1.  Introduction

References to “AVPartners” in this Code of Conduct for Suppliers (Code) includes AVPartners Pty Ltd and related entities (as defined pursuant to the Corporations Act 2001 (Cth)). When referred to in this Code, “Suppliers” means any entity that supplies goods or services to AVPartners and “Workers” includes employees, contractors, agents, student and temporary staff of a Supplier. At AVPartners, we are committed to:

1.1   complying with all applicable laws and regulations;

1.2   upholding health and safety, human rights and labour standards;

1.3   protecting the environment; and

1.4   encouraging compliance with this Code and transparency in our supply chains, in our own operations as well as in relation to our business partners.

This Code sets out the minimum standards of conduct that AVPartners expects its suppliers to meet in the above areas. 

2.  AVPartners expects its suppliers to read, understand and ensure that their business and supply chain meet the standards in this Code. Legal compliance and integrity

Suppliers must comply with all applicable laws and regulations in the countries where they operate, in particular:

2.1   Prohibition of corruption and bribery: Suppliers must not engage in or tolerate any form of corruption or bribery, in particular any payment, “kickback” or other form of benefit conferred for the purpose of influencing decision making. This applies even if it is legal or common practice in a country. Suppliers must comply with applicable anti-bribery and anti-corruption laws and must have adequate policies and procedures in place to monitor compliance with such laws. 

2.2   Competition and antitrust: Suppliers must conduct business in compliance with all applicable competition/antitrust laws and regulations and disclose information in accordance with the applicable laws and regulations. Suppliers must also comply with applicable laws and regulations relating to sanctions, export, re-export, import and trade controls. 

2.3   Conflict of interest: Suppliers must avoid all conflicts of interest or situations giving the appearance of a potential conflict of interest in business dealings with AVPartners or third parties.

2.4   Confidentiality: Suppliers must keep AVPartners’ business, financial and technical data as well as business correspondence confidential; do not misappropriate AVPartners’ or other entities’ tangible or intellectual property. Any transfer of technology and knowhow must be handled in a manner that protects intellectual property rights. 

3.  Health and safety

Suppliers play a vital role in our commitment to keep our workers, customers and the public safe, and must:

3.1   Comply with all applicable laws and regulations on work health and safety.

3.2   Set up and follow a reasonable work health and safety management system including:

3.2.1   taking reasonable steps to identify workplace hazards and minimise the risk of workplace injury, illness and disease for Workers;

3.2.2   providing appropriate equipment, resources, instruction, education and training for Workers to safely carry out their duties;

3.2.3   having training and emergency equipment in place to effectively manage incidents and emergencies; and

3.2.4   ensuring facilities for workers are clean and safe;

3.3   Commit to continuous improvements of work health and safety.

4.  Human rights and labour standards

AVPartners expect Suppliers to respect and support the protection of human rights of Workers, including  by the following means:

4.1  Working time: Suppliers must comply with the applicable law and sector-specific labour regulations concerning working time, including overtime laws.

4.2  Wages and benefits: Suppliers must provide wages and benefits as prescribed by the respective national laws, including minimum wage legislation, and in line with existing practice in the industry and local labour markets. Suppliers must not use deductions from wages as a disciplinary measure and must pay Workers promptly. 

4.3. Non-discrimination and fairness: Suppliers must apply the principles of equal opportunity and fair treatment. Zero-tolerance of any form of discrimination or verbal or physical harassment of employees is required. Suppliers must also respect Workers freedom of association and must not discriminate, harass, intimidate or retaliate against Workers from participating in trade union activities. 

4.4  No forced labour: Suppliers must have zero-tolerance to any form of forced labour, including forced prison labour, bonded labour, slave labour or any form of human trafficking. Workers must not be required to surrender any personal document as a condition of employment or be required to pay employers’ or agents’ recruitment or any other fee for their employment. 

4.5. No child labour: Use of child labour is strictly prohibited and the minimum age for employment in accordance with the relevant legislation is to be adhered to. 

5.  Environmental protection

Suppliers must minimise adverse environmental impacts of their operations by:

5.1  Complying with all applicable laws and regulations and international standards relating to the protection and preservation of the environment.

5.2  Delivering electrical or electronic equipment in line with relevant regulations in the regions of operation and of intended equipment use. 

5.3  Committing to continuous improvements of environmental protection.

5.4  Setting up and following a reasonable environmental management system.

6.  Supply chain

Suppliers must:

6.1  Exercise due diligence to ensure that Suppliers do not directly or indirectly support organisations or individuals associated with illegal activities, human rights abuses or terror.

6.2  Undertake reasonable efforts to encourage your own suppliers and subcontractors to comply with the principles of this Supplier Code of Conduct.

7.  Privacy

AVPartners Privacy Policy published on our website outlines AVPartners’ commitment to protecting privacy and personal information. Suppliers must apply adequate privacy and data security protection to protect the personal information of AVPartners and its customers and employees from unauthorised access, use and disclosure. This includes by not doing anything which would cause AVPartners to be perceived as acting inconsistent with the AVPartners Privacy Policy.

Author: Maria Kirkman
Last Revised: 29/08/2019