Modern Slavery, Labour Standards and Human Rights Policy

Purpose

This policy documents Westlink Logistics’ approach to labour standards and human rights, and its commitment to preventing modern slavery and human trafficking, across our operations and supply chains. It provides the framework for upholding fair and lawful working conditions and for identifying, assessing and mitigating labour-rights and modern slavery risks, in accordance with the Fair Work Act 2009 (Cth), the Modern Slavery Act 2018 (Cth), and the UN Guiding Principles on Business and Human Rights. Modern slavery is addressed as the most serious form of labour-rights abuse within this broader commitment.

Scope

This policy applies to all Westlink Logistics directors, workers, contractors, labour hire personnel, agents, and suppliers across all business functions and operational locations. It extends to all tiers of the supply chain, including subcontractors and their supply networks. It covers Westlink’s labour standards and human rights commitments to its own workforce and its expectations of its supply chain, of which the prohibition of modern slavery is one part. Modern slavery encompasses slavery, servitude, forced labour, deceptive recruiting, debt bondage, forced marriage, and the worst forms of child labour as defined by the Modern Slavery Act 2018 (Cth).

Organisational Context

Westlink Logistics operates heavy haulage, project logistics, and maritime services across Australia, primarily supporting defence, government, resources, and infrastructure sectors. The supply chain includes labour hire providers, transport subcontractors, equipment suppliers, and maintenance service providers — sectors identified by the Australian Government as carrying elevated modern slavery risk.

While Westlink is below the $100 million consolidated revenue threshold for mandatory reporting under the Modern Slavery Act 2018, the organisation maintains this policy as a matter of ethical responsibility. Defence prime contractors and government clients require demonstrable modern slavery due diligence through JOSCAR pre-qualification and contractual flow-down clauses.

Policy Commitments

Westlink Logistics has zero tolerance for modern slavery in any form. Westlink is committed to:

• Assessing modern slavery risks across operations and supply chains, with particular attention to labour hire, subcontracting, and procurement from regions with elevated forced labour indicators.

• Implementing supply chain due diligence proportionate to risk, including pre-qualification questionnaires, contractual modern slavery clauses with right to audit, and the requirement for suppliers to cascade equivalent standards to their own supply chains.

• Providing modern slavery awareness training to workers engaged in procurement, supplier management, and recruitment functions, covering indicators, reporting pathways, and obligations under this policy.

• Maintaining accessible reporting channels for workers, contractors, and third parties to raise concerns about suspected modern slavery without reprisal, per GOV-POL-011 and GOV-POL-018.

• Responding promptly to any identified instances or credible indicators, including engaging with affected persons, reporting to the Australian Federal Police where criminal conduct is suspected, and taking remedial action within the supply chain.

Labour Standards and Human Rights

Beyond the prohibition of modern slavery, Westlink Logistics is committed to upholding labour standards and respecting human rights for its workers and across its supply chain, consistent with the Fair Work Act 2009 (Cth) and the UN Guiding Principles on Business and Human Rights. Westlink is committed to:

• complying with the Fair Work Act 2009 (Cth), the National Employment Standards and applicable awards — including minimum wages, maximum working hours, leave entitlements and the lawful engagement of workers and labour-hire personnel;

• providing a safe and healthy working environment under the WMS work-health-and-safety arrangements (ISO 45001), and managing working hours and fatigue so that workers are not required to work in unsafe conditions;

• treating workers fairly and without unlawful discrimination, harassment or victimisation, and respecting equal opportunity and diversity (GOV-POL-010, GOV-POL-014);

• respecting workers’ freedom of association and their right to join, or not join, an industrial association and to bargain collectively;

• expecting suppliers, subcontractors and labour-hire providers to uphold equivalent labour standards and human rights, and cascading these expectations through pre-qualification and contractual terms; and

• providing accessible grievance and remediation pathways for labour-rights and human-rights concerns, without reprisal (GOV-POL-011, GOV-POL-018).

Responsibilities

Role	Responsibility	When
Chief Executive Officer	Accountable for this policy. Ensures modern slavery risks are considered in strategic planning and resource allocation.	Ongoing; annual management review
QHSE Manager	Coordinates modern slavery risk assessments. Maintains the supplier due diligence framework. Delivers awareness training. Reports on modern slavery metrics through management review.	Ongoing; on supplier onboarding
Managers with Procurement Responsibility	Implement supply chain due diligence within their areas. Include modern slavery clauses in supplier agreements. Escalate concerns promptly.	On procurement; on concern raised
All Workers and Contractors	Report any indicators of modern slavery observed in the course of their work. Complete awareness training when required.	Ongoing; on observation

Review

This policy is reviewed annually as part of the management review cycle, or earlier where significant changes occur to applicable legislation, supply chain composition, or the risk profile. Review considers modern slavery risk assessment outcomes, reported concerns, and JOSCAR evidence requirements. This policy is communicated to all workers and is available to suppliers and interested parties on request.

Applicable Standards and Legislation

• Modern Slavery Act 2018 (Cth)

• UN Guiding Principles on Business and Human Rights (2011)

• Fair Work Act 2009 (Cth)

• ISO 9001:2015 Quality Management Systems — Requirements

• ISO 45001:2018 Occupational Health and Safety Management Systems — Requirements

Related Documents

• GOV-POL-011 Grievance Resolution Policy

• GOV-POL-012 Anti-Bribery and Corruption Policy

• GOV-POL-018 Whistleblower Policy

• QHSE-MAN-001 Westlink Management System Manual