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← Back to Document LibrarySexual Harassment Prevention Policy
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Purpose
This policy establishes Westlink Logistics’ commitment to a workplace free from sexual harassment. It gives effect to the positive duty under section 47C of the Sex Discrimination Act 1984 (Cth), as introduced by the Respect@Work Act 2022, which requires Westlink to take reasonable and proportionate measures to eliminate sexual harassment, sex discrimination, and related unlawful conduct as far as possible.
Scope
This policy applies to all Westlink Logistics directors, workers, contractors, labour hire workers, volunteers, and visitors. It covers all work-related settings including offices, operational sites, vehicles, client premises, work-related travel, social functions, and online or digital communications connected to the workplace.
Organisational Context
Westlink Logistics operates heavy haulage, project logistics, and maritime services across Australia, primarily supporting defence, government, resources, and infrastructure sectors. The workforce includes workers in isolated and remote environments, on vessels, and in male-dominated operational settings — risk factors identified by the AHRC as elevating sexual harassment risk.
The organisation holds Defence Industry Security Program (DISP) membership and is subject to JOSCAR pre-qualification. Sexual harassment prevention is integrated into the WMS as a psychosocial hazard under ISO 45001 cl.6.1.2 and the WHS Act 2020 (WA) s.19.
Policy Commitments
Westlink Logistics has zero tolerance for sexual harassment in any form. In compliance with the positive duty under s.47C, Westlink commits to proactive prevention aligned with the seven AHRC standards:
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Leadership — Senior leadership demonstrates visible commitment to preventing sexual harassment. The CEO and senior managers set behavioural expectations, allocate adequate resources, and hold themselves accountable for positive duty compliance.
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Culture — Westlink fosters a culture of respect, safety, and inclusion where sexual harassment is not tolerated. All workers are expected to model respectful behaviour and challenge inappropriate conduct.
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Knowledge — All workers and contractors receive training on sexual harassment prevention at induction and through regular refresher programs, covering identification of unlawful conduct, bystander intervention, and reporting channels.
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Risk Management — Sexual harassment risks are identified, assessed, and controlled through the WMS risk framework. Risk factors including power imbalances, isolated work environments, alcohol at work events, and workforce demographics are evaluated and mitigated.
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Support — Appropriate support is provided to any person who experiences or witnesses sexual harassment, including access to the Employee Assistance Program, reasonable workplace adjustments, and referral to external services, regardless of whether a formal complaint is made.
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Reporting and Response — Multiple accessible reporting channels are maintained. All reports are treated confidentially and investigated promptly, impartially, and with procedural fairness for all parties. Substantiated complaints result in appropriate action up to and including termination.
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Monitoring and Evaluation — Westlink monitors the effectiveness of prevention measures through data on reports, outcomes, training completion, and workplace culture. Findings are reported to senior management and used to drive continual improvement.
Victimisation or reprisal against any person who makes a complaint, provides information, or is involved in a complaint process is strictly prohibited and constitutes a separate breach of this policy and the Sex Discrimination Act 1984.
Responsibilities
| Role | Responsibility | When |
|---|---|---|
| Chief Executive Officer | Accountable for this policy and positive duty compliance. Allocates resources for prevention. Sets leadership example of expected behaviour. | Ongoing; annual management review |
| QHSE Manager | Coordinates sexual harassment risk assessments. Maintains training records. Monitors complaint data. Reports on prevention effectiveness through management review. | Ongoing; on complaint; quarterly reporting |
| Managers and Supervisors | Model respectful behaviour. Respond promptly to reports. Ensure their teams complete required training. Escalate matters appropriately. | Ongoing; on report received |
| All Workers and Contractors | Treat others with dignity and respect. Refrain from sexual harassment. Report any incidents experienced or witnessed. Cooperate with investigations. | Ongoing; on incident |
Review
This policy is reviewed annually as part of the management review cycle, or following any sexual harassment complaint, significant legislative change, or update to AHRC guidance. Reviews assess prevention measures against the seven AHRC positive duty standards. This policy is communicated to all workers at induction and is available on the WMS.
Applicable Standards and Legislation
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Sex Discrimination Act 1984 (Cth)
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Anti-Discrimination and Human Rights Legislation Amendment (Respect at Work) Act 2022 (Cth)
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AHRC Guidelines for Complying with the Positive Duty under the Sex Discrimination Act 1984 (2023)
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Fair Work Act 2009 (Cth)
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Equal Opportunity Act 1984 (WA)
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Work Health and Safety Act 2020 (WA)
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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-002 Work Health and Safety Policy
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GOV-POL-006 Workplace Behaviour Policy
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GOV-POL-009 Equal Employment Opportunity Policy
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GOV-POL-010 Inclusion and Diversity Policy
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GOV-POL-011 Grievance Resolution Policy
Compliance coverage — cited by 35 requirements across 5 frameworks
Anti-Discrimination — Sex/Age/Race/Disability Discrimination Acts (Cth) + AHRC Act complaints + Equal Opportunity Act 1984 (WA)(2)
| Requirement | Clause | Coverage | Severity | Notes |
|---|---|---|---|---|
| SDA-8A-01 | SDA s.8A | Partial | Low | §Organisational ContextRisk factors (male-dominated settings, isolated work, alcohol at events) are common to multi-attribute hostile environments; GOV-POL-014 Commitment 4 (Risk Management) addresses these. |
| SDA-47A-01 | SDA s.47A | Full | §Policy CommitmentsClosing paragraph of Policy Commitments prohibits victimisation/reprisal as a separate breach of the Sex Discrimination Act. |
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(4)
| Requirement | Clause | Coverage | Severity | Notes |
|---|---|---|---|---|
| FW-527A-01 | FW Act s.527A | Partial | Medium | §PurposeSexual Harassment Prevention policy is structured around the SDA / Respect@Work positive duty regime that Part 3-5A enforces in parallel — the s.527A guide is the navigational anchor for the FWC enforcement route. |
| FW-527D-01 | FW Act s.527D | Partial | Medium | §ScopePolicy scope extends to all workers, contractors, labour hire, volunteers and visitors, and to all work-related settings including offices, sites, vehicles, client premises, work travel, social functions and digital communications — captures the 'in connection with work' scope of s.527D(1) which is broader than 'at work'. |
| FW-527E-01 | FW Act s.527E | Partial | Medium | §Policy CommitmentsSeven AHRC standards as policy commitments — collectively constitute the documented 'all reasonable steps' for the s.527E defence (mirrors the SDA s.106(2) defence at the SDA-106-01 row). |
| FW-527F-01 | FW Act s.527F | Full | §Policy CommitmentsCommitment 6 (Reporting and Response) commits to multiple accessible reporting channels including external — the FWC under Part 3-5A is one such pathway. Should explicitly name FWC s.527F applications in the Reporting Channels evidence trail. |
ISO 45001:2018(10)
| Requirement | Clause | Coverage | Severity | Notes |
|---|---|---|---|---|
| ISO45001-2018-4.1-01 | 4.1 | Full | §Organisational ContextOperational risk factors for sexual harassment (remote sites, male-dominated workforce) — cl.4.1. | |
| ISO45001-2018-5.1-01 | 5.1 | Partial | §ResponsibilitiesCommitment 1 Leadership + CEO positive duty accountability — cl.5.1 leadership and commitment. | |
| ISO45001-2018-5.2-01 | 5.2 | Full | §ScopeSexual harassment prevention is one operative expression of the OH&S policy commitment — cl.5.2. | |
| ISO45001-2018-5.2-02 | 5.2 | Full | §ReviewPolicy available on WMS — cl.5.2(e/f) availability to relevant interested parties. | |
| ISO45001-2018-5.4-01 | 5.4 | Partial | §Policy CommitmentsCommitment 2 Culture — cl.5.4 consultation and participation. | |
| ISO45001-2018-6.1.2.2-01 | 6.1.2.2 | Partial | §Organisational ContextPsychosocial hazard identification — sexual harassment is the named psychosocial hazard class under cl.6.1.2.2. | |
| ISO45001-2018-7.2-01 | 7.2 | Full | §Policy CommitmentsCommitment 3 Knowledge — cl.7.2 competence (training in sexual harassment prevention). | |
| ISO45001-2018-7.3-01 | 7.3 | Full | §Policy CommitmentsCommitment 3 Knowledge — cl.7.3 awareness (worker awareness of harassment behaviours and reporting). | |
| ISO45001-2018-9.1.1-01 | 9.1.1 | Full | §Policy CommitmentsCommitment 7 Monitoring and Evaluation — cl.9.1.1 monitoring/measurement/analysis/evaluation. | |
| ISO45001-2018-9.3-01 | 9.3 | Full | §ReviewAnnual review against 7 AHRC standards — cl.9.3 management review. |
Sex Discrimination Act 1984 (Cth) — Positive Duty + AHRC Seven Standards(18)
| Requirement | Clause | Coverage | Severity | Notes |
|---|---|---|---|---|
| SDA-28A-01 | SDA s.28A | Full | §PurposePolicy adopts statutory definitions by reference (commitment to a workplace free from sexual harassment 'as defined by the SDA'); zero-tolerance language operationalises the s.28A test. | |
| SDA-28AA-01 | SDA s.28AA | Partial | Medium | §Policy CommitmentsZero-tolerance commitment expressly covers sexual harassment 'in any form' — captures sex-based harassment without requiring sexual-nature conduct; respectful-behaviour expectations in Commitment 2 (Culture) directly address the demeaning-conduct standard. |
| SDA-28B-01 | SDA s.28B | Full | §ScopePolicy expressly extends to directors, workers, contractors, labour hire workers, volunteers and visitors — covers each relationship class within s.28B. | |
| SDA-28M-01 | SDA s.28M | Partial | Low | §Organisational ContextPolicy identifies male-dominated operational settings, isolated/remote environments, and alcohol at work events as elevated risk factors per AHRC guidance — directly addresses hostile-environment risk factors at the organisational-context level. |
| SDA-47C-01 | SDA s.47C(1) | Full | §PurposePolicy Purpose expressly gives effect to s.47C and commits Westlink to take reasonable and proportionate measures to eliminate sexual harassment, sex discrimination and related unlawful conduct as far as possible. | |
| SDA-47C-02 | SDA s.47C(2) | Full | §Policy CommitmentsPolicy commitments are structured around the seven AHRC Standards which operationalise the s.47C(2) categories: Leadership + Culture (47C(2)(c)), Knowledge (47C(2)(c)), Risk Management (47C(2)(a) prevention), Support (47C(2)(d)), Reporting and Response (47C(2)(e)), Monitoring and Evaluation (47C(2)(b) coordination/review). Accountability and consequences (47C(2)(f)) addressed via Reporting and Response commitment ('substantiated complaints result in appropriate action up to and including termination') and the Responsibilities table. | |
| SDA-47C-03 | SDA s.47C(6) | Partial | Medium | §Organisational ContextOrganisational Context section identifies operational scale (heavy haulage, project logistics, maritime services across Australia), workforce profile (workers in isolated/remote environments, vessels, male-dominated operational settings) and elevated-risk factors — provides the size, nature, likelihood and potential-harm context to which 'reasonable and proportionate' is calibrated. |
| SDA-94-01 | SDA s.94 | Full | §Policy CommitmentsClosing paragraph of Policy Commitments expressly prohibits victimisation or reprisal against any person who makes a complaint, provides information or is involved in a complaint process — names this as a separate breach of policy and the Sex Discrimination Act. | |
| SDA-105-01 | SDA s.105 | Partial | Low | §ResponsibilitiesManagers and Supervisors row obliges them to model respectful behaviour, respond promptly to reports, ensure team training, and escalate appropriately — operationalises the duty not to instruct, induce, aid or permit unlawful conduct. |
| SDA-106-01 | SDA s.106 | Partial | Medium | §Policy CommitmentsThe seven-standard positive-duty action plan structured into the Policy Commitments is the substantive 'all reasonable steps' evidence — leadership, culture, knowledge (training), risk management, support, reporting/response, monitoring. Treated as the PCBU's reasonable-and-proportionate measures under s.47C, which simultaneously supports the s.106(2) defence. |
| AHRC-PD-01 | AHRC Guidelines for Complying with the Positive Duty (2023) — Standard 1 Leadership | Full | §Policy CommitmentsCommitment 1 (Leadership) — CEO and senior managers set behavioural expectations, allocate resources, hold themselves accountable for positive duty compliance. | |
| AHRC-PD-02 | AHRC Guidelines for Complying with the Positive Duty (2023) — Standard 2 Culture | Full | §Policy CommitmentsCommitment 2 (Culture) — fosters culture of respect, safety and inclusion where sexual harassment is not tolerated; workers expected to model respectful behaviour and challenge inappropriate conduct. | |
| AHRC-PD-03 | AHRC Guidelines for Complying with the Positive Duty (2023) — Standard 3 Knowledge | Partial | Medium | §Policy CommitmentsCommitment 3 (Knowledge) — all workers and contractors receive training at induction and through regular refresher programs covering identification of unlawful conduct, bystander intervention and reporting channels. |
| AHRC-PD-04 | AHRC Guidelines for Complying with the Positive Duty (2023) — Standard 4 Risk management | Full | §Policy CommitmentsCommitment 4 (Risk Management) — risks identified, assessed and controlled through WMS risk framework; risk factors including power imbalances, isolated work environments, alcohol at work events and workforce demographics are evaluated and mitigated. | |
| AHRC-PD-05 | AHRC Guidelines for Complying with the Positive Duty (2023) — Standard 5 Support | Full | §Policy CommitmentsCommitment 5 (Support) — appropriate support including access to Employee Assistance Program, reasonable workplace adjustments, and referral to external services, regardless of whether a formal complaint is made. | |
| AHRC-PD-06 | AHRC Guidelines for Complying with the Positive Duty (2023) — Standard 6 Reporting and response | Partial | Medium | §Policy CommitmentsCommitment 6 (Reporting and Response) — multiple accessible reporting channels; reports treated confidentially and investigated promptly, impartially and with procedural fairness; substantiated complaints result in appropriate action up to termination. |
| AHRC-PD-07 | AHRC Guidelines for Complying with the Positive Duty (2023) — Standard 7 Monitoring and evaluation | Partial | Medium | §Policy CommitmentsCommitment 7 (Monitoring and Evaluation) — monitors effectiveness of prevention measures through data on reports, outcomes, training completion and workplace culture; findings reported to senior management and used to drive continual improvement. |
| AHRC-CEP-01 | AHRC Positive Duty Compliance and Enforcement Policy (4 December 2025) | Referenced-only | §ReviewPolicy review trigger includes 'update to AHRC guidance' — captures changes in AHRC's published compliance and enforcement approach. |
Work Health and Safety Act 2020 (WA)(1)
| Requirement | Clause | Coverage | Severity | Notes |
|---|---|---|---|---|
| WHS-WA-19-01 | WHS Act 2020 (WA) s.19 | Full | §Organisational ContextSexual harassment classified as psychosocial hazard under WHS Act 2020 (WA) s.19 PCBU primary duty. |
Declared compliance references (35)
AHRC-CEP-01AHRC-PD-01AHRC-PD-02AHRC-PD-03AHRC-PD-04AHRC-PD-05AHRC-PD-06AHRC-PD-07FW-527A-01FW-527D-01FW-527E-01FW-527F-01ISO45001-2018-4.1-01ISO45001-2018-5.1-01ISO45001-2018-5.2-01ISO45001-2018-5.2-02ISO45001-2018-5.4-01ISO45001-2018-6.1.2.2-01ISO45001-2018-7.2-01ISO45001-2018-7.3-01ISO45001-2018-9.1.1-01ISO45001-2018-9.3-01WHS-WA-19-01SDA-105-01SDA-106-01SDA-28A-01SDA-28AA-01SDA-28B-01SDA-28M-01SDA-47A-01SDA-47C-01SDA-47C-02SDA-47C-03SDA-8A-01SDA-94-01
Document Revision Summary
| Rev | Issued | Document Ref | Document Title | Author | Approved |
|---|---|---|---|---|---|
| 1 | 24/05/2021 | WLK-GBL-GOV-POL-014 | Sexual Harassment Prevention Policy | CEO (JDG) | CEO (JDG) |
| 2 | 09/03/2026 | GOV-POL-014 | Sexual Harassment Prevention Policy | FTM (CF) | CEO (JDG) |
| 3 | 16/03/2026 | GOV-POL-014 | Sexual Harassment Prevention Policy | FTM (CF) | CEO (JDG) |
Document Revision Details
| Rev | Purpose of revision and changes made |
|---|---|
| 3 | Added Organisational Context section — identifies Westlink's operational risk factors per AHRC guidance: isolated/remote environments, vessel operations, and male-dominated settings.• Retained 7 AHRC positive duty standards as policy commitments — this is a recognised audit framework (Leadership, Culture, Knowledge, Risk Management, Support, Reporting, Monitoring).• Tightened commitment language — removed some procedural detail (cultural assessment timing, specific training content) while retaining all 7 standards.• 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 WHS, Behaviour, EEO, Inclusion, and Grievance policies. Removed GOV-POL-016 (Social Media) and HR-PRO-001 (Screening) as not directly relevant.• Added ISO 45001 and ISO 9001 to applicable standards — sexual harassment is a psychosocial hazard under cl.6.1.2.• Added requirements traceability matrix mapping policy elements to SDA s.47C, AHRC standards, WHS Act, and ISO clauses. |