Purpose

This policy establishes a fair, transparent, and accessible framework for the resolution of workplace grievances at Westlink Logistics. It provides structured mechanisms for workers to raise concerns, complaints, and disputes with confidence that they will be addressed promptly, impartially, and without reprisal.

Scope

This policy applies to all Westlink Logistics workers, contractors, and labour hire personnel across all business functions and operational locations. It covers grievances relating to employment conditions, workplace relationships, management decisions, application of policies and procedures, and any matter that affects a worker’s work or wellbeing. Complaints of bullying, harassment, or discrimination may be raised under this policy and will be managed in conjunction with GOV-POL-006 and GOV-POL-009.

Organisational Context

Westlink Logistics operates heavy haulage, project logistics, and maritime services across Australia, primarily supporting defence, government, resources, and infrastructure sectors. Workers are dispersed across office, field, and remote site locations, often on client premises or in transit, which requires grievance mechanisms that are accessible regardless of work location.

The organisation holds Defence Industry Security Program (DISP) membership and is subject to JOSCAR pre-qualification, both of which require demonstrated governance and worker welfare standards. Grievance resolution is integrated into the Westlink Management System (WMS) as a worker participation mechanism under ISO 45001 cl.5.4 and a corrective action input under ISO 9001 cl.10.2.

Policy Commitments

Westlink Logistics is committed to:

Handling all grievances in accordance with natural justice principles: the right to be heard, the right to an impartial decision-maker, and the right to be informed of the outcome and reasons for any decision.
Maintaining confidentiality throughout the grievance process. Information will only be disclosed to those with a legitimate need to know in order to investigate or resolve the matter.
Providing a staged resolution process: (1) informal resolution with the other party or supervisor; (2) formal written grievance to the QHSE Manager with investigation and written outcome; (3) internal review by the CEO or delegate; (4) external resolution through the Fair Work Commission, Equal Opportunity Commission WA, or WorkSafe WA at any stage.
Prohibiting victimisation or retaliation against any person who raises a grievance in good faith, participates in an investigation, or provides evidence in connection with a grievance, in accordance with Fair Work Act 2009 s.340 and WHS Act 2020 s.104.
Recording grievances that reveal process nonconformities or systemic issues and managing them through the corrective action process per ISO 9001 cl.10.2 to prevent recurrence.

Responsibilities

Role	Responsibility	When
Chief Executive Officer	Accountable for this policy. Ensures the grievance framework operates fairly and effectively. Acts as final internal review authority.	Ongoing; on Stage 3 review request
QHSE Manager	Maintains the grievance process. Conducts or oversees formal investigations. Maintains grievance records. Reports trends and systemic issues through management review.	On formal grievance; quarterly reporting
Managers and Supervisors	Receive and respond to grievances in their areas. Attempt informal resolution where appropriate. Escalate per this policy when resolution is not achieved.	On grievance raised; during resolution
All Workers and Contractors	Raise concerns in good faith. Participate constructively in the resolution process. Cooperate with investigations.	On concern; during resolution

Review

This policy is reviewed annually as part of the management review cycle, or earlier where significant changes occur to applicable legislation or industrial instruments. Grievance data and trends are analysed as part of management review to identify improvement opportunities. This policy is communicated to all workers during induction and is available to interested parties on request.

Applicable Standards and Legislation

Fair Work Act 2009 (Cth)
Work Health and Safety Act 2020 (WA)
Equal Opportunity Act 1984 (WA)
ISO 45001:2018 Occupational Health and Safety Management Systems — Requirements
ISO 9001:2015 Quality Management Systems — Requirements

GOV-POL-006 Workplace Behaviour Policy
GOV-POL-009 Equal Employment Opportunity Policy
GOV-POL-010 Inclusion and Diversity Policy
GOV-POL-014 Sexual Harassment Prevention Policy
GOV-POL-018 Whistleblower Policy

Requirement	Clause	Coverage	Severity	Notes
FW-340-01	FW Act s.340	Full		§Policy CommitmentsCommitment 4 explicitly prohibits victimisation or retaliation against any person who raises a grievance in good faith, participates in an investigation, or provides evidence — citing Fair Work Act 2009 s.340 directly. Captures the operative s.340(1) and s.340(2) prohibitions.
FW-341-01	FW Act s.341	Partial	Medium	§PurposePurpose statement establishes 'a fair, transparent, and accessible framework for the resolution of workplace grievances' — operationalises s.341(1)(c)(ii) by guaranteeing workers a structured channel to make an in-employment complaint.
FW-342-01	FW Act s.342	Full		§Policy CommitmentsCommitment 4 prohibits 'victimisation or retaliation' against grievance raisers, investigators, and evidence-providers — captures the s.342 adverse-action categories at policy level (dismissal, injury in employment, alteration to prejudice, discrimination).
FW-343-01	FW Act s.343	Partial	Medium	§Policy CommitmentsCommitment 4 (no-victimisation) read together with Commitment 1 (natural justice — right to be heard, impartial decision-maker, informed outcome) prohibits coercive conduct against grievance participants. Commitment 2 (confidentiality, disclosure only on need-to-know) reduces structural pressure on participants.
FW-345-01	FW Act s.345	Partial	Low	§Policy CommitmentsCommitment 3 (staged resolution with written outcome and right of internal review) operationalises against misrepresentation by requiring written, reasoned decisions and a documented escalation pathway. Commitment 1 (natural justice — right to be informed of the outcome and reasons for any decision) directly addresses the s.345 risk.
FW-346-01	FW Act s.346	Partial	Low	§ScopeGrievance scope covers 'workplace relationships' and 'any matter that affects a worker's work or wellbeing' — would capture a worker grievance about adverse action because of industrial-association status, but the policy does not specifically name union or industrial-association activity.
FW-351-01	FW Act s.351	Full		§ScopeGrievance scope captures complaints alleging discriminatory adverse action — directly addresses s.351 via the in-employment complaint workplace right.
FW-352-01	FW Act s.352	Partial	Low	§ScopeGrievance scope captures complaints about dismissal during temporary illness/injury absence — enables s.352 enforcement via the FWC general protections route.
FW-357-01	FW Act s.357	Partial	Medium	§ScopeGrievance scope covers 'application of policies and procedures' and complaints affecting workers — would capture a worker complaint that they have been mischaracterised as a contractor. The substantive contracting-classification governance is owned outside this policy.
FW-527D-01	FW Act s.527D	Partial	Medium	§ScopeGrievance policy covers sexual harassment complaints handled in conjunction with GOV-POL-014 — captures the internal pathway component for s.527D contraventions.
FW-527F-01	FW Act s.527F	Full		§Policy CommitmentsCommitment 3 (staged resolution with external pathway) names FWC as an external resolution pathway 'at any stage' — captures s.527F applications for sexual harassment disputes.
FW-595-01	FW Act s.595	Full		§Policy CommitmentsCommitment 3 names FWC as an external resolution pathway 'at any stage' — captures the s.595 jurisdiction. The FWC's power is authorised by the various enabling provisions (s.527F for sexual harassment, s.789FC for bullying, s.365 for general protections court applications, etc.).
FW-738-01	FW Act Part 6-2 Div 2 (ss.738-740)	Referenced-only		§Policy CommitmentsReference only — Westlink's workforce is currently award-covered, not enterprise-agreement-covered, so Part 6-2 Div 2 dispute-term requirements do not currently apply. Captured here so that if Westlink negotiates an enterprise agreement in the future, the dispute-term requirement is on-hand. The FWC's general dispute jurisdiction at s.595 (FW-595-01) operates regardless of enterprise-agreement status.
FW-789FC-01	FW Act s.789FC	Full		§Policy CommitmentsCommitment 3 names FWC as an external resolution pathway 'at any stage' — captures s.789FC applications for stop-bullying orders. Bullying complaints handled internally under GOV-POL-011 in conjunction with GOV-POL-006 (Workplace Behaviour); the external FWC route is preserved as a non-negotiable alternative.
FW-789FF-01	FW Act s.789FF	Full		§ResponsibilitiesQHSE Manager investigates formal grievances and maintains records — when GOV-POL-011 procedures are exhausted or unable to resolve a bullying matter, s.789FF(2)(b)/(c) requires the FWC to take account of those internal procedures and outcomes. The internal grievance trail directly conditions the FWC's order-making discretion.
WHS-WA-104-01	WHS Act 2020 (WA) s.104	Full		§Policy CommitmentsCommitment 4 explicitly prohibits victimisation or retaliation against grievance raisers, citing 'WHS Act 2020 s.104' — direct adoption of s.104 as the policy's victimisation-prohibition source. Captures both criminal and civil pathways.
WHS-WA-105-01	WHS Act 2020 (WA) s.105	Full		§Policy CommitmentsZero-tolerance / no-victimisation commitment captures the categories of discriminatory conduct in s.105 (dismissal, contract termination, detriment, refusal/failure to engage, less favourable terms, commercial-arrangement termination). The grievance procedure includes labour-hire workers expressly under Scope, covering the s.105(d) prospective-worker and s.105(e) commercial-arrangement categories.
WHS-WA-106-01	WHS Act 2020 (WA) s.106	Partial	Low	§Policy CommitmentsCommitment 4 no-reprisal protection for raising grievances captures s.106(d) where the grievance relates to WHS — bullying, harassment, psychosocial issues all fall within. The protection of evidence-providers in Commitment 4 captures s.106(c) assistance with a WHS function.
WHS-WA-107-01	WHS Act 2020 (WA) s.107	Partial	Low	§ResponsibilitiesManager/supervisor accountabilities and CEO oversight of fair operation of the grievance framework operationalise s.107 — managers must not direct or authorise discriminatory action against grievance participants.
WHS-WA-108-01	WHS Act 2020 (WA) s.108	Partial	Low	§Policy CommitmentsNatural-justice principles (Commitment 1) and no-victimisation prohibition (Commitment 4) collectively address coercion against grievance participants. The s.108 specific framing — coercion regarding exercise of WHS powers/functions — overlaps with but is narrower than the grievance policy's general scope.
WHS-WA-109-01	WHS Act 2020 (WA) s.109	Partial	Low	§ResponsibilitiesManager/supervisor accountability for fair operation of the grievance framework operationalises s.109 — managers must not misrepresent workers' rights to raise WHS issues or to escalate to external regulators.
WHS-WA-110-01	WHS Act 2020 (WA) Part 6 Divisions 2-4 (ss.110-115)	Referenced-only		§Policy CommitmentsReference-only — Part 6 Divs 2-4 are state enforcement mechanisms, not Westlink-side duties. Captured for completeness so that the grievance pathway and the WHS-discrimination enforcement pathway are visibly connected in the framework. The internal grievance procedure under GOV-POL-011 is one route a worker may pursue; the s.112 civil action and s.110 prosecution are external alternatives.

Requirement	Clause	Coverage	Notes
ISO45001-2018-4.1-01	4.1	Full	§Organisational ContextDispersed workforce grievance context — cl.4.1.
ISO45001-2018-4.2-01	4.2	Full	§Organisational ContextDISP / JOSCAR governance expectations on grievance handling — cl.4.2.
ISO45001-2018-5.1-01	5.1	Partial	§ResponsibilitiesCEO — final internal grievance review authority — cl.5.1 leadership.
ISO45001-2018-5.3-01	5.3	Full	§ResponsibilitiesQHSE Manager — investigations and trend reporting role — cl.5.3 organisational roles.
ISO45001-2018-5.4-01	5.4	Partial	§PurposeGrievance framework operationalises cl.5.4 consultation and participation — fair, transparent process for raising concerns.
ISO45001-2018-7.4.1-01	7.4.1	Full	§Policy CommitmentsConfidentiality and availability commitments — cl.7.4.1 communication general.
ISO45001-2018-9.1.1-01	9.1.1	Full	§ResponsibilitiesQHSE Manager — grievance trend analysis as monitoring/measurement input — cl.9.1.1.
ISO45001-2018-9.3-01	9.3	Full	§ReviewAnnual review with grievance trend analysis — cl.9.3 management review.
ISO45001-2018-10.2-01	10.2	Full	§Policy CommitmentsCorrective action for systemic grievance issues — cl.10.2 incident, nonconformity and corrective action (OH&S MS).

Rev	Issued	Document Ref	Document Title	Author	Approved
1	24/05/2021	WLK-GBL-GOV-POL-011	Grievance Resolution Policy	CEO (JDG)	CEO (JDG)
2	09/03/2026	GOV-POL-011	Grievance Resolution Policy	FTM (CF)	CEO (JDG)
3	16/03/2026	GOV-POL-011	Grievance Resolution Policy	FTM (CF)	CEO (JDG)

Pending approval — not yet published

Grievance Resolution Policy

Purpose

Scope

Organisational Context

Policy Commitments

Responsibilities

Review

Applicable Standards and Legislation

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(22)

ISO 45001:2018(9)

ISO 9001:2015(1)

Pending approval — not yet published

Grievance Resolution Policy

Purpose

Scope

Organisational Context

Policy Commitments

Responsibilities

Review

Applicable Standards and Legislation

Related Documents

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(22)

ISO 45001:2018(9)

ISO 9001:2015(1)