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Purpose
This policy establishes Westlink Logistics’ commitment to the identification, protection, and respectful management of Aboriginal and Torres Strait Islander cultural heritage in connection with the organisation’s operations. It provides the framework for heritage compliance and for meaningful engagement with Traditional Owners and Aboriginal communities.
Scope
This policy applies to all Westlink Logistics operations, projects, workers, contractors, and subcontractors. It covers all activities that may affect Aboriginal and Torres Strait Islander cultural heritage, including heavy haulage, project logistics, site establishment, route planning, laydown areas, and ground-disturbing works. It applies across all jurisdictions in which Westlink operates, with particular reference to Western Australian requirements.
Organisational Context
Westlink Logistics operates heavy haulage, project logistics, and maritime services across Australia, primarily supporting defence, government, resources, and infrastructure sectors. Operations frequently traverse regional and remote areas of Western Australia where Aboriginal heritage sites are present, including transport corridors through the Pilbara, Kimberley, Mid West, and Goldfields regions.
Client contracts in the defence and resources sectors routinely require demonstrated heritage management capability. The organisation holds Defence Industry Security Program (DISP) membership and is subject to JOSCAR pre-qualification, which includes social value and community engagement requirements. Heritage obligations are integrated into the Westlink Management System (WMS) and managed as environmental aspects under ISO 14001.
Policy Commitments
Westlink Logistics acknowledges and respects the continuing connection of Aboriginal and Torres Strait Islander peoples to their lands, waters, and cultural heritage. The organisation is committed to:
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Complying with all applicable heritage legislation, including the Aboriginal Heritage Act 1972 (WA), the Native Title Act 1993 (Cth), and the heritage provisions of the Environment Protection and Biodiversity Conservation Act 1999 (Cth).
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Conducting heritage risk assessments and due diligence searches of the Aboriginal Heritage Inquiry System before operations in new areas, establishing laydown facilities, or planning transport routes through areas of potential heritage sensitivity.
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Engaging with Traditional Owners and Aboriginal communities in a genuine, respectful, and timely manner when planning activities that may affect cultural heritage, applying the principles of free, prior, and informed consent where practicable.
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Implementing a stop-work protocol when a previously unidentified heritage site, object, or Aboriginal ancestral remains are discovered. Work must cease immediately, the area must be secured, and the discovery reported to the Department of Planning, Lands and Heritage (WA) per s.15 and s.17 of the Aboriginal Heritage Act 1972.
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Providing heritage awareness training to all workers and contractors operating in areas of heritage sensitivity, covering identification of potential sites, reporting obligations, and cultural significance.
Responsibilities
| Role | Responsibility | When |
|---|---|---|
| Chief Executive Officer | Accountable for this policy. Ensures operations respect and protect Aboriginal and Torres Strait Islander cultural heritage. | Ongoing; annual management review |
| QHSE Manager | Maintains this policy. Ensures heritage risk assessments are completed. Coordinates heritage awareness training. Manages heritage incident reporting to DPLH. | On new project; on heritage discovery |
| Project Managers | Complete heritage due diligence before project mobilisation. Implement project-specific heritage management plans. Manage engagement with Traditional Owners as required by project conditions. | Pre-mobilisation; during project |
| All Workers and Contractors | Comply with heritage management controls. Complete heritage awareness training when required. Immediately cease work and report any suspected heritage discoveries. | Ongoing; on discovery |
Review
This policy is reviewed annually as part of the management review cycle, or earlier where significant changes occur to heritage legislation, the organisation’s operational footprint, or following a heritage incident. This policy is communicated to all workers and contractors and is available to Traditional Owners, clients, and other interested parties on request.
Applicable Standards and Legislation
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Aboriginal Heritage Act 1972 (WA)
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Native Title Act 1993 (Cth)
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Environment Protection and Biodiversity Conservation Act 1999 (Cth)
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ISO 14001:2026 Environmental Management Systems — Requirements
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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-004 Environmental Management Policy
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QHSE-MAN-001 Westlink Management System Manual
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QHSE-PRO-001 Hazard and Incident Reporting and Investigation Procedure
Compliance coverage — cited by 20 requirements across 3 frameworks
Aboriginal Heritage Act 1972 (WA) + Commonwealth heritage provisions (EPBC + Native Title)(9)
| Requirement | Clause | Coverage | Severity | Notes |
|---|---|---|---|---|
| AHA-5-01 | AH Act 1972 (WA) s.5 | Partial | Low | §ScopePolicy scope covers all activities that may affect Aboriginal and Torres Strait Islander cultural heritage — heavy haulage, site establishment, route planning, laydown areas, and ground-disturbing works — operating within the s.5 site definition by reference rather than restating the categories. |
| AHA-15-01 | AH Act 1972 (WA) s.15 | Full | §Policy CommitmentsPolicy commits to a stop-work protocol on discovery of a previously unidentified heritage site, object or Aboriginal ancestral remains — work ceases immediately, the area is secured, and the discovery is reported to the Department of Planning, Lands and Heritage (WA) per s.15 and s.17. The 'All Workers and Contractors' responsibility row requires workers to immediately cease work and report suspected heritage discoveries. | |
| AHA-17-01 | AH Act 1972 (WA) s.17 + s.57 + s.58 | Partial | Medium | §Policy CommitmentsPolicy commits to complying with the Aboriginal Heritage Act 1972 (WA) and to conducting heritage risk assessments and due-diligence searches of the Aboriginal Heritage Inquiry System before operations in new areas, establishing laydown facilities, or planning transport routes — controls that prevent a s.17 breach. The stop-work protocol prevents continued damage once a site is identified. |
| AHA-18-01 | AH Act 1972 (WA) s.18 + s.55 | Partial | Medium | §Policy CommitmentsPolicy commits to heritage risk assessments and due-diligence searches before mobilisation; the Responsibilities table assigns Project Managers to complete heritage due diligence before project mobilisation and to implement project-specific heritage management plans. |
| AHA-62-01 | AH Act 1972 (WA) s.62 | Partial | Low | §Policy CommitmentsPolicy commits to due-diligence searches of the Aboriginal Heritage Inquiry System and to heritage risk assessments before operations in new areas — the diligence on which a s.62 defence would rest. Heritage awareness training supports worker-level recognition of potential sites. |
| EPBC-NH-01 | EPBC Act 1999 (Cth) s.15B / s.15C | Partial | Medium | §Policy CommitmentsPolicy commits to complying with the heritage provisions of the Environment Protection and Biodiversity Conservation Act 1999 (Cth). |
| EPBC-CH-01 | EPBC Act 1999 (Cth) s.27B / s.27C | Partial | Low | §Policy CommitmentsPolicy commits to EPBC heritage compliance; the organisational context notes defence-sector work, which brings Commonwealth Heritage places into scope. |
| NTA-FA-01 | Native Title Act 1993 (Cth) Pt 2 Div 3 (future acts) + Subdiv P (right to negotiate) | Referenced-only | §Policy CommitmentsPolicy commits to complying with the Native Title Act 1993 (Cth) and to engaging Traditional Owners and Aboriginal communities. Westlink's exposure is indirect (operating under client tenements) — the future-act regime is the awareness context for that engagement. | |
| NTA-ILUA-01 | Native Title Act 1993 (Cth) Pt 2 Div 3 Subdiv B-E (Indigenous Land Use Agreements) | Partial | Low | §Policy CommitmentsPolicy commits to genuine, respectful and timely engagement with Traditional Owners and Aboriginal communities when planning activities that may affect cultural heritage, applying free, prior and informed consent principles where practicable — the engagement an ILUA's protocols formalise. |
ISO 14001:2026(10)
| Requirement | Clause | Coverage | Severity | Notes |
|---|---|---|---|---|
| ISO14001-2026-4.1-01 | 4.1 | Full | §Organisational ContextOrganisational Context — WA operational areas | |
| ISO14001-2026-4.2-01 | 4.2 | Partial | §Organisational ContextOrganisational Context — client and JOSCAR requirements; Commitment — Traditional Owner engagement | |
| ISO14001-2026-5.1-01 | 5.1 | Full | §ResponsibilitiesCEO accountable for policy | |
| ISO14001-2026-5.2-01 | 5.2 | Full | §PurposePurpose — heritage protection framework | |
| ISO14001-2026-5.2-02 | 5.2 | Full | §ReviewAvailable to interested parties on request | |
| ISO14001-2026-5.3-01 | 5.3 | Full | §ResponsibilitiesQHSE Manager — heritage risk and incident reporting; Project Managers — due diligence and engagement | |
| ISO14001-2026-6.1.2-03 | 6.1.2 | Full | §Policy CommitmentsCommitment — heritage risk assessments and due diligence | |
| ISO14001-2026-6.1.3-01 | 6.1.3 | Full | §Policy CommitmentsCommitment — legislative compliance | |
| ISO14001-2026-7.2-01 | 7.2 | Full | §Policy CommitmentsCommitment — heritage awareness training | |
| ISO14001-2026-9.3.1-01 | 9.3.1 | Full | §ReviewAnnual review in management review cycle |
ISO 45001:2018(1)
| Requirement | Clause | Coverage | Severity | Notes |
|---|---|---|---|---|
| ISO45001-2018-7.2-01 | 7.2 | Full | §Policy CommitmentsCommitment — heritage awareness training |
Declared compliance references (20)
AHA-15-01AHA-17-01AHA-18-01AHA-5-01AHA-62-01EPBC-CH-01EPBC-NH-01ISO14001-2026-4.1-01ISO14001-2026-4.2-01ISO14001-2026-5.1-01ISO14001-2026-5.2-01ISO14001-2026-5.2-02ISO14001-2026-5.3-01ISO14001-2026-6.1.2-03ISO14001-2026-6.1.3-01ISO14001-2026-7.2-01ISO14001-2026-9.3.1-01ISO45001-2018-7.2-01NTA-FA-01NTA-ILUA-01
Document Revision Summary
| Rev | Issued | Document Ref | Document Title | Author | Approved |
|---|---|---|---|---|---|
| 1 | 24/05/2021 | WLK-GBL-GOV-POL-008 | Indigenous Heritage Policy | CEO (JDG) | CEO (JDG) |
| 2 | 09/03/2026 | GOV-POL-008 | Indigenous Heritage Policy | FTM (CF) | CEO (JDG) |
| 3 | 16/03/2026 | GOV-POL-008 | Indigenous Heritage Policy | FTM (CF) | CEO (JDG) |
Document Revision Details
| Rev | Purpose of revision and changes made |
|---|---|
| 3 | Removed all references to Aboriginal Cultural Heritage Act 2021 (WA) — repealed 15 November 2023 by the Aboriginal Heritage Legislation Amendment and Repeal Act 2023. Aboriginal Heritage Act 1972 (WA) reinstated as current legislation.• Added Organisational Context section (ISO 14001:2015 cl.4.1) — grounds the policy in Westlink's operational areas (Pilbara, Kimberley, Mid West, Goldfields) where heritage sites are present, and client/JOSCAR heritage requirements.• Consolidated 9 policy commitments to 5 focused obligations — removed aspirational social responsibility items (Indigenous employment, business participation) that are better addressed in a Reconciliation Action Plan.• Added specific Aboriginal Heritage Act section references — s.15 (protection), s.17 (reporting) now explicit in stop-work commitment.• Responsibilities converted from paragraphs to 3-column table — added Project Managers role for heritage due diligence.• Updated terminology: 'employee' to 'worker' throughout (WHS Act alignment).• Curated cross-references — replaced auto-discovered list with directly relevant documents. Removed QHSE-GDL-001 (contractor requirements, too operational for policy level).• Added requirements traceability matrix mapping policy elements to Aboriginal Heritage Act 1972, EPBC Act 1999, and ISO clauses. |