Anti-Bribery and Corruption Policy

Purpose

This policy establishes Westlink Logistics’ zero-tolerance position on bribery and corruption in all forms. It provides the framework for preventing, detecting, and responding to bribery and corrupt conduct, ensuring compliance with Commonwealth and Western Australian criminal law.

Scope

This policy applies to all Westlink Logistics directors, workers, contractors, agents, consultants, and any person acting on behalf of the organisation, regardless of location or jurisdiction. It covers all business activities including tendering, procurement, contract management, dealings with government officials, and interactions with suppliers, clients, and third parties.

Organisational Context

Westlink Logistics operates heavy haulage, project logistics, and maritime services across Australia, primarily supporting defence, government, resources, and infrastructure sectors. A significant proportion of revenue derives from government and defence procurement, where anti-corruption obligations are contractually mandated and subject to audit.

The organisation holds Defence Industry Security Program (DISP) membership and is subject to JOSCAR pre-qualification, both of which require demonstrated anti-bribery and corruption controls. Integrity obligations are integrated into the Westlink Management System (WMS) and informed by ISO 37001 anti-bribery management principles.

Policy Commitments

Westlink Logistics maintains a zero-tolerance approach to bribery and corruption. The organisation will not engage in, solicit, or accept bribes or corrupt payments in any form, whether directly or through intermediaries. Westlink is committed to:

• Prohibiting all forms of bribery, including offering or accepting financial or other advantage as an inducement or reward for improper conduct, bribing foreign public officials in contravention of Criminal Code Act 1995 Div.70, secret commissions, kickbacks, and facilitation payments.

• Requiring all gifts, hospitality, and entertainment to be reasonable, proportionate, transparent, and declared per GOV-POL-019. They must never be offered or accepted where they could be perceived as influencing a business decision or government action.

• Requiring all workers and associated persons to report known or suspected bribery or corrupt conduct immediately to the CEO or QHSE Manager, or through the mechanisms in GOV-POL-018 (Whistleblower Policy). Westlink will protect reporters from retaliation.

• Conducting due diligence on agents, consultants, and intermediaries acting on behalf of Westlink to ensure they do not circumvent the requirements of this policy.

• Treating breaches as serious misconduct. Suspected criminal conduct will be reported to the Australian Federal Police or the Western Australian Corruption and Crime Commission as appropriate.

Responsibilities

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 business activities, or the risk environment. Review considers bribery risk assessments, reported incidents, and JOSCAR evidence requirements. This policy is communicated to all workers and is available to interested parties on request.

Applicable Standards and Legislation

• Criminal Code Act 1995 (Cth)

• Corruption, Crime and Misconduct Act 2003 (WA)

• Criminal Code Act Compilation Act 1913 (WA) — Chapter XLIII

• ISO 37001:2016 Anti-Bribery Management Systems (informative reference)

• ISO 9001:2015 Quality Management Systems — Requirements

Related Documents

• GOV-POL-011 Grievance Resolution Policy

• GOV-POL-013 Modern Slavery Policy

• GOV-POL-018 Whistleblower Policy

• GOV-POL-019 Gifts, Hospitality and Conflicts of Interest Policy

• QHSE-MAN-001 Westlink Management System Manual