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Purpose
This policy establishes Westlink Logistics’ commitment to a work environment free from bullying, harassment, discrimination, victimisation, and occupational violence. It provides the framework for identifying and managing psychosocial hazards and sets out obligations for reporting, investigation, and resolution of complaints.
Scope
This policy applies to all Westlink Logistics employees, contractors, labour hire workers, volunteers, and visitors across all workplaces, work-related events, and digital communications. It covers conduct at Westlink premises, client sites, during travel for work purposes, and at work-related social functions. It extends to conduct outside the workplace where there is a sufficient connection to the employment relationship.
Organisational Context
Westlink Logistics operates heavy haulage, project logistics, and maritime services across Australia, primarily supporting defence, government, resources, and infrastructure sectors. Workers operate in high-risk environments including remote sites, vessel operations, and heavy vehicle transport where psychosocial hazards compound physical safety risks.
The organisation holds Defence Industry Security Program (DISP) membership and is subject to JOSCAR pre-qualification, both of which require demonstrated workforce management standards. Workplace behaviour obligations are integrated into the Westlink Management System (WMS) and managed alongside WHS risks under ISO 45001.
Policy Commitments
Westlink Logistics is committed to:
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Eliminating or minimising psychosocial risks so far as is reasonably practicable, in accordance with the Work Health and Safety Act 2020 (WA) and the WHS Regulations 2022 Part 5.1.
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Meeting the positive duty to eliminate sexual harassment, sex discrimination, and related conduct under the Sex Discrimination Act 1984 (Cth) s.47C, as amended by the Respect@Work Act 2022.
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Providing accessible, confidential reporting mechanisms and ensuring all complaints are investigated promptly, impartially, and in accordance with procedural fairness.
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Taking appropriate disciplinary action where unacceptable behaviour is substantiated, and protecting complainants and witnesses from victimisation.
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Ensuring all workers understand expected standards of behaviour through induction training, regular awareness activities, and leadership example.
Definitions
Workplace bullying is repeated and unreasonable behaviour directed towards a worker or group of workers that creates a risk to health and safety, as defined in the Fair Work Act 2009 s.789FD. A single occurrence of unreasonable behaviour is not workplace bullying but may constitute another form of unacceptable conduct.
Harassment is unwelcome conduct that a reasonable person would anticipate would offend, humiliate, or intimidate. Sexual harassment is unwelcome sexual conduct as defined in the Sex Discrimination Act 1984 s.28A, regardless of the intention of the person engaging in the conduct.
Discrimination is treating a person less favourably because of a protected attribute under the Equal Opportunity Act 1984 (WA), including race, sex, age, disability, sexual orientation, gender identity, religious belief, pregnancy, marital status, or family responsibilities.
Victimisation is subjecting or threatening to subject a person to detrimental treatment because they have made, or propose to make, a complaint or have assisted another person in making a complaint.
Occupational violence is any incident where a worker is physically attacked, threatened, or abused in circumstances arising out of or in the course of their work, including aggression, intimidation, assault, and threats.
Reasonable management action carried out in a reasonable manner is not workplace bullying. This includes performance management, allocation of work, disciplinary action for misconduct, and operational decisions such as restructuring or redeployment.
Prohibited Conduct
Prohibited conduct includes, but is not limited to:
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Verbal abuse, offensive language, yelling, or repeated belittling of a person or their work.
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Spreading malicious rumours or gossip intended to harm a person’s reputation or standing in the workplace.
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Deliberately excluding or isolating a person from work activities, information, or social interactions without legitimate operational reason.
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Intimidating or threatening behaviour, including physical gestures, invasion of personal space, or implied threats to employment security.
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Assigning meaningless or degrading tasks, withholding information necessary for work, or setting unreasonable deadlines designed to cause failure.
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Unwelcome physical contact, sexual advances, requests for sexual favours, or sexually suggestive comments, messages, or images.
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Physical assault, pushing, shoving, throwing objects, or any form of physical violence or threat of violence.
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Cyberbullying, including threatening or abusive electronic communications, demeaning content on social media, or using digital means to harass or intimidate a worker.
Reporting and Investigation
Any worker who experiences or witnesses unacceptable workplace behaviour must report the matter as soon as practicable. Reports may be made to the worker’s direct supervisor, any member of management, the QHSE Manager, or via the confidential reporting mechanism. Reports may be made verbally or in writing. Anonymous reports will be accepted and investigated to the extent possible.
All complaints will be treated seriously, investigated promptly, and handled with appropriate confidentiality. Investigations will be conducted impartially and in accordance with principles of procedural fairness, including the right of all parties to be heard.
Workers who are not satisfied with the internal resolution of a complaint may refer the matter to WorkSafe WA, the Australian Human Rights Commission, the Equal Opportunity Commission of Western Australia, or the Fair Work Commission for anti-bullying orders under s.789FC of the Fair Work Act 2009.
Responsibilities
| Role | Responsibility | When |
|---|---|---|
| Chief Executive Officer | Accountable for this policy. Ensures the organisation provides a workplace free from bullying, harassment, discrimination, victimisation, and violence. | Ongoing; annual management review |
| QHSE Manager | Maintains this policy. Coordinates complaint investigations. Monitors psychosocial hazards within the WMS risk framework. Ensures workers are trained in their obligations. | On complaint; quarterly risk review |
| Managers and Supervisors | Model appropriate behaviour. Take immediate action on observed or reported unacceptable conduct. Support workers who raise concerns. Must not ignore or trivialise reports. | Ongoing; on incident |
| All Workers | Treat others with dignity and respect. Comply with this policy. Report unacceptable behaviour. Cooperate with investigations. | Ongoing; on incident |
Review
This policy is reviewed annually as part of the management review cycle, or earlier where significant changes occur to applicable legislation, the organisation’s psychosocial risk profile, or following a significant workplace behaviour incident. This policy is communicated to all workers during induction and is available to interested parties on request.
Applicable Standards and Legislation
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Work Health and Safety Act 2020 (WA)
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Work Health and Safety (General) Regulations 2022 (WA)
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Code of Practice: Managing Psychosocial Hazards at Work (WA, 2022)
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Fair Work Act 2009 (Cth)
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Sex Discrimination Act 1984 (Cth)
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Equal Opportunity Act 1984 (WA)
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ISO 45001:2018 Occupational Health and Safety Management Systems — Requirements
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ISO 9001:2015 Quality Management Systems — Requirements
Related Documents
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GOV-POL-002 Work Health and Safety Policy
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GOV-POL-009 Equal Employment Opportunity Policy
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GOV-POL-010 Inclusion and Diversity Policy
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GOV-POL-011 Grievance Resolution Policy
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GOV-POL-014 Sexual Harassment Prevention Policy
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GOV-POL-016 Social Media Usage Policy
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GOV-POL-018 Whistleblower Policy
Compliance coverage — cited by 31 requirements across 6 frameworks
Anti-Discrimination — Sex/Age/Race/Disability Discrimination Acts (Cth) + AHRC Act complaints + Equal Opportunity Act 1984 (WA)(10)
| Requirement | Clause | Coverage | Severity | Notes |
|---|---|---|---|---|
| RDA-18C-01 | RDA s.18C | Partial | Low | Workplace Behaviour Policy — operational standard for respectful-conduct expectations and prohibition on offensive behaviour. |
| EOA-WA-Pt-II-01 | EOA-WA Part II + s.11 | Full | §DefinitionsDefinition — discrimination (protected attributes) | |
| EOA-WA-Pt-IIAA-01 | EOA-WA Part IIAA | Full | §DefinitionsDefinition — discrimination (protected attributes) | |
| EOA-WA-Pt-IIA-01 | EOA-WA Part IIA | Full | §DefinitionsDefinition — discrimination (protected attributes) | |
| EOA-WA-Pt-IIB-01 | EOA-WA Part IIB | Full | §DefinitionsDefinition — discrimination (protected attributes) | |
| EOA-WA-Pt-III-01 | EOA-WA Part III | Full | §DefinitionsDefinition — discrimination (protected attributes) | |
| EOA-WA-Pt-IV-01 | EOA-WA Part IV | Full | §DefinitionsDefinition — discrimination (protected attributes) | |
| EOA-WA-Pt-IVA-01 | EOA-WA Part IVA | Full | §DefinitionsDefinition — discrimination (protected attributes) | |
| EOA-WA-Pt-IVB-01 | EOA-WA Part IVB | Full | §DefinitionsDefinition — discrimination (protected attributes) | |
| EOA-WA-67-01 | EOA-WA s.67 | Full | §Policy CommitmentsCommitment — disciplinary action and victimisation protection |
DSPF Principle 16 / Control 16.1 / Annex A(1)
| Requirement | Clause | Coverage | Severity | Notes |
|---|---|---|---|---|
| DSPF-A16.1-entry-gov-08 | A16.1-entry-gov-08 | Partial | Workplace Behaviour Policy addresses psychosocial/behavioural concerns adjacent to insider threat indicators. |
Fair Work Act 2009 (Cth) General Protections + Part 3-5A Sexual Harassment + Part 6-2 Disputes + Part 6-4B Bullying + WHS Act 2020 (WA) Part 6 Discriminatory Conduct(3)
| Requirement | Clause | Coverage | Severity | Notes |
|---|---|---|---|---|
| FW-789FC-01 | FW Act s.789FC | Full | §DefinitionsDefinition — workplace bullying; Reporting — external referral options | |
| FW-789FF-01 | FW Act s.789FF | Full | §Policy CommitmentsCommitment — disciplinary action and victimisation protection; Definition — workplace bullying | |
| WHS-WA-104-01 | WHS Act 2020 (WA) s.104 | Full | §Reporting and InvestigationReporting — external referral options |
ISO 45001:2018(13)
| Requirement | Clause | Coverage | Severity | Notes |
|---|---|---|---|---|
| ISO45001-2018-4.1-01 | 4.1 | Full | §Organisational ContextOrganisational Context — operational environment | |
| ISO45001-2018-4.2-01 | 4.2 | Full | §Organisational ContextOrganisational Context — DISP/JOSCAR workforce standards | |
| ISO45001-2018-5.1-01 | 5.1 | Partial | §ResponsibilitiesCEO accountable for policy | |
| ISO45001-2018-5.2-01 | 5.2 | Full | §ScopeScope — all workers and workplaces | |
| ISO45001-2018-5.2-02 | 5.2 | Full | §ReviewAvailable to interested parties on request | |
| ISO45001-2018-5.3-01 | 5.3 | Full | §ResponsibilitiesQHSE Manager — investigations and psychosocial risk | |
| ISO45001-2018-5.4-01 | 5.4 | Partial | §Policy CommitmentsCommitment — accessible reporting mechanisms | |
| ISO45001-2018-5.4-02 | 5.4 | Partial | §Policy CommitmentsCommitment — accessible reporting mechanisms | |
| ISO45001-2018-6.1.2.1-01 | 6.1.2.1 | Full | §PurposePurpose — psychosocial hazard framework | |
| ISO45001-2018-6.1.2.1-02 | 6.1.2.1 | Partial | Workplace Behaviour Policy addresses psychosocial hazard types (bullying/harassment). | |
| ISO45001-2018-7.3-01 | 7.3 | Full | §Policy CommitmentsCommitment — training and awareness | |
| ISO45001-2018-9.3-01 | 9.3 | Full | §ReviewAnnual review in management review cycle | |
| ISO45001-2018-9.3-02 | 9.3 | Full | §ReviewAnnual review in management review cycle |
Sex Discrimination Act 1984 (Cth) — Positive Duty + AHRC Seven Standards(3)
| Requirement | Clause | Coverage | Severity | Notes |
|---|---|---|---|---|
| SDA-28A-01 | SDA s.28A | Full | §DefinitionsDefinition — sexual harassment | |
| SDA-47C-01 | SDA s.47C(1) | Full | §Policy CommitmentsCommitment — positive duty re sexual harassment | |
| SDA-47C-02 | SDA s.47C(2) | Full | §Policy CommitmentsCommitment — positive duty re sexual harassment |
Work Health and Safety Act 2020 (WA)(1)
| Requirement | Clause | Coverage | Severity | Notes |
|---|---|---|---|---|
| WHS-WA-19-01 | WHS Act 2020 (WA) s.19 | Full | §ScopeScope — all workers and workplaces; Commitment — eliminate/minimise psychosocial risks SFAIRP |
Declared compliance references (31)
DSPF-A16.1-entry-gov-08EOA-WA-67-01EOA-WA-Pt-II-01EOA-WA-Pt-IIA-01EOA-WA-Pt-IIAA-01EOA-WA-Pt-IIB-01EOA-WA-Pt-III-01EOA-WA-Pt-IV-01EOA-WA-Pt-IVA-01EOA-WA-Pt-IVB-01FW-789FC-01FW-789FF-01ISO45001-2018-4.1-01ISO45001-2018-4.2-01ISO45001-2018-5.1-01ISO45001-2018-5.2-01ISO45001-2018-5.2-02ISO45001-2018-5.3-01ISO45001-2018-5.4-01ISO45001-2018-5.4-02ISO45001-2018-6.1.2.1-01ISO45001-2018-6.1.2.1-02ISO45001-2018-7.3-01ISO45001-2018-9.3-01ISO45001-2018-9.3-02WHS-WA-19-01RDA-18C-01SDA-28A-01SDA-47C-01SDA-47C-02WHS-WA-104-01
Document Revision Summary
| Rev | Issued | Document Ref | Document Title | Author | Approved |
|---|---|---|---|---|---|
| 1 | 24/05/2021 | WLK-GBL-GOV-POL-006 | Workplace Bullying Policy | CEO (JDG) | CEO (JDG) |
| 2 | 09/03/2026 | GOV-POL-006 | Workplace Behaviour Policy | FTM (CF) | CEO (JDG) |
| 3 | 13/03/2026 | GOV-POL-006 | Workplace Behaviour Policy | FTM (CF) | CEO (JDG) |
Document Revision Details
| Rev | Purpose of revision and changes made |
|---|---|
| 3 | Added Organisational Context section (ISO 45001:2018 cl.4.1) — grounds the policy in Westlink's operational environment, remote/maritime workforce, and DISP/JOSCAR obligations.• Added positive duty commitment — Sex Discrimination Act 1984 s.47C (Respect@Work Act 2022 amendments) requires proactive elimination of sexual harassment, not just reactive response.• Separated Definitions into its own headed section — previously buried under Policy Statement. Added statutory cross-references for each definition.• Separated Prohibited Conduct into its own headed section — clearer structure for workers and investigators.• Responsibilities converted to table format — aligns with §2.1 standard and makes role obligations auditable.• Curated cross-references — replaced auto-discovered references with directly relevant policies (WHS, EEO, Grievance, Sexual Harassment, Whistleblower).• Tightened policy commitments from narrative to 5 focused obligations.• Review section now references management review cycle and external availability (cl.5.2.2).• Added requirements traceability matrix mapping policy elements to ISO clauses and legislation. |