitments)
SDA-28M-01	🟡 Partial	[GOV-POL-014 §Organisational Context](/wms/GOV-POL-014#sOrganisational Context) [GOV-POL-014 §Policy Commitments](/wms/GOV-POL-014#sPolicy Commitments)	🟢 Low	Hostile workplace environment is a separate unlawful-conduct ground introduced by Respect@Work; GOV-POL-014 addresses the underlying risk factors but does not explicitly name ‘hostile workplace environment on the ground of sex’ as a standalone form of unlawful conduct. Consider adding an explicit reference to s.28M in the policy Purpose statement and to the Policy Commitments preamble alongside the existing s.47C reference, so that hostile-environment and harassment are visibly distinguished.
SDA-47C-01	✅ Full	GOV-POL-014 §Purpose GOV-POL-014 §Scope [GOV-POL-006 §Policy Commitments](/wms/GOV-POL-006#sPolicy Commitments)
SDA-47C-02	✅ Full	[GOV-POL-014 §Policy Commitments](/wms/GOV-POL-014#sPolicy Commitments) GOV-POL-014 §Responsibilities [GOV-POL-006 §Policy Commitments](/wms/GOV-POL-006#sPolicy Commitments)
SDA-47C-03	🟡 Partial	[GOV-POL-014 §Organisational Context](/wms/GOV-POL-014#sOrganisational Context)	🟡 Medium	GOV-POL-014 establishes the contextual factors but does not contain an explicit reasonable-and-proportionate justification record (e.g., a documented assessment that the chosen measures are calibrated to Westlink’s size, resources and risk profile). For audit defensibility, consider maintaining a positive-duty action plan or annual self-assessment document that explicitly addresses each s.47C(6) factor; AHRC’s 2023 Guidelines and 2025 Enforcement Policy both contemplate this as evidence of compliance.
SDA-94-01	✅ Full	[GOV-POL-014 §Policy Commitments](/wms/GOV-POL-014#sPolicy Commitments)
SDA-105-01	🟡 Partial	GOV-POL-014 §Responsibilities	🟢 Low	GOV-POL-014 obliges managers and supervisors to respond and escalate but does not explicitly state that turning a blind eye to or tolerating unlawful conduct attracts personal liability under s.105 accessorial liability. For supervisor training and policy reinforcement, consider adding a sentence to the Responsibilities table notes flagging the personal-liability consequence.
SDA-106-01	🟡 Partial	[GOV-POL-014 §Policy Commitments](/wms/GOV-POL-014#sPolicy Commitments) GOV-POL-014 §Responsibilities	🟡 Medium	GOV-POL-014 does not explicitly identify itself as evidence supporting a s.106(2) all-reasonable-steps defence. For audit defensibility, the positive-duty action plan (s.47C) should be cross-referenced to s.106(2) — for example via an addendum or in the policy Review section noting that the action plan is the organisation’s record of reasonable steps for vicarious liability purposes.

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.