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← Back to Document LibraryEqual Employment Opportunity Policy
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Purpose
This policy establishes Westlink Logistics’ commitment to equal employment opportunity and to a workplace free from unlawful discrimination, harassment, and victimisation. It provides the framework for merit-based employment decisions and compliance with Commonwealth and Western Australian anti-discrimination legislation.
Scope
This policy applies to all Westlink Logistics workers, contractors, labour hire workers, and applicants for employment. It covers all aspects of the employment relationship including recruitment, selection, terms and conditions, training, development, performance management, promotion, transfer, and termination. It extends to conduct at Westlink premises, client sites, during work-related travel, and at work-related social functions.
Organisational Context
Westlink Logistics operates heavy haulage, project logistics, and maritime services across Australia, primarily supporting defence, government, resources, and infrastructure sectors. The workforce spans office, field, and remote site roles across multiple states, with a significant proportion of workers engaged through labour hire and subcontracting arrangements.
The organisation holds Defence Industry Security Program (DISP) membership and is subject to JOSCAR pre-qualification, both of which require demonstrated workforce management standards including diversity and equal opportunity. EEO obligations are integrated into the Westlink Management System (WMS) and managed alongside workforce competence under ISO 9001 and ISO 45001.
Policy Commitments
Westlink Logistics does not tolerate unlawful discrimination on the basis of any protected attribute. Under Commonwealth and Western Australian legislation, protected attributes include: race, colour, national extraction, ethnic origin, or social origin; sex, sexual orientation, gender identity, and intersex status; age; physical or mental disability (past, present, or imputed); marital or relationship status and family or carer’s responsibilities; pregnancy or potential pregnancy; religious belief or activity, political opinion, or trade union membership; and spent criminal conviction.
Westlink Logistics is committed to:
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Basing all recruitment, selection, promotion, and termination decisions on the genuine requirements of the position and on individual merit, qualifications, skills, and experience.
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Providing equal access to training, development, and career advancement opportunities regardless of any protected attribute.
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Making reasonable adjustments for workers and applicants with disability to enable them to perform the inherent requirements of their role, unless doing so would impose unjustifiable hardship.
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Investigating all complaints of discrimination, harassment, or victimisation promptly, impartially, and confidentially, and protecting complainants and witnesses from victimisation.
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Providing all workers with information about their rights and obligations under anti-discrimination legislation during induction and through regular awareness activities.
Workers who believe they have experienced unlawful discrimination may raise a complaint internally per GOV-POL-011 or lodge a complaint with the Equal Opportunity Commission of Western Australia, the Australian Human Rights Commission, or the Fair Work Commission for general protections disputes under Part 3-1 of the Fair Work Act 2009.
Responsibilities
| Role | Responsibility | When |
|---|---|---|
| Chief Executive Officer | Accountable for this policy. Ensures the organisation maintains a workplace culture that values equal opportunity and is free from unlawful discrimination. | Ongoing; annual management review |
| QHSE Manager | Maintains this policy. Coordinates EEO awareness training. Monitors discrimination complaints and trends. Advises management on anti-discrimination compliance. | Ongoing; on complaint |
| Managers and Supervisors | Implement this policy within their areas. Model inclusive behaviour. Ensure employment decisions are merit-based. Take prompt action on any discriminatory conduct observed or reported. | Ongoing; on incident |
| All Workers and Contractors | Treat others with dignity and respect. Comply with this policy and anti-discrimination legislation. Report any conduct believed to be discriminatory, harassing, or victimising. | Ongoing; on incident |
Review
This policy is reviewed annually as part of the management review cycle, or earlier where significant changes occur to anti-discrimination legislation, the organisation’s workforce profile, or industry requirements. This policy is communicated to all workers during induction and is available to applicants for employment and other interested parties on request.
Applicable Standards and Legislation
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Equal Opportunity Act 1984 (WA)
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Fair Work Act 2009 (Cth)
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Age Discrimination Act 2004 (Cth)
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Disability Discrimination Act 1992 (Cth)
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Racial Discrimination Act 1975 (Cth)
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Sex Discrimination Act 1984 (Cth)
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Australian Human Rights Commission Act 1986 (Cth)
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ISO 9001:2015 Quality Management Systems — Requirements
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ISO 45001:2018 Occupational Health and Safety Management Systems — Requirements
Related Documents
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GOV-POL-006 Workplace Behaviour 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
Compliance coverage — cited by 53 requirements across 4 frameworks
Anti-Discrimination — Sex/Age/Race/Disability Discrimination Acts (Cth) + AHRC Act complaints + Equal Opportunity Act 1984 (WA)(43)
| Requirement | Clause | Coverage | Severity | Notes |
|---|---|---|---|---|
| SDA-5-01 | SDA s.5 | Full | §Policy CommitmentsProtected-attributes paragraph expressly lists sex; merit-based decision commitment operationalises non-discrimination across employment lifecycle. | |
| SDA-5A-01 | SDA s.5A | Full | §Policy CommitmentsProtected-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 | Full | §Policy CommitmentsProtected-attributes paragraph expressly lists gender identity. | |
| SDA-5C-01 | SDA s.5C | Full | §Policy CommitmentsProtected-attributes paragraph expressly lists intersex status. | |
| SDA-6-01 | SDA s.6 | Full | §Policy CommitmentsProtected-attributes paragraph expressly lists marital or relationship status. | |
| SDA-7-01 | SDA s.7 | Full | §Policy CommitmentsProtected-attributes paragraph expressly lists pregnancy or potential pregnancy. | |
| SDA-7AA-01 | SDA s.7AA | Partial | Low | §Policy CommitmentsProtected-attributes paragraph references pregnancy and family responsibilities; breastfeeding not separately named but is implied by SDA protected-attributes coverage. |
| SDA-7A-01 | SDA s.7A | Full | §Policy CommitmentsProtected-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 | Partial | Low | §Policy CommitmentsProtected-attributes paragraph covers each underlying ground individually; multi-attribute hostile-environment risk not separately named. |
| SDA-14-01 | SDA s.14 | Full | §ScopeScope covers recruitment, selection, terms and conditions, training, development, performance management, promotion, transfer and termination — comprehensive employment lifecycle coverage. | |
| SDA-15-01 | SDA s.15 | Partial | Low | §ScopeScope extends to contractors; commission-agent relationships are uncommon for Westlink but the scope clause is broad enough to capture them. |
| SDA-16-01 | SDA s.16 | Full | §ScopeScope expressly extends to contractors and labour hire workers — captures the s.16 relationship. | |
| SDA-47A-01 | SDA s.47A | Full | §Policy CommitmentsCommitment 4 expressly commits to investigating complaints and protecting complainants and witnesses from victimisation. | |
| ADA-14-01 | ADA s.14 | Full | §Policy CommitmentsProtected-attributes paragraph expressly lists age; merit-based decision commitment applies. | |
| ADA-15-01 | ADA s.15 | Partial | Medium | §Policy CommitmentsCommitment 1 (merit-based decisions on genuine requirements of the position) implicitly addresses indirect discrimination — selection criteria must be defensible against age-based disparate impact. |
| ADA-18-01 | ADA s.18 | Full | §ScopeScope 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. | |
| ADA-47A-01 | ADA s.47A | Full | §Policy CommitmentsCommitment 4 (investigation and protection from victimisation) covers victimisation across all federal anti-discrimination Acts. | |
| ADA-56-01 | ADA s.56 | Partial | Low | §ResponsibilitiesManagers and Supervisors row obliges them to take prompt action on any discriminatory conduct observed or reported — operationalises the duty not to permit unlawful conduct. |
| RDA-10-01 | RDA s.10 | Full | §Policy CommitmentsProtected-attributes paragraph lists race, colour, national extraction, ethnic origin, social origin — comprehensive RDA coverage. | |
| RDA-15-01 | RDA s.15 | Full | §ScopeScope covers employment lifecycle and contractors — captures s.15 employment prohibition. | |
| RDA-18C-01 | RDA s.18C | Partial | Low | §Policy CommitmentsProtected-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. |
| RDA-18AA-01 | RDA s.18AA | Full | §Policy CommitmentsCommitment 4 (investigation and protection from victimisation) covers victimisation across all federal anti-discrimination Acts. | |
| RDA-18A-01 | RDA s.18A and s.18E | Partial | Medium | §Policy CommitmentsCommitment 5 (workforce awareness training) operationalises the 'all reasonable steps' defence — training records evidence reasonable steps. |
| DDA-5-01 | DDA s.5 | Full | §Policy CommitmentsProtected-attributes paragraph expressly lists physical or mental disability (past, present, or imputed). Commitment 3 (reasonable adjustments) operationalises the s.5 reasonable-adjustment limb. | |
| DDA-6-01 | DDA s.6 | Full | §Policy CommitmentsCommitment 3 (reasonable adjustments unless unjustifiable hardship) directly addresses the indirect discrimination test. | |
| DDA-11-01 | DDA s.11 | Partial | Medium | §Policy CommitmentsCommitment 3 expressly references unjustifiable hardship as the limit of the reasonable-adjustment obligation. |
| DDA-15-01 | DDA s.15 | Full | §ScopeScope covers employment lifecycle and contractors — captures s.15-17 employment-context coverage. | |
| DDA-58A-01 | DDA s.58A | Full | §Policy CommitmentsCommitment 4 (protection of complainants and witnesses from victimisation) covers victimisation across all federal anti-discrimination Acts. | |
| DDA-122-01 | DDA s.122 + s.123 | Partial | Medium | §ResponsibilitiesResponsibilities table cascade establishes supervisory layer engaged in prevention — supports vicarious-liability defence; managers/supervisors operationalise non-toleration duty to avoid accessorial liability. |
| AHRCA-46P-01 | AHRC Act 1986 (Cth) Part IIB s.46P | Full | §Policy CommitmentsClosing 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 | Referenced-only | §Policy CommitmentsReference 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. | |
| AHRCA-46PH-01 | AHRC Act 1986 (Cth) Part IIB s.46PH | Full | §Policy CommitmentsAwareness 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 | Full | §Policy CommitmentsClosing 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 | Full | §Policy CommitmentsProtected-attributes paragraph expressly lists sex, marital status, pregnancy; family responsibility/carer's responsibilities also listed. Breastfeeding implicit in pregnancy coverage. | |
| EOA-WA-Pt-IIAA-01 | EOA-WA Part IIAA | Full | §Policy CommitmentsProtected-attributes paragraph expressly lists gender identity — captures the gender-history equivalent. | |
| EOA-WA-Pt-IIA-01 | EOA-WA Part IIA | Full | §Policy CommitmentsProtected-attributes paragraph expressly lists family or carer's responsibilities — covers both family responsibility and family status grounds. | |
| EOA-WA-Pt-IIB-01 | EOA-WA Part IIB | Full | §Policy CommitmentsProtected-attributes paragraph expressly lists sexual orientation. | |
| EOA-WA-Pt-III-01 | EOA-WA Part III | Full | §Policy CommitmentsProtected-attributes paragraph expressly lists race, colour, national extraction, ethnic origin, social origin — covers EOA-WA race ground. | |
| EOA-WA-Pt-IV-01 | EOA-WA Part IV | Full | §Policy CommitmentsProtected-attributes paragraph expressly lists religious belief or activity, political opinion, or trade union membership. | |
| EOA-WA-Pt-IVA-01 | EOA-WA Part IVA | Full | §Policy CommitmentsProtected-attributes paragraph expressly lists physical or mental disability (past, present, or imputed) — covers WA impairment ground. Commitment 3 (reasonable adjustments) applies. | |
| EOA-WA-Pt-IVB-01 | EOA-WA Part IVB | Full | §Policy CommitmentsProtected-attributes paragraph expressly lists age. | |
| EOA-WA-67-01 | EOA-WA s.67 | Full | §Policy CommitmentsCommitment 4 (protecting complainants and witnesses from victimisation) covers EOA-WA victimisation. | |
| EOA-WA-161-01 | EOA-WA s.161 | Partial | Medium | §Policy CommitmentsCommitment 5 (worker awareness through induction and refresher training) provides foundation of 'reasonably practicable steps' evidence. |
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(1)
| Requirement | Clause | Coverage | Severity | Notes |
|---|---|---|---|---|
| FW-351-01 | FW Act s.351 | Full | §Policy CommitmentsPolicy commits to merit-based decisions and lists each protected attribute under s.351. Same coverage as the anti-discrimination.md Cth/WA rows — s.351 is the FW Act parallel enforcement route. |
ISO 45001:2018(2)
| Requirement | Clause | Coverage | Severity | Notes |
|---|---|---|---|---|
| ISO45001-2018-7.2-01 | 7.2 | Full | §Policy CommitmentsEqual access to WHS training and development — cl.7.2 competence (parallel anchor to ISO 9001 cl.7.2). | |
| ISO45001-2018-7.3-01 | 7.3 | Full | §Policy CommitmentsEEO awareness and training commitment — cl.7.3 awareness. |
ISO 9001:2015(7)
| Requirement | Clause | Coverage | Severity | Notes |
|---|---|---|---|---|
| ISO9001-2015-4.1-01 | 4.1 | Full | §Organisational ContextMulti-state workforce — EEO scope spans all jurisdictions; cl.4.1 context anchor. | |
| ISO9001-2015-4.2-01 | 4.2 | Full | §Organisational ContextDISP / JOSCAR interested-party expectations on workforce non-discrimination — cl.4.2. | |
| ISO9001-2015-5.1.1-01 | 5.1.1 | Partial | Low | §ResponsibilitiesCEO accountable for EEO policy — cl.5.1 leadership. |
| ISO9001-2015-5.3-01 | 5.3 | Full | §ResponsibilitiesQHSE Manager — EEO training and compliance monitoring role assignment — cl.5.3. | |
| ISO9001-2015-7.2-01 | 7.2 | Full | §Policy CommitmentsEqual access to training and development commitment — cl.7.2 competence. | |
| ISO9001-2015-7.4-01 | 7.4 | Full | §ReviewPolicy available to interested parties on request — cl.7.4 communication. | |
| ISO9001-2015-9.3.1-01 | 9.3.1 | Full | §ReviewAnnual EEO review in management review cycle — cl.9.3.1. |
Declared compliance references (53)
ADA-14-01ADA-15-01ADA-18-01ADA-47A-01ADA-56-01AHRCA-46P-01AHRCA-46PF-01AHRCA-46PH-01AHRCA-46PO-01DDA-11-01DDA-122-01DDA-15-01DDA-5-01DDA-58A-01DDA-6-01EOA-WA-161-01EOA-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-351-01ISO45001-2018-7.2-01ISO45001-2018-7.3-01ISO9001-2015-4.1-01ISO9001-2015-4.2-01ISO9001-2015-5.1.1-01ISO9001-2015-5.3-01ISO9001-2015-7.2-01ISO9001-2015-7.4-01ISO9001-2015-9.3.1-01RDA-10-01RDA-15-01RDA-18A-01RDA-18AA-01RDA-18C-01SDA-14-01SDA-15-01SDA-16-01SDA-47A-01SDA-5-01SDA-5A-01SDA-5B-01SDA-5C-01SDA-6-01SDA-7-01SDA-7A-01SDA-7AA-01SDA-8A-01
Document Revision Summary
| Rev | Issued | Document Ref | Document Title | Author | Approved |
|---|---|---|---|---|---|
| 1 | 24/05/2021 | WLK-GBL-GOV-POL-009 | Equal Employment Opportunity Policy | CEO (JDG) | CEO (JDG) |
| 2 | 09/03/2026 | GOV-POL-009 | Equal Employment Opportunity Policy | FTM (CF) | CEO (JDG) |
| 3 | 16/03/2026 | GOV-POL-009 | Equal Employment Opportunity Policy | FTM (CF) | CEO (JDG) |
Document Revision Details
| Rev | Purpose of revision and changes made |
|---|---|
| 3 | Added Organisational Context section — grounds the policy in Westlink's multi-state, multi-arrangement workforce and DISP/JOSCAR diversity requirements.• Consolidated protected attributes into a single paragraph — replaces the separate bullet-per-attribute format for readability while retaining all attributes.• Consolidated 8 policy commitments to 5 focused obligations — removed procedural detail (selection criteria specifics, performance management processes) that belongs in HR procedures.• Added GOV-POL-011 cross-reference in external complaint pathway paragraph — directs workers to the grievance process first.• Responsibilities converted from paragraphs to 3-column table — aligns with §2.1 standard and makes role obligations auditable.• Updated terminology: 'employee' to 'worker' throughout (WHS Act alignment).• Curated cross-references — retained directly relevant people policies (Behaviour, Inclusion, Grievance, Sexual Harassment). Removed GOV-POL-016 (Social Media) and HR-PRO-001 (Workforce Screening) as not directly relevant at policy level.• Added requirements traceability matrix mapping policy elements to anti-discrimination legislation and ISO clauses. |