Chain of Responsibility Policy

Purpose

This policy establishes Westlink Logistics’ commitment to compliance with Chain of Responsibility (CoR) obligations under the Road Traffic (Vehicles) Act 2012 (WA) Part 4 for Western Australian operations, and the Heavy Vehicle National Law (HVNL) 2012 for interstate operations. It defines the obligations of all parties in the transport chain and the due diligence requirements of executive officers.

Scope

This policy applies to all Westlink Logistics operations involving heavy vehicles with a gross vehicle mass (GVM) or aggregate trailer mass (ATM) exceeding 4.5 tonnes. It applies to all directors, officers, managers, workers, and contractors who exercise control or influence over a transport activity, including consigning, loading, packing, receiving, driving, operating, scheduling, and managing heavy vehicle transport tasks.

Organisational Context

Westlink Logistics is a heavy haulage, project logistics, and maritime services provider operating across Australia, primarily supporting defence, government, resources, and infrastructure sectors. Heavy vehicle transport is the core of the business. Westlink operates as an operator, consignor, loader, packer, and loading manager — multiple CoR roles simultaneously.

WA is not an HVNL jurisdiction. CoR obligations for WA operations arise from the Road Traffic (Vehicles) Act 2012 Part 4 and the Road Traffic (Administration) Act 2008. When Westlink operates interstate (SA, NSW, Vic, Qld, ACT, Tas), the HVNL 2012 applies, including the primary duty under s.26C and executive officer due diligence under s.26G. WA fatigue management follows the Road Traffic (Vehicles) Regulations 2014, not the HVNL fatigue provisions.

Jurisdictional Application

Westlink determines the applicable CoR regime per transport activity by reference to where the activity is performed. WA law governs activities performed wholly within Western Australia; the HVNL governs activities performed in HVNL jurisdictions (SA, NSW, Vic, Qld, ACT, Tas). The following table sets out the key considerations that differ between the two regimes.

Consideration	WA operations (home jurisdiction)	Interstate operations (HVNL jurisdictions)
Primary duty source	Road Traffic (Vehicles) Act 2012 (WA) Part 4	Heavy Vehicle National Law 2012 s.26C
Executive officer due diligence	Road Traffic (Vehicles) Act 2012 (WA) Part 4	Heavy Vehicle National Law 2012 s.26G
Fatigue management regime	Road Traffic (Vehicles) Regulations 2014 (WA)	HVNL Standard Hours, Basic Fatigue Management (BFM), or Advanced Fatigue Management (AFM)
Chain-party roles recognised	Operator, driver, and parties exercising control or influence over a transport activity	Consignor, consignee, packer, loader, unloader, scheduler, operator, and driver per HVNL s.5
Accident / incident reporting	Road Traffic (Administration) Act 2008 (WA) s.67; Road Traffic Act 1974 (WA) s.75	HVNL notifiable occurrence provisions and the state road authority in the jurisdiction of the event

Where a single transport activity crosses jurisdictions — for example, Westlink loads a heavy vehicle at a WA yard for an interstate journey, or dispatches a vehicle from a WA base onto an interstate route — CoR obligations apply concurrently. WA law governs activities performed in WA (including loading, packing, and scheduling decisions made in WA), and the HVNL governs the on-road movement and associated duties in the destination jurisdictions. Westlink meets concurrent obligations by complying with the stricter applicable control wherever the two regimes overlap.

WA adoption of the HVNL has been under intermittent review. If WA adopts the HVNL or passes equivalent heavy vehicle legislation, this policy will be re-issued to reflect the unified regime and any transitional arrangements.

Policy Commitments

Every party in the heavy vehicle transport chain shares responsibility for safety. Westlink Logistics is committed to:

• Ensuring, so far as is reasonably practicable, the safety of all transport activities by eliminating or minimising risks arising from mass, dimension, loading, speed, fatigue, vehicle condition, and driver fitness.

• Requiring executive officers to exercise personal due diligence: acquiring current knowledge of heavy vehicle safety, understanding the nature of transport risks, ensuring adequate resources and processes, and verifying compliance through regular review and audit.

• Operating all heavy vehicles within prescribed mass and dimension limits, using certified weighing systems, restraining loads per the NTC Load Restraint Guide, and verifying container weights per SOLAS VGM requirements.

• Managing driver fatigue under the applicable regime: WA Road Traffic (Vehicles) Regulations 2014 for WA operations, HVNL fatigue provisions (Standard Hours, BFM, AFM) for interstate operations. Schedulers must not set schedules that cause drivers to exceed work hours or miss required rest breaks.

• Maintaining all heavy vehicles in a safe and roadworthy condition. Pre-departure inspections before each trip. Defects affecting safety must be rectified before operation. Reporting all heavy vehicle incidents immediately per QHSE-PRO-001.

Responsibilities

Role	Responsibility	When
CEO and Executive Officers	Personal due diligence liability under RT(V) Act 2012 and HVNL s.26G. Accountable for adequate resources, systems, and processes for CoR compliance.	Ongoing; annual due diligence review
Operations Manager	Day-to-day implementation of CoR controls across transport operations including scheduling, loading, and fleet maintenance.	Ongoing; per transport activity
QHSE Manager	CoR compliance monitoring, audit, incident investigation, and reporting to executive management.	Ongoing; on incident; quarterly
Managers, Supervisors, Drivers, Loaders, Schedulers	Comply with CoR requirements within their area of control or influence. Report fatigue, defects, and incidents immediately.	Per transport activity; on issue
Contractors and Subcontractors	Comply with this policy as a condition of engagement. Maintain own CoR compliance for activities under their control.	Per engagement; ongoing

Review

This policy is reviewed annually as part of the management review cycle, or when significant changes occur to CoR legislation (including WA adoption of HVNL), fleet composition, or following a serious heavy vehicle incident or regulatory action. This policy is communicated to all relevant workers and is available to the NHVR on request.

Applicable Standards and Legislation

• Road Traffic (Vehicles) Act 2012 (WA) — Part 4

• Road Traffic (Administration) Act 2008 (WA)

• Heavy Vehicle National Law 2012

• National Transport Commission — Load Restraint Guide (3rd edition, 2018)

• Work Health and Safety Act 2020 (WA)

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

• ISO 9001:2015 Quality Management Systems — Requirements

Related Documents

• GOV-POL-002 Work Health and Safety Policy

• GOV-POL-003 Drug and Alcohol Policy

• GOV-POL-005 Fitness for Work Policy

• GOV-POL-017 Stop Work Authority Policy

• QHSE-MAN-001 Westlink Management System Manual

• QHSE-PRO-001 Hazard and Incident Reporting and Investigation Procedure