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Supplier Code of Conduct

 

This Code of Conduct (Code) provides guidance for suppliers, contractors, consultants, service providers and delivery partners (Suppliers) when engaging in business activities with RetireAustralia. This includes the purchasing and supply of goods and services, disposal of goods and equipment, and the contracting out of activities and services that are not core activities of RetireAustralia.

RetireAustralia’s employees are required to maintain high standards of integrity and ethical conduct, consistent with the positions of trust they hold. RetireAustralia relies on its Suppliers to help deliver vital services to the RetireAustralia communities (Residents). This means we depend on our Suppliers to demonstrate the highest environmental, health & safety, social and ethical standards, just as our Residents expect the same standards of RetireAustralia.

We expect that all Suppliers and their employees respect our employees’ commitment to these standards and comply with the same principles whilst undertaking business activities with us.
This Code sets out the minimum expectations that all Suppliers need to satisfy. However, it also encourages Suppliers to go beyond minimum compliance, show leadership, continuously improve performance, innovate and develop competencies, in delivering best value outcomes for our Residents.

This Code is designed to ensure that business relationships between RetireAustralia and Suppliers are fair and productive for all parties by:

  • Providing guidelines on what to expect from RetireAustralia and explaining the mutual obligations, roles and constraints of all parties to an arrangement.
  • Outlining RetireAustralia’s ethical standards and our expectation that Suppliers will comply with these standards in all of their dealings with us.

Fundamental to the Code is that all our Suppliers operate in full compliance of the law, rules and regulations of the countries in which they operate, and in accordance with the specific requirements of RetireAustralia as outlined in this Code.

What you can expect from RetireAustralia

RetireAustralia will endeavour to ensure that its policies, procedures and practices related to the engagement and management of our Suppliers are consistent with best practice and high standards of ethical conduct.

When doing business with Suppliers, RetireAustralia employees are accountable for their actions and are expected to:

  • comply with RetireAustralia’s policies and procedures;
  • deal fairly, honestly and ethically with all individuals and organisations that supply goods or services to RetireAustralia;
  • avoid any conflicts of interest where an employee could be influenced, or could be perceived to be influenced, by a personal interest in carrying out their duty to RetireAustralia;
  • refuse improper rewards or gifts that are intended to, or are likely to create the perception that they may act in a partial manner in the course of their duties;
  • accept responsibility and always be accountable for actions in accordance with delegated functions;
  • always act with care and diligence, utilising organisational resources in a proper manner;
  • observe the law whereby all employees must comply with all legislative, industrial or administrative requirements relevant to their position and any guidelines issued by RetireAustralia concerning the performance of their duties;
  • encourage fair competition whilst seeking value for money;
  • ensure all relevant potential Suppliers are given equal access to information and opportunities to submit bids;
  • ensure all procurement or disposal activities and decisions are fully and clearly documented to provide an effective internal audit trail, allowing for effective performance review of contracts;
  • endeavour to ensure tenders will not be called unless RetireAustralia has a firm intention to proceed to contract;
  • endeavour to ensure RetireAustralia will not disclose confidential or personal information unless legally compelled or able to do so;
  • present an official RetireAustralia purchase order, work order, (order) credit card or petty cash when procuring goods and services on behalf of RetireAustralia; and
  • purchase, wherever reasonably commercially feasible, energy efficient equipment, products containing recycled materials and environmentally friendly products.

When doing business with RetireAustralia Suppliers are expected to:

  • comply with RetireAustralia’s policies & procedures, handbooks and any guidelines as provided to them;
  • respect and comply with the terms and conditions as contained in any documents as provided by and as agreed with RetireAustralia;
  • refrain from supplying goods or services to RetireAustralia until such time as a Purchase Order, Work Order (Order) or Contract has been provided to you;
  • provide accurate and reliable advice and information when requested;
  • declare to RetireAustralia any actual, potential or perceived conflicts of interest as soon as they are arise;
  • act ethically, fairly and honestly in all dealings with RetireAustralia;
  • take all reasonable measures to prevent the disclosure of confidential RetireAustralia information;
  • refrain from engaging in any form of collusive or other anti-competitive practice;
  • not offer inducements or incentives (such as money, gifts or offers of entertainment or employment opportunities) to RetireAustralia employees where this might influence, or be seen to influence, the conduct of their (Note that offers of a gift during or prior to the tendering process are strictly prohibited);
  • refrain from discussing RetireAustralia business or information with the media unless prior explicit consent has been given by RetireAustralia;
  • ensure safe work practices are adhered to in order to minimise risks to persons and or property; and
  • assist RetireAustralia to prevent unethical practices in our business relationships and dealings.

Why is compliance important?

By complying with this Code, Suppliers will be able to advance their business objectives and interests in a fair and ethical manner. Compliance with this Code will not pose a disadvantage to any Suppliers, with all RetireAustralia Suppliers required to comply. With the likely outcome of adherence being enhanced reputation and repeat business.

Parties should also be aware of the consequences of not complying with RetireAustralia’s ethical requirements. Demonstrated corrupt or unethical conduct could lead to:

  • termination of any Purchase Orders, Work Orders (Orders) or Contracts;
  • removal from RetireAustralia’s Supplier database;
  • damage to reputation;
  • potential long term loss of future work due to damage to reputation;
  • formal investigation for corruption and other offences; and/or
  • matters being referred for criminal investigation.

RetireAustralia has a responsibility to operate in a transparent and ethical manner for our Residents. We are committed to the highest standards of corporate governance in delivering our services. We take accountability seriously, and will investigate and address any issues or breaches relating to this Code.

RetireAustralia’s key business principles of conduct

The key business principles for conduct set the minimum appropriate levels of behaviour that support RetireAustralia’s company vision, values and purpose.

  1. Competing fairly and ethically

    Our commitment

    We protect the integrity of a competitive market using fair, ethical and lawful business practices. Competition helps grow and sustain business by enabling efficiency, innovation and tangible outcomes such as lower prices and improved quality in goods and services.

    Our expectation

    That our Suppliers will avoid anti-competitive conduct that reduces or eliminates competition; and abide by Consumer Laws as relevant to the jurisdiction being operated in.

  2. Value for money

    Our commitment

    The principle of value for money is at the core of all RetireAustralia’s business relationships with Suppliers. Value for money does not mean the lowest price. To achieve value for money RetireAustralia will take into consideration all relevant factors including initial cost, whole-of-life costs (performance, maintenance and disposal), timelines, quality, and reliability.
    Part of obtaining best value for money also includes ensuring all our business relationships are honest, ethical, fair, transparent and consistent.

    Our expectation

    That our Suppliers will be fair and transparent in all transactions and business dealings.

  3. Environment and Sustainable Practices

    Our commitment

    We are committed to embedding sustainability in our business and the communities we serve for positive social, environmental and financial outcomes, using appropriate preventative measures where necessary.
    We recognise the importance of protecting human rights, and oppose all forms of slavery and forced labour.

    Our expectation

    That our Suppliers:
    • use resources efficiently and implement sustainable improvements;
    • actively know and comply with environmental standards and regulations;
    • avoid environment harm by exercising care with hazardous materials;
    • compliance with all relevant laws and regulations regarding environmental management;
    • not engage in or be complicit in any practices of slavery;
    • implement an environmental management system and reporting procedure appropriate for the Supplier’s operations; and
    • monitor performance and implement best practice solutions to continuously reduce the Supplier’s adverse environmental impact.

  4. Maintain a safe and healthy workplace

    Our commitment

    The safety and health of everyone who works for or with us prevails over all operational and financial decisions and actions. Our expectation is that everyone takes responsibility for safety when performing their role, engaging with others and operating our business.

    Our expectation

    That our Suppliers:
    • comply with all relevant laws and regulations with regard to health and safety;
    • be fit for work physically, emotionally and mentally;
    • identify, assess, eliminate, or control hazards using risk protocols;
    • be inducted and know how to implement emergency procedures;
    • immediately stop unsafe or potentially unsafe work and promptly report these conditions to the immediate manager and RetireAustralia;
    • have a written health and safety policy or equivalent document (and or system) that employees are aware of and understand; and
    • implement, monitor and continuously improve the performance of health and safety through the Supplier’s management system.

  5. Modern slavery, labour & human rights

    Our commitment

    RetireAustralia respects human rights and is opposed to, and will oppose, all forms of slavery. RetireAustralia expects that all Suppliers (and the businesses that form their supply chains) respect human rights and ensure that they do not engage in or are complicit with human rights abuses, including slavery.

    Our expectation

    That our Suppliers:
    • must take all reasonable efforts to ensure that they, and organisations in their supply chain, are not engaged in, benefitting from or complicit with, human rights abuses such as coercion, involuntary and underage labour or modern slavery practice as defined in the Modern Slavery Act 2018. This includes undertaking risk assessments to identify the risk of human rights breaches, particularly in vulnerable industries.
    • abide by all relevant laws and regulations including the Modern Slavery Act 2018 (Cth), the Modern Slavery Act 2018 (NSW) and any other anti-Modern Slavery laws or regulations in force in Australia; and
    • respect and support internationally recognised human rights as outlined in the UN Universal Declaration of Human Rights, the International Covenant on Economic, Social and Cultural Rights, International Covenant on Civil and Political Rights, International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work.

    In addition, RetireAustralia expects that our Suppliers ensure that their related entities and the members of their supply chains do the same.

  6. Diversity and inclusion

    Our commitment

    RetireAustralia believes in diversity and valuing the people that are at the heart of our services. We are committed to ensuring that our workforce is as diverse as the communities we serve.

    Our expectation

    That our Suppliers can demonstrate that they are committed to employing and developing a diverse and inclusive workforce.

  7. Community engagement

    Our commitment

    RetireAustralia is committed to developing effective working relationships with our Residents, community and stakeholders across all stages of a project lifecycle, from planning through to construction, maintenance and operations.

    Our Suppliers must
    • be open and honest;
    • listen to and respond to the opinions of the Residents, community and stakeholder representatives;
    • have appropriate systems to monitor engagement;
    • develop project specific and effective engagement plans,
    • provide feedback to the Residents, community and stakeholders on how their input was addressed in the decision-making process; and
    • learn from engagement experiences and continue to improve performance.

  8. Gifts, benefits and hospitality

    RetireAustralia employees are not to solicit incentives, gifts or benefits in connection with their employment. Suppliers should refrain from offering any such ‘incentives’ to RetireAustralia employees and all such offers of significant gifts are to be reported in line with the RetireAustralia Gifts and benefits Policy. RetireAustralia employees are not permitted to ask for any reward or incentive for doing their job.

    RetireAustralia only permits its employees to accept gifts if:
    • gifts are token and of nominal value;
    • the offer is not from a potential supplier during the procurement/tendering process; and
    • the offer is not considered to be inappropriate.

    Gifts of cash or negotiable instruments of any value are prohibited

  9. Conflicts of interest

    A conflict of interest is a conflict or incompatibility between a RetireAustralia employee’s personal interest and the impartial fulfilment of their RetireAustralia duties. All RetireAustralia employees are required to disclose any actual, potential or perceived conflicts of interest and RetireAustralia extends this requirement to all of its Suppliers.

  10. Confidential information

    RetireAustralia recognises the importance of the right to privacy and protecting confidential information and are committed to proactively manage data and data security threats.

    Our Suppliers must treat any RetireAustralia information that is not in the public domain as confidential unless otherwise indicated.

    Confidential information includes customer data, personal data, commercial performance data, corporate strategies and business plans, marketing and pricing strategies, trade secrets, intellectual property, and the like, in any form including electronic or magnetic forms.

    Inappropriate use of information may affect our reputation and competitive position resulting in a breach of privacy, competition laws or breach of contract.Protecting the personal information of our employees, Suppliers and Residents is important as it relates to an individual being identified or located by that information alone or together with other information in our possession.

 

Reporting violations of the Code of Conduct

If you have any questions regarding this Code or wish to provide information about suspected corrupt conduct, please contact RetireAustralia directly.

If you observe, or reasonably suspect, conduct that may be contrary to this Code, whether it be unethical or illegal, you must report it immediately to RetireAustralia’s Chief Financial Officer.

 

Penalties for breach of the Code of Conduct

RetireAustralia takes breaches of the Code very seriously with consequences ranging from disciplinary action, the appointment of an external investigator through to termination of employment.
We reserve the right to inform the appropriate authorities where it is considered that there has been criminal activity or an apparent breach of law.

Any conduct of a Supplier that does not comply with the Code will jeopardise their business relationship with us and the possible consequences include termination of contract.