Our policies.
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Introduction
Bidfood Australia is committed to conducting business in an environmentally and socially responsible manner. As a food wholesaler, we recognise the significant impact our procurement practices can have on the environment, communities and public health. Therefore, we have developed this Sustainable Procurement Policy to guide our sourcing decisions and promote sustainability throughout our supply chain.
Scope
This policy applies to all procurement activities undertaken by Bidfood Australia Ltd, including the sourcing of raw materials, ingredients, packaging materials, finished products for resale and products used in our business.
Principles
- Environmental responsibility: We will prioritise the procurement of products and materials that minimise environmental impact, including those that are sustainably sourced, produced using renewable energy and have minimal carbon footprints.
- Social responsibility: We are committed to upholding labour rights, fair trade practices and ethical treatment of workers throughout our supply chain. We will not tolerate any form of modern slavery including forced labour, child labour, discrimination or unsafe working conditions.
- Quality and safety: We will prioritise the procurement of products that meet high standards of quality, safety and traceability. We will work with suppliers who not only adhere to food safety regulations but also and industry best practices.
- Local sourcing: Whenever feasible, we will prioritise sourcing products from local suppliers and producers to support the local economy, reduce transportation emissions and promote community resilience.
- Waste reduction: We will strive to minimise waste throughout our supply chain by reducing packaging, promoting reusable and recyclable materials, and implementing efficient inventory management practices.
- Continuous improvement: We will regularly review and evaluate our procurement practices to identify opportunities for improvement and innovation in sustainability.
Supplier engagement
- Supplier code of conduct: We expect our suppliers to share our vision for sustainable sourcing. We will communicate our sustainability expectations to all suppliers and require them to adhere to our Supplier Code of Conduct, which outlines our standards for environmental and social responsibility.
- Supplier evaluation: We will assess and monitor the sustainability performance of our suppliers, including their environmental practices, labour standards and ethical conduct.
- Collaboration and partnership: We will collaborate with suppliers, industry partners and stakeholders to promote sustainability initiatives, share best practices and address common challenges.
Compliance and accountability
- Compliance: All employees involved in procurement activities are responsible for adhering to this Sustainable Procurement Policy and ensuring that our sourcing decisions align with our sustainability commitments.
- Monitoring and reporting: We will establish mechanisms to monitor and report on our progress towards achieving our sustainability goals, including key performance indicators related to environmental and social impact.
Communication and transparency
- Stakeholder engagement: We will engage with stakeholders, including customers, employees, suppliers and communities, to promote awareness of our sustainability efforts and solicit feedback for continuous improvement.
- Transparency: We will strive to be transparent about our procurement practices, including the sourcing origins of our products, certifications obtained and efforts to address sustainability challenges.
Review and revision
This Sustainable Procurement Policy will be reviewed periodically to ensure its effectiveness and relevance to our business operations.
Introduction
Bidfood Australia Limited welcomes feedback from security researchers and the general public to help improve our security. If you believe you have discovered a vulnerability, privacy issue, exposed data, or other security issues in any of our assets, we want to hear from you. This policy outlines steps for reporting vulnerabilities to us, what we expect, what you can expect from us.
Systems in scope
This policy applies to any digital assets owned, operated, or maintained by Bidfood Australia Limited.
Out of scope
Assets or other equipment not owned by parties participating in this policy.
Vulnerabilities discovered or suspected in out-of-scope systems should be reported to the appropriate vendor or applicable authority.
Our commitments
When working with us, according to this policy, you can expect us to:
- Respond to your report promptly, and work with you to understand and validate your report;
- Strive to keep you informed about the progress of a vulnerability as it is processed;
- Work to remediate discovered vulnerabilities in a timely manner, within our operational constraints; and
- Extend Safe Harbor for your vulnerability research that is related to this policy.
Our expectations
In participating in our vulnerability disclosure program in good faith, we ask that you:
- Play by the rules, including following this policy and any other relevant agreements. If there is any inconsistency between this policy and any other applicable terms, the terms of this policy will prevail;
- Report any vulnerability you’ve discovered promptly;
- Avoid violating the privacy of others, disrupting our systems, destroying data, and/or harming user experience;
- Use only the Official Channels to discuss vulnerability information with us;
- Provide us a reasonable amount of time (at least 90 days from the initial report) to resolve the issue before you disclose it publicly;
- Perform testing only on in-scope systems, and respect systems and activities which are out-of-scope;
- If a vulnerability provides unintended access to data: Limit the amount of data you access to the minimum required for effectively demonstrating a Proof of Concept; and cease testing and submit a report immediately if you encounter any user data during testing, such as Personally Identifiable Information (PII), Personal Healthcare Information (PHI), credit card data, or proprietary information;
- You should only interact with test accounts you own or with explicit permission from the account holder; and
- Do not engage in extortion.
Official channels
Please report security issues via [email protected], providing all relevant information. The more details you provide, the easier it will be for us to triage and fix the issue.
Safe harbour
When conducting vulnerability research, according to this policy, we consider this research conducted under this policy to be:
- Authorised concerning any applicable anti-hacking laws, and we will not initiate or support legal action against you for accidental, good-faith violations of this policy;
- Authorised concerning any relevant anti-circumvention laws, and we will not bring a claim against you for circumvention of technology controls;
- Exempt from restrictions in our Terms of Service (TOS) and/or Acceptable Usage Policy (AUP) that would interfere with conducting security research, and we waive those restrictions on a limited basis; and
- Lawful, helpful to the overall security of the Internet, and conducted in good faith.
You are expected, as always, to comply with all applicable laws. If legal action is initiated by a third party against you and you have complied with this policy, we will take steps to make it known that your actions were conducted in compliance with this policy.
If at any time you have concerns or are uncertain whether your security research is consistent with this policy, please submit a report through one of our Official Channels before going any further.
Note that the Safe Harbor applies only to legal claims under the control of the organization participating in this policy, and that the policy does not bind independent third parties.
Introduction and purpose
Bidfood Australia Limited (the Company) strives to operate with a culture of ethical and appropriate corporate behaviour in all business activities. This includes ensuring that the officers and employees of the Company act with integrity, honesty and in accordance with good governance principles.
This purpose is supported by:
- ensuring that the Company has sound procedures to allow all workers and their families to identify and report concerns about suspected misconduct or an improper state of affairs pertaining to the Company (Reportable Conduct), without fear of detrimental action; and
- ensuring all employees and officers of the Company are aware of the protections available under this policy and applicable Whistleblower legislation.
In this policy:
Auditor or any member of the audit team refers to any registered company auditor who participates in the conduct of the audit conducted for the purposes as described in the Corporations Act 2001 and includes a review of a financial report for a financial year or a half-year or Internal Auditor dealing with financial matters.
Officer refers to an officer of the Company within the meaning of the Corporations Act 2001
Reportable Conduct refers to the types of matters outlined at section 4 below, which are protected by Whistleblower Laws (defined below) and the terms of this policy.
Senior Manager is a person who makes, or participates in making, decisions that affect the whole, or a substantial part, of the business of the Company; or has the capacity to significantly affect the Company’s financial standing. This will also include Regional Area Managers.
Eligible Whistleblower refers to an individual eligible to make a Reportable Conduct report as identified in section 3 below.
Whistleblower Laws refers to the protections contained in Part 9.4AAA of the Corporations Act 2001.
Commencement and scope
This policy will replace all other policies and procedures dealing with Eligible Whistleblowers (defined below) and Whistleblower Laws.
Who does this policy apply to?
This Policy applies to an individual who is or has been:
- An employee of the Company;
- An outworker, trainee, apprentice, student gaining work experience, or volunteer working at the Company;
- An Officer of the Company;
- A contractor or subcontractor of the Company and their employees;
- An employee of a labour hire company assigned to work for the Company;
- A Supplier of goods or services to the Company and their employees;
- An associate of the Company;
- A relative or dependant of any of the above of the Company (Eligible Whistleblower).
What is reportable conduct?
For the purpose of this Policy, Reportable Conduct that must be reported to the Company, includes but is not limited to, actions that are:
- Dishonest, including the willful or serious breach of internal policies and or procedures;
- Illegal, such as theft;
- Fraud, money laundering or misappropriation of funds;
- Offering or accepting a bribe;
- Failure to comply with, or breach of, legal or regulatory requirements;
- A significant or serious threat to health or safety;
- Endangering the public or the financial system;
- Enabling or endorsing Modern Slavery or human trafficking either within the Company or its supply chain;
- Engaging in or threatening to engage in detrimental action against a person who has made a disclosure or is believed or suspected to have made or be planning to make a disclosure;
- An offence against, or a contravention of, a provision of the Corporations Act 2001 and
- An offence against any other law of the Commonwealth that is punishable by imprisonment for a period of 12 months or more.
To be eligible for protection under this policy and the Whistleblower Laws, an Eligible Whistleblower must have reasonable grounds to suspect Reportable Conduct has occurred. This means the Eligible Whistleblower must have some basis for making a report, but they do not need to prove the Reportable Conduct occurred.
This Policy does not apply to personal work-related grievances, which include bullying and harassment, unless they relate to a report of Reportable Conduct. Examples of personal work-related grievances include:
- An interpersonal conflict between you and another employee;
- A decision relating to your employment or a transfer or promotion;
- A decision relating to the terms and conditions of your employment including your remuneration;
- A complaint of bullying, harassment, discrimination or other unfair treatment; and
- A decision to suspend or terminate your employment or disciplinary action taken against you.
Who can reportable conduct be disclosed to?
The Company has several preferred confidential reporting channels which are:
- Deloitte hotline: 1800 633 293
- Email: [email protected]
- Website: https://www.tip-offs.com/MakeReport.aspx
- Nominated members of the Executive Team as listed at section 11;
- An Officer or Senior Manager;
- A member of the Whistleblower Committee (as listed at section 11);
- An Internal Auditor or external auditor or any member of the audit team engaged by the Company; or
- An actuary engaged by the Company.
Eligible Whistleblower reports should include, to the extent possible, specific information such as dates, places, persons, witnesses, and amounts in order to assist the Company in considering next steps.
The Reportable Conduct report, once received by an Eligible Recipient, will be provided to the Whistleblower Committee.
All Eligible Whistleblower reports will be promptly directed for review and action as follows:
Reporting relating to: |
Directed to: |
Chairman of the Board |
Chairman of the Audit Committee |
Chairman of the Audit Committee |
Chairman of the Board |
Directors of the Company |
Chairman of the Audit Committee |
Executive leaders |
Chairman of the Audit Committee |
Internal audit team members |
A director of the Company or Chairman of the Audit Committee |
All others |
Whistleblower Committee |
Nothing in this policy should be taken as restricting Eligible Whistleblowers from making a report to a regulator (such as the Australian Securities and Investments Commission), or any other person in accordance with any relevant law or regulation. The Company encourages Eligible Whistleblowers to report to Eligible Recipients within the Company first.
Anonymity and confidentiality
There is no requirement for an Eligible Whistleblower to identify themselves to be protected by this policy and the Whistleblower Laws. The Company however encourages Eligible Whistleblowers to disclose their identity so that the Company can better monitor the Eligible Whistleblower’s welfare and protect them against detrimental action. It will also help the Company to obtain further information from the Eligible Whistleblower, should this be required.
The identity of an Eligible Whistleblower and information that is likely to lead to the identification of an Eligible Whistleblower will remain confidential at all times.
An Eligible Whistleblower’s identity will not be disclosed to anyone else unless:
- The Company is legally obliged to do so;
- The disclosure is required if and when the Company is required or decide to report the matter to a regulator or law enforcement body;
- The Eligible Whistleblower provides their consent.
Protection and support
All reports made under this policy are treated seriously. Anyone reporting Reportable Conduct should feel confident that they can do so without fear of detrimental action.
The Company will protect Eligible Whistleblowers from detrimental action in relation to a report of Reportable Conduct, whether substantiated or not substantiated by any subsequent investigation. Detrimental action includes:
- Dismissal of an employee;
- Injury of an employee in their employment;
- Alteration of an employee’s position or duties to their disadvantage;
- Discrimination between an employee and other employees of the same employer;
- Harassment or intimidation of a person;
- Harm or injury to a person, including psychological harm;
- Damage to a person’s property; h) Damage to a person’s reputation;
- Damage to a person’s business or financial position; j) Any other damage to a person.
A Whistleblower Protection Officer (WPO) may also be assigned to monitor the welfare of an Eligible Whistleblower, receive reports of actual or threatened detrimental action and provide feedback on the progress and results of the investigation.
Any person who causes or threatens to cause detrimental conduct against an Eligible Whistleblower who makes a report under this policy is potentially liable for serious civil and criminal penalties. In addition, Officers and employees who breach this policy may be subject to disciplinary proceedings including termination.
Bidfood provides an Employee Assistance Program (EAP), which is a short term, confidential, counselling service designed to offer a problem solving, solution-oriented approach to support employees with personal or work related issues.
The EAP is staffed by independent qualified practitioners and all employees have access to the EAP, which provides for a limited number of counselling sessions at no cost to the employee and can be provided over the phone or face to face. This program is provided through Access EAP (1800 818 728) and is available to all current Officers and employees.
Investigating reportable conduct
Eligible Recipients will refer reports of Reportable Conduct to the Whistleblower Committee to determine the scope of any investigation. The Whistleblower Committee will investigate the relevant matters in a manner compliant with the confidentiality obligations outlined in section 6 of this policy.
The Whistleblower Committee may appoint an appropriately qualified and impartial person or entity to investigate the report.
Whilst every investigation process will differ according to the relevant circumstances, the Whistleblower Committee will ordinarily ensure that appropriate enquiries are made to determine whether:
- The allegations are substantiated or not substantiated; and
- Whether responsive actions need to be taken in order to address the Reportable Conduct.
Any investigation will be conducted in an objective and fair manner, and otherwise as is reasonable and appropriate, having regard to the nature of the Reportable Conduct and the circumstances. An investigation may be undertaken using internal or external resources. Any person named in a report will be afforded procedural fairness in relation to any investigation undertaken.
Feedback, where possible, will be provided to the Eligible Whistleblower before, during and after any investigation performed.
Access to this policy
This policy will be made available by the following means:
- The Company intranet;
- Disclosed to employees on commencement of employment: and
- The Company’s external website.
Variations
This policy may be varied, amended, or replaced from time to time and at any time at the absolute discretion of the Company.
Roles and responsibilities
Role |
Responsibility |
Employee |
|
Investigator |
|
Whistleblower Committee |
|
Whistleblower Protection Officer |
|
Position |
Name |
Executive Team |
|
Whistleblower Committee |
|