Gifts, Hospitality and Conflicts of Interest Policy

Purpose

This policy establishes Westlink Logistics’ requirements for the management of gifts, hospitality, and conflicts of interest. It supports the adequate procedures defence under Criminal Code Act 1995 (Cth) Div.70 and supplements GOV-POL-012 (Anti-Bribery and Corruption Policy).

Scope

This policy applies to all Westlink Logistics directors, officers, workers, contractors, consultants, and agents. It covers all gifts, hospitality, entertainment, and other benefits offered, given, or received in the course of business, and all actual, perceived, or potential conflicts of interest.

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 business involves government procurement and defence contracts where gifts and hospitality are subject to heightened regulatory scrutiny.

The organisation holds DISP membership and is subject to JOSCAR pre-qualification. The PSPF and Defence procurement rules impose strict limits on gifts and hospitality involving government officials and Defence personnel. This policy is informed by ISO 37001 anti-bribery management principles.

Policy Commitments

Westlink Logistics requires all personnel to act with integrity, transparency, and in the best interests of the company. Westlink is committed to:

• Applying approval thresholds for all gifts and hospitality: up to $100 — no prior approval required but must be recorded; $100–$500 — prior written approval from line manager; over $500 — prior written CEO approval with business justification. All values assessed per-occasion and cumulative per-annum per external party.

• Prohibiting regardless of value: cash or cash equivalents, gifts during tender or procurement processes, lavish or disproportionate items, anything that could be perceived as an inducement, and anything that contravenes a client’s or government agency’s own gifts policy.

• Exercising heightened diligence in government and Defence dealings. PSPF and DISP standards typically prohibit all gifts other than items of nominal value such as branded promotional materials. Personnel must comply with the applicable agency’s requirements.

• Recording all gifts and hospitality in the Gifts and Hospitality Register within five business days, regardless of value. The register is maintained by the QHSE Manager and reviewed by the CEO quarterly.

• Requiring all personnel to identify and disclose in writing any actual, potential, or perceived conflict of interest to their line manager and the CEO. Personnel must not participate in any decision where they have an undisclosed conflict. Related party transactions must be on arm’s length terms with prior CEO disclosure.

Responsibilities

Review

This policy is reviewed annually as part of the management review cycle, or when significant changes occur to applicable legislation, business relationships, or the nature of contracts held. This policy is communicated to all workers and is available to interested parties on request.

Applicable Standards and Legislation

• Criminal Code Act 1995 (Cth)

• Corporations Act 2001 (Cth)

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

• Protective Security Policy Framework (PSPF)

• Defence Industry Security Program (DISP) — Security Governance Framework

• ISO 9001:2015 Quality Management Systems — Requirements

Related Documents

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

• GOV-POL-018 Whistleblower Policy

• QHSE-MAN-001 Westlink Management System Manual