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Compliance Policy

Scope

This policy applies to all Vanderfield Pty. Ltd. (Vanderfield) business operations and its subsidiaries, employees and managers.

Responsibilities

Chief Executive Officer – Holds overall responsibility for all compliance matters and the implementation and review of this policy and related procedures.

Chief Financial Officer – Holds responsibility and authority for the role of Compliance Officer for Vanderfield and has a direct report to the Chief Executive Officer.

Branch Managers – Have responsibility for ensuring the strict application of this policy by staff in their branch across all Vanderfield’s business areas.

Department Heads – Have whole of company responsibility for ensuring strict application of this policy in their area of responsibility.

All Employees and Agents – Have responsibility for adhering to this policy and related procedures and processes.

Policy

Vanderfield recognizes and accepts its obligations for the betterment of the company and its operations through nurturing a culture of compliance at all levels.  Vanderfield is unequivocal in its determination to ensure that its operations meet and comply with all applicable laws, standards, regulations and company policies and procedures. This includes application of this policy with any agents, suppliers and independent contractors who may be engaged by the company.

Vanderfield is committed to the development, implementation, maintenance and continual improvement of its Compliance Program which is based on the relevant aspects of Australian Standard 3806 – Compliance Programs.

The aim of this policy is to ensure that Vanderfield and its employees and agents comply with applicable laws, regulations, standards, codes and operational procedures and instructions.

Specifically this policy addresses compliance to the requirements of the Trade Practices Act (1974).

Our commitment to this policy means:

  1. That the Chief Financial Officer or other nominated senior staff member performs the role of Compliance Officer and carries out the duties detailed in the relevant position description.
  2. The Compliance Officer has direct reporting responsibility to the Chief Executive Officer on all compliance matters.
  3. The Chief Executive Officer has reporting responsibility to the Vanderfield Board of Directors on all compliance related matters.
  4. That periodic assessment of compliance will be carried out to ensure the effectiveness of the compliance program and maintenance of this policy.
  5. That senior management will exhibit a positive attitude towards compliance and will opportunistically reinforce this attitude during presentations to and communication with company staff.
  6. That relevant employees will be provided with regular training in Trade Practices Act compliance.
  7. That employees have access to material resources such as applicable standards, company policy and procedures and other TPA related resources to assist them with compliance.
  8. That all relevant Vanderfield staff are made fully aware that they must not enter into any discussion, contract, arrangement or understanding with competitors that involves:
  • price fixing
  • bid rigging
  • allocating customers, suppliers or territories, or
  • restrictions to output.
  1. That TPA compliance forms an integral part of Vanderfield’s induction for all new employees.
  2. That management, sales, customer service and other relevant staff will be provided with initial training and periodic refresher training in the Trade Practices Act to ensure behavioural compliance with the Act.
  3. That all Vanderfield employees are made aware of their requirement to report any compliance related issues, including any Trade Practices compliance concerns or issues, to the Compliance Officer as soon as they become aware of the issue or have cause for concern.
  4. That all complaints, including complaints that may relate to the Trade Practices Act, are handled in accordance with Vanderfield’s Complaints Handling Procedure.

 

  1. That disciplinary action will be taken against employees who deliberately and knowingly breach the Trade Practices Act and that Vanderfield will not provide indemnity for these employees.
  2. That whistleblowers who raise potential breaches of the Trade Practices Act or other applicable legislation will be guaranteed protection from prosecutions or disadvantage, to the extent that is allowable by law, and that the information provided will be treated in a secure and confidential manner.

Authorisation

This policy was first authorised on 29th October 2009.

Bruce Vandersee
Managing Director
29th October 2009