Purpose and Objectives
To establish the framework for the management of Policies, Procedures and supporting documents at the Company and alignment to relevant Regulatory Compliance Instruments, as appropriate.
Scope/Coverage
Our corporate policies and guidelines relating to our functions and responsibilities. Executives participate in formulating, adopting and reviewing organisational policy, in accordance with the provisions of the Work Health and Safety Act 2011 and relevant legislation. The Chief Executive Officer approves administrative policy relating to the management of the organisation’s operations including internal services.
There are four types of policies:
- Statutory Policies– are adopted by the organisation due to a legislative requirement, or approved the CEO as prescribed in the relevant legislation.
- Environmental Policies– are adopted by the organisation and have a direct impact on the environment.
- Administrative Policies– are adopted by the organisation and provide direction for internal management of the day to day operations of the organisation.
- Management Directives– are approved by the CEO and provide direction for internal management of the day to day operations of the organisation.
There is a hierarchy which applies to the Policy and Procedures Library (PPL). Each level of the hierarchy is described below in its order of precedence:
- Legislation
- Delegations of Authority
- Policies & Quality Manual
- Procedures & Plans
- Operating Procedures, Work Instructions
- Visual Aids, Forms, Checklists, etc
- Records
- A document lower in the hierarchy must relate to, and be consistent with, a document higher in the hierarchy. Each Policy, Procedure or Guideline must not be inconsistent with any Legislation or delegations of authority.
Policy Statement
The Company, through its Policies, Policy Instruments and Regulatory Compliance Instruments and Regulatory Compliance Obligations establishes a compliance management framework to enable it to effectively and efficiently manage its obligations and compliance risks.
A Policy is a high-level strategic directive that establishes a principle-based approach to a subject. A Policy should be developed for any area of the Company’s operation where direction or purpose needs to be set in the order to conduct Company business.
A Policy is implemented through other instruments, such as Procedures or supporting documents, which give instructions and set out processes to implement a Policy. This Framework establishes a hierarchy and categories of Policies, Procedures and supporting documentation and sets out the requirements and standards for each step of the development and improvement process. All Policies and Procedures must be developed, deployed, monitored and revised in accordance with this Framework.
A Regulatory Compliance Instrument is an external compliance instrument provided by legislation, regulation, standards, statutes or rules, including subordinate instruments.
A Regulatory Compliance Obligation is an external obligation provided in Regulatory Compliance Instruments. All Regulatory Compliance Instruments and Regulatory Compliance Obligations should be recorded in the Company’s Compliance Register.
Duration of enforcement
A Policy or Procedure will remain in force unless formally repealed by the organisation, Chief Executive Officer or delegated approval authority (Approval Authority).
Impact of structural change on enforcement
Where structural changes to the Company result in a different Approval Authority or other role referenced in a particular Policy or Procedure, the existing Policy or Procedure will remain in force until the Policy or Procedure is amended to reflect the new or amended position title or authority. Until such time as an amendment is formally made, the Approval Authority may nominate an alternate member of the Company community to operationally undertake the authority associated with the particular Policy or Procedure action.
Policy and Procedure compliance
Policy and Procedure compliance is mandatory for all Company employees and contractors, as applicable and provided in the scope of the Policy or Policy Instrument. The Company may at its sole discretion commence an applicable action in accordance with relevant Company Policies and/or employment contracts, as applicable, or seek other penalties if a person or entity breaches Policy or any related Procedures.
Policy and Procedure application
Policies and Procedures must be applied fairly and consistently.
Commitment to Compliance management
Through this Framework, Company is committed to complying with all relevant Regulatory requirements. Failure to comply with this Policy or Policy Instrument may be considered as misconduct and the provisions of the relevant Policy or Procedure applied. A hard copy of this electronic document is uncontrolled and may not be current as Company regularly reviews and updates its Policies and Policy Instruments. The latest controlled version can be found in the Company Policy and Procedure Library.
Compliance Instruments. This is achieved through the following levels of risk assurance:
- organisational management
- Policy and Procedure
- internal audit.
To ensure strong corporate governance and to carry out the Company operations in an environment of due diligence, the Framework is based on the principles of the Standard AS 3806-2006 Compliance programs.
In undertaking reviews of Policy, Policy Instruments and regulatory compliance, the Accountable Officer is responsible for the appropriate identification and documentation of Policy and Procedure updates required as a result of the regulatory change, either at a strategic or operational level. The Accountable Officer should recommend reasonable action to the Approval Authority, or where empowered to, should take reasonable action.
Responsibilities
Executives and management must be aware of their responsibilities and agree they should:
- exercise due care when handling or using information acquired in their role as a manager/officer for the organisation;
- acknowledge that there will be information that must be treated as confidential because to release it would reduce public trust and confidence in the integrity of the organisation ;
- if uncertain, presume information is confidential, and seek advice from the CEO prior to any release of it;
- undertake not to disclose, and to use their best endeavours to prevent disclosure of,
- confidential information to any person or organisation, specifically:
- avoid discussing confidential organisational information with family, friends and business associates; and
- ensure documents containing confidential information are properly safeguarded at all times – including materials stored at private or business residences.