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Employer of Choice

DHCC Australia is committed to being an employer of choice. The majority of our staff are full time employees supported by excellent people management.

DHCC Australia is a place:

• where differences are celebrated
• where we value hard work and also downtime to keep you refreshed
• we champion dreams, open minds and innovation
• we develop our people and assist with the pursuit of knowledge
• we champion flexibility and openness

We recruit, hire and work according to the following values:

• Trust and Respect
• Collaboration
• Customer Centricity
• Honesty
• Continuous Learning
• Employee Focus
• Innovation

We live these values by demonstrating the following behaviours:

• We trust and respect each other
• We collaborate on processes
• We choose culture-fit over skill-fit
• We put the customer first
• We embrace challenge and face the truth
• We relentlessly chase better
• We take calculated risks and learn fast
• We think outside of the box
• We invest in our people

We have a number of policies covering issues such as:

• Flexible working

DHCC Australia Flexible Working Policy




BACKGROUND

DHCC Australia endeavours to assist our employees to achieve their personal, family and relationship goals by providing flexible working arrangements. Flexible Work Arrangements are about an employee and an employer making changes to when, where and how a person will work to better meet individual and business needs.

This policy covers the following Flexible Working Arrangements:

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• Conversion to part-time employment. Part-time employees work a regular and predictable number of hours each week
• Job sharing. Job sharing involves one position being shared by two or more employees
• Out of office Work. Employee performs some work responsibilities from out of the office
• Field Work. Employees work in locations where DHCC Australia doesn’t have an office and work is conducted from a client office or other location
• Other flexible work arrangements. Different type of Flexible Work Arrangement as agreed between employee and manager, could include an agreement to change the pattern of hours an employee will work to make allowances for caring duties or to have extended leave to cover personal circumstances such as domestic violence.




PURPOSE

This policy was developed to ensure that employees and managers are aware of the range of Flexible Working Arrangements available at DHCC Australia and understand the roles and responsibilities of each person involved in the application and approval process. The availability of these arrangements is subject to individual situations and DHCC Australia’s operational requirements.




SCOPE

This policy applies to all DHCC Australia employees.




POLICY

Flexible Work Arrangements can assist employees to balance personal needs while considering business needs. Flexible Working Arrangements may not always be possible due to operational or other limitations. Managers and employees need to be open to discussing and considering a range of flexible work options. Managers are responsible for deciding about Flexible Working Arrangements following a request by an employee. Further responsibilities of managers and employees are detailed in the Roles and Responsibilities section of this policy.




1. Assessing Requests for Flexible Work Arrangements

When assessing requests for Flexible Work Arrangements, factors that may be relevant could include:

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• That the new working arrangements requested by the employee would be too costly for the employer
• That there is no capacity to change the working arrangements of other employees to accommodate the new working arrangements requested by the employee
• That it would be impractical to change the working arrangements of other employees or recruit new employees, to accommodate the new working arrangements requested by the employee
• That the new working arrangements requested by the employee would be likely to result in a significant loss in efficiency or productivity
• That the new working arrangements requested by the employee would be likely to have a significant negative impact on customer service.

When assessing requests for Out of Office work, other factors that may be relevant could include:

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• The proposed work area provides an appropriate level of privacy and security to enable the employee to fully comply with DHCC Australia policies relating to the protection of DHCC Australia information, including the Information Security Policy and the Acceptable Use Guidelines. This information may be in electronic form, in hardcopy on paper or other media or oral, for example via a conversation
• an employee's performance prior to making the request
• an employee's ability to supervise others effectively while working remotely.

All Flexible Working Arrangements must be formally requested, agreed and managed in accordance with this policy.




2. Trial Periods of Flexible Work Arrangements

DHCC Australia may request that any Flexible Working Arrangement approved under this policy should undergo a trial period to ensure the arrangements meet the business requirements of DHCC Australia and the flexibility required by the employee. If the trial is successful and Flexible Working Arrangements are adopted, managers must review these work arrangements regularly to ensure:

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• All deliverables are being met
• The quality, quantity and timeliness of the work performed is to the standard required
• The impact on other members of the work team is not detrimental
• The operational requirements of the area are being met
• The employee is complying with the terms of the agreement
• The Flexible Working Arrangements continue to meet the needs of the employee
• Work Health and Safety requirements continue to be met
• DHCC Australia policies and procedures are being adhered to.

DHCC Australia reserves the right to cancel any Flexible Working Arrangement with an employee at any time giving two weeks’ notice following a discussion with the employee.




3. Categories of Flexible Working Arrangements

Converting to Part-time Employment

An employee may request to convert to part-time employment on a temporary or permanent basis. Any request to convert from full-time to part-time employment needs to be balanced with the operational requirements and the needs and impact on other employees in the function. Employees interested in converting to part-time employment should speak to their manager about their reasons for moving into part-time employment.




Job Sharing

Job sharing involves a position being shared by two or more employees. Employees who share a position will be employed on a permanent part-time basis. Positions under a job share agreement are considered to be part-time (though hours do not have to be split equally). Job sharing may be initiated by employees but must be approved by the manager. Approvals will be dependent on the job share arrangement not disadvantaging operational business performance. The employees who share a position will agree with their manager how the position is to be divided. If one of the employees on a job share arrangement leaves the organisation, the other affected employee will be consulted to explore alternative job share or flexible work arrangements.

DHCC Australia reserves the right to withdraw a job share arrangement if one of the employees leaves DHCC Australia and an alternative option is not agreed.




Other Flexible Work Arrangements

DHCC Australia will consider other Flexible Work Arrangements proposed by an employee in addition to those set out in this policy such as formalising an agreement to change the pattern of hours an employee will work.




Ad Hoc Working from Home

DHCC Australia recognises that it may be necessary for an employee to work from home as required on an ad hoc basis and will not reject these requests on an unreasonable basis.




Field Worker

Where employees at DHCC Australia are required to work in locations outside the DHCC Australia offices (e.g. at a client site), the arrangements will be assessed as per 1 above.




Out of Office Working Arrangements

Out of Office Working Arrangements (including Field Work and Ad Hoc working from home) are not a substitute for childcare or other dependent care. Employees are responsible for ensuring that appropriate childcare or dependent care arrangements are in place whilst engaged in Home Working Arrangements. No face to face meetings are to be held on an employee’s home premises. DHCC Australia policies and procedures in relation to Work Health and Safety apply.

For all Out of Office Working Arrangements, DHCC Australia will arrange fire and theft insurance of contents, equipment and facilities owned by DHCC Australia and employees will be covered for workers' compensation insurance. While DHCC Australia will not be responsible for providing or paying for any facilities required for an employee to conduct Home Working Arrangements, any adjustments, corrective actions or additional equipment required to ensure the safety of the home workplace as recommended by a Health Safety and Environment assessor will be reasonably considered by DHCC Australia. Upon variation or cancellation, employees are required to return any DHCC Australia equipment. DHCC Australia may provide an allowance to cover an appropriate portion of the Internet, phone, lighting and heating etc. The Out of Office Working Allowance amount will be reviewed and amended from time to time at DHCC Australia's discretion.

A detailed risk self-assessment of the home workplace environment must be completed by the employee using the DHCC Australia Out of Office Health Safety and Environment Checklist. A DHCC Australia Health Safety and Environment Representative will review this assessment and decide if the workplace is Health Safety and Environment compliant. With the exception of a portable laptop and headset, DHCC Australia will not be responsible for providing or paying for any other facilities/equipment required for an employee to conduct Out of Office Working Arrangements.




4. Flexible Work Arrangements Application Process

The Flexible Work Arrangements application process is a transparent process which complies with relevant legislation, e.g. Fair Work Act 2009. Detailed information about the application process along with supporting materials like Frequently Asked Questions and Quick Reference Guides can be sourced from your manager. In the first instance, an employee should discuss their intention to apply for a Flexible Work Arrangement with their manager. At this stage, managers may contact the CEO for policy guidance.

DHCC Australia may consider any factors or information it considers relevant on business grounds when considering Flexible Work Arrangement applications and will provide a written response within 21 days (starting from the date of submission to the manager).




5. Roles and responsibilities

Managers are responsible for:

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• Considering each employee application in conjunction with this policy and relevant legislation, e.g. Fair Work Act 2009 in deciding if a request can be accommodated and the terms of any arrangement
• Ensuring Flexible Working Arrangements are in line with this policy
• Managing differences in work styles and practices, e.g. managing employees on a home-based work arrangement
• Tracking the career progression of employees who are on Flexible Work Arrangements to ensure they have access to all training and to ensure that they suffer no disadvantage in opportunities for promotion or career development
• Providing the necessary resources and equipment to facilitate Flexible Working Arrangements within the context of this policy
• Evaluating the outcomes of Flexible Working Arrangements and looking for improvements.

Employees are responsible for:

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• Identifying personal needs and possible solutions and being realistic about what is possible
• Ensuring the physical security of DHCC Australia information and assets at all times when outside of DHCC Australia premises
• Taking responsibility for delivering their own workload as agreed with their manager
• Reporting any workplace incidents, injuries or illnesses that occur whilst undertaking Flexible Working Arrangements
• Reporting any potential hazards that may exist in the Home Working Arrangements environment as it changes from time to time
• Ensuring that any Home Working Arrangements comply with all DHCC Australia policies and procedures, including Corporate Security and acceptable use guidelines
• Reviewing and modifying arrangements as their personal circumstances or operational requirements change from time to time.




6. More information

Please contact your Manager if you require additional information in relation to this policy.

Please note that this Policy summarises some of the rights and obligations which are created by the legislation. The Policy is not intended to go beyond the legislation. This Policy is not a term of any contract, including any contract of employment, and does not impose any contractual duties on DHCC Australia. This Policy may be varied by DHCC Australia from time to time.

Note: Current policy is under review.

OKAY
• Anti-bullying and harassment policies

DHCC Australia Anti-Harassment & Bullying Policy




BACKGROUND

At DHCC Australia, we are committed to meeting our legal Equal Employment Opportunity (EEO), anti-discrimination and Health and Safety obligations and acknowledge our responsibilities to provide a workplace that is free of harassment and bullying.




PURPOSE

This Harassment and Bullying Policy summarises the standards applicable at DHCC Australia. It is to be used as a guide by managers and employees to set up and maintain systems and procedures that prevent harassment and bullying in the workplace.

As an employer, we acknowledge that harassment and bullying can adversely affect the physical and psychological health, safety and wellbeing of employees.

Any form of harassment or bullying, as outlined in this policy, is totally unacceptable and will not be tolerated at DHCC Australia under any circumstances.

DHCC Australia will ensure that a trained Contact Officer is available for employee support on any EEO, anti-discrimination, harassment or bullying matters. The Contact Officer at DHCC Australia is the Head of Talent.

When read in conjunction with the Issues and Disputes Policy, this policy also provides a mechanism for dealing with incidents of harassment or bullying, should they arise. This policy is also closely linked to our Equal Employment Opportunity and Anti-Discrimination Policy.




SCOPE

This policy applies to all DHCC Australia employees and contractors.




POLICY

Legislation relating to harassment and bullying covers all persons in the workplace including:

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• Job applicants
• Probationers
• Full-time and part-time employees
• Casual or Temporary employees
• Apprentices and trainees
• Interns and unpaid workers
• Contract workers.

Workplace participants who work on the same premises but for different employers.

The “workplace” is defined as a place at which the workplace participant works or otherwise attends in connection with being a workplace participant. This includes workplace activities and functions that may be conducted at a location other than the normal place of business, e.g. client’s premises, conference facilities, social events.




1. Forms of Harassment

Harassment is any form of inappropriate, unwelcome, unsolicited and unreciprocated behaviour that puts someone down, offends them, humiliates them or intimidates them. Harassment is often about one person or a group of people wielding power in an inappropriate manner over another person or group of people.

Harassment is not always intended. Acts or behaviour which are funny or don't mean much to one person may hurt or offend another. Harassment does not have to be a series of incidents nor even an ongoing pattern of behaviour. Just one act can be enough to constitute harassment. What is important is how the behaviour affects the person it is directed towards.

At DHCC Australia, we are committed to promoting a workplace that is free of harassment and bullying, in keeping with the principles of EEO. These are summarised in our Fair Treatment Policy Statement which is to be explained to all new employees and volunteers as part of their induction program.




2. Grounds of Harassment

Harassment on the following grounds is illegal under EEO and anti-discrimination legislation:

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• Age
• Colour
• Family or carer’s responsibilities
• Marital status
• National extraction
• Physical or mental disability
• Political opinion
• Pregnancy
• Race
• Religion
• Gender
• Sexual preference
• Social origin.

Any behaviour that puts the mental or physical health and safety of another employee at risk is also illegal under Health and Safety legislation. It is also against the law to victimise someone because they have made a formal complaint of harassment.

Please note that discriminatory behaviour towards others, based on these and other attributes covered under EEO and anti-discrimination legislation is also against the law. Please refer to our Equal Employment Opportunity and Anti-discrimination Policy.




3. Examples of Inappropriate Behaviours that Constitute Harassment

The following examples of inappropriate behaviour are in breach of EEO and anti-discrimination principals and constitute “harassment”; this list is not exhaustive. They will not be tolerated at DHCC Australia.

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• Using sexist or racist language
• Derogatory ethnic or racist jokes
• Humiliating pranks or putdowns
• Verbal abuse or comments that put down or stereotype people generally because of their gender, race, etc.
• Offensive gestures
• Isolation or excluding a person or group
• Humiliating someone through sarcasm or insults
• Intimidating a person by yelling, or by threatening them
• Unreasonable rudeness
• Systematic targeting or scapegoating
• Intimidating or threatening behaviour
• Practical jokes based on a person's disability, race, sexual preference, etc.
• Saying or writing something insulting about a person on the basis of their sex, disability, race, etc.
• Unwelcome comments or questions about a person's sex life, appearance or dress
• Displaying offensive, explicit or pornographic calendars, literature, posters or other material
• Using technology such as email, screen savers, the internet or mobile telephones to access, store, display or distribute inappropriate material.

Harassment can occur over a period of time, but in some cases a single act may be enough to amount to harassment. Any DHCC Australia employee displaying behaviours such as these which breach EEO and antidiscrimination principals will be subject to immediate disciplinary action leading to termination of employment.

There are specific types of harassment that warrant special attention. These are outlined below.




4. Sexual Harassment

Sexual harassment is unwelcome and uninvited conduct of a sexual nature that offends, humiliates or intimidates the other person. Sexual harassment may occur as a single incident or a series of incidents.

The types of behaviour that can constitute sexual harassment include:

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• Personally offensive comments
• Comments or teasing about a person’s alleged sexual activities or private life
• Persistent unwelcome invitations, telephone calls, text messages or emails
• Sexual remarks or innuendo
• Offensive hand or body gestures
• Physical contact, such as kissing, patting, pinching or touching
• The display of sexually suggestive material
• Using computer systems for the retention and distribution of sexually explicit material
• Staring or leering in a sexual manner
• Requests for sexual favours
• Intrusive or inappropriate questions about sexual activity
• Lewd comments, dirty jokes, foul language
• Suggestive comments about a person's appearance
• Unwanted declarations of affection
• Other unwelcome conduct of a sexual nature.

Sexual harassment may take the form of a threat or an implication. It does not matter whether the person harassing carries out these threats or not. If an employee feels that their job or job benefits depend upon accepting unwanted sexual attentions, then sexual harassment has occurred. .

For sexual harassment to have occurred, there does not need to have been intent on the part of the person accused. It is sufficient that the person affected felt offended, humiliated or intimidated.

Additionally, a lack of protest by the person experiencing the sexual harassment does not imply that the conduct was welcome.

Please note that it is not sexual harassment to develop friendships or relationships with other workers where both parties are consenting. Management has no concern with the private lives of employees unless their conduct affects the workplace.




5. Bullying

Bullying is a form of harassment. Bullying is repeated, unreasonable behaviour that intimidates, humiliates and or undermines a person or group. It is behaviour that is beyond normal workplace interaction.

Bullying behaviour puts the mental or physical health and safety of an employee (including volunteers) or a group of employees at risk.

Examples of bullying behaviour include:

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• Verbal abuse
• Using aggressive or threatening language
• Excluding, isolating or ignoring someone
• Psychological harassment
• Intimidation
• Assigning meaningless tasks unrelated to the job
• Giving employees impossible assignments
• Deliberately changing work rosters to inconvenience particular employees
• Deliberately withholding information that is vital for effective work performance
• Deliberate damage to personal property
• Unreasonable threats of dismissal
• Psychological abuse that destroys self-esteem and confidence, such as continual criticism, putting someone down, etc.
• Unfair or excessive criticism
• Setting impossible deadlines
• Initiation rituals or subjecting someone to physical abuse.




6. Vilification

Vilification is a public act that incites, encourages, or urges others to hate, have serious contempt for, or severely ridicule a person or group of people because they are, or are thought to be, members of a particular race or religion. Vilification covers statements made at public meetings, in publications and on the internet. It includes threats of physical harm or damage to property.

A single incident or a series of incidents over a period of time can constitute vilification.

DHCC Australia will take all necessary steps to ensure vilification does not occur. Persons found guilty of vilification will be subject to disciplinary processes.




7. Victimisation

Victimisation is the term used to describe unfavourable treatment, "pay-backs" or intimidation, which might result from a discrimination or harassment complaint. Victimisation refers not only to intimidation of anybody who has, or is about to complain, but also to the harasser or discriminator, witnesses, supporters and those resolving or investigating any complaints.

DHCC Australia will take all necessary steps to ensure victimisation does not occur. Persons found guilty of victimisation will be subject to disciplinary processes.




8. Workplace Violence

Workplace violence refers to any situation in which an employee (including volunteers) is physically attacked or threatened in the workplace, either by a fellow employee, a volunteer, a customer or an intruder.

Workplace violence covers all behaviours that could cause a person to believe they are in danger. These behaviours include:

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• Verbal threats
• Hitting, kicking or scratching
• Pushing, shoving, grabbing or tripping
• Biting or spitting
• Throwing objects
• Attacking with any type of weapon
• Any form of indecent physical contact.

Violence in any form will not be tolerated by DHCC Australia. If a violent or potentially violent situation arises, the police will be called immediately.




What is not Harassment?

A relationship or behaviour that is freely accepted by all persons involved is not harassment. If people are in doubt about whether or not certain behaviours are acceptable, they should ask the person concerned.

Any relationships that occur outside the confines of the workplace are not covered by anti-discrimination law. However, if an outside relationship brings bad feelings or behaviour back into the workplace it will be a management issue and, depending on the nature of what happens in the workplace, may then become workplace harassment.




Dealing with Harassment or Bullying

Initially If you, as an employee believe that you have been or are being harassed or bullied, follow the procedures outlined below:

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1. If you can, make it very clear to the offender that their behaviour is offensive. This usually means confronting the person and asking them to stop
2. If you would like assistance, information or mediation support, then contact your Manager or your Contact Officer
3. If you feel the situation is serious and/or beyond your individual control or has not been resolved through steps 1 and 2, you are able to make a formal written complaint.

Employees who witness harassment or bullying also have an obligation to deal with the behaviour they have observed by reporting it to their Manager or their Contact Officer.




Formal Complaints and Complaint Investigation

Where a situation is not able to be resolved through mediation, the employee has the option of making a formal written complaint to the Executive GM of Client Services. The written complaint must contain the names of those the complaint is made against, a description of the situation(s) or incident(s) that have led to the complaint, dates of the incidents and the names of any witnesses.

The Executive GM of Client Services is responsible for complaint investigation. In the event of a formal written complaint being made, the situation will be investigated in accordance with our Issues and Disputes Policy.




Complaint Resolution

Please refer to our Issues and Disputes Policy for information on the resolution of complaints. A complaint may be made to the Fair Work Commission or, where applicable, the relevant State Equal Opportunity and Human Rights Authority or the relevant State Health and Safety Authority.




Responsibilities

At DHCC Australia, we take our anti-harassment and anti-bullying responsibilities very seriously and place the following expectations on our employees:

The Executive GM of Client Services is responsible for:

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• Ensuring a Harassment and Bullying Awareness Program is provided for all employees
• Confirming DHCC Australia’s commitment to providing a workplace free from discrimination, harassment and bullying by reissuing the Fair Treatment Policy Statement
• Reminding managers and employees of their responsibilities in the workplace
• Reinforcing the Harassment and Bullying Policy, including the complaints resolution processes
• All responsibilities listed for Managers below.

Managers are responsible for:

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• Promoting and developing a work environment that is free of harassment and bullying
• Ensuring the Fair Treatment Policy Statement is displayed on the intranet
• Monitoring the work environment to ensure that acceptable standards of respect, tolerance and conduct are consistently displayed
• Taking action if unacceptable standards of conduct are observed.

All Managers will operate under the following code of conduct:

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• All complaints will be treated seriously and sympathetically under the strictest confidence
• All complaints will be investigated impartially – both sides will be fairly and fully investigated
• No action will be taken until the matter is fully investigated and the Managing Director or his delegate has been informed
• Complainant, respondents and witnesses will not be victimised in any way.

The Contact Officer is DHCC Australia’s organisational representative for EEO matters relating to harassment and bullying. The Contact Officer role is currently performed by the Head of Talent. Their responsibilities are to:

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• Be the first point of contact for people who have concerns about inappropriate behaviour and to provide support for these people
• Act impartially when involved in investigating complaints of discrimination, harassment or bullying in the workplacee
• Know the company procedures for resolution of complaints
• Maintain confidentiality
• Assist the employee in the resolution of the complaint.

The Contact Officer will operate under the following code of conduct:

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• All complaints will be treated seriously and sympathetically under the strictest confidence
• All complaints will be investigated impartially – both sides will be fairly and fully investigated
• No action will be taken until the matter is fully investigated and the Managing Director or his delegate has been informed
• Complainant, respondents and witnesses will not be victimised in any way.

Employees have an obligation to ensure their own behaviour and the behaviour of other employees does not contravene legislation and this policy.

Employees are responsible for:

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• Treating all colleagues, clients and others in the workplace fairly and with respect.
• Respecting the diversity of colleagues, clients and others in the workplace.
• Promoting and modelling appropriate standards of behaviour at all times.
• Reporting any incidents of harassment or bullying they may see happening around them to their Manager or Contact Officer.
• Ensuring that if involved in complaints, confidentiality is maintained.

All non-employees, such as clients, customers, visitors and contractors have an obligation to ensure their own behaviour in the workplace does not contravene legislation. Any harassment or bullying by these non-employees will not be tolerated and may lead to termination of contracts or suspension of services, as appropriate. Should anyone observe unacceptable behaviour by one of DHCC Australia’s employees or non-employees, or directed towards one of our employees, it is his or her responsibility to deal with the offence by notifying their Manager or their Contact Officer immediately.




Non-Compliance and Policy Breaches

Employees who are not fully compliant with DHCC Australia’s Anti-Harassment and Bullying Policy will be provided with additional information, instruction training or supervisory support in keeping with our Training and Development Policy and Performance Improvement Policy.

Employees who are in blatant breach of DHCC Australia’s Anti-Harassment and Bullying Policy and who have subsequently placed the company at risk will be subject to disciplinary action that may lead to termination of employment in keeping with our Performance Improvement Policy.

Note: Current policy is under review.

OKAY
• Diversity and Inclusion

DHCC Australia Diversity and Inclusion Policy




BACKGROUND

At DHCC Australia, we are committed to finding ways to encourage a diverse and inclusive workforce. We commit to providing actionable plans to foster an inclusive and diverse workforce, free from any discrimination, and understand our legal requirements of the Equal Opportunities Act. DHCC Australia commits to ensuring that there is no discrimination in hiring, compensation, access to training, promotion, termination or retirement.




PURPOSE

This Diversity and Inclusion Policy summarises the standards applicable at DHCC Australia. It is to be used as a guide by managers and employees to create measurable plans of action to improve diversity and inclusion within our workforce and report on progress.

As an employer, we acknowledge that by creating an inclusive and diverse workforce we promote a feeling of safety and well being in our employees and benefit from increased innovation due to a variety of perspectives, knowledge, and experience.

Any form of discrimination is totally unacceptable and will not be tolerated at DHCC Australia under any circumstances.

DHCC Australia will ensure that a trained Contact (Grievance) Officer is available for employee support on any EEO, anti-discrimination, harassment or bullying matters. This is where employees can lodge misconduct or grievances without fear of reprisal. The Contact Officer at DHCC Australia is the Head of Talent.

When read in conjunction with the Anti-Harassment and Bullying Policy, this Policy also provides a mechanism for dealing with incidents of discrimination, should they arise. This Policy is also closely linked to our Equal Employment Opportunity.




SCOPE

This policy applies to all DHCC Australia employees and contractors.




POLICY

Legislation relating to diversity and inclusion covers all persons in the workplace, including:

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• Job applicants
• Probationers
• Full-time and part-time employees
• Casual or Temporary employees
• Apprentices and trainees
• Interns and unpaid workers
• Contract workers.

Workplace participants who work on the same premises but for different employers.

The “workplace” is defined as a place at which the workplace participant works or otherwise attends in connection with being a workplace participant. This includes workplace activities and functions that may be conducted at a location other than the normal place of business, e.g. the client’s premises, conference facilities, social events.




1. Diversity

Diversity is a term used to describe all the visible or non-visible differences between people. It also refers to diverse or unique ways of thinking and working.

We understand that attracting and retaining employees and managers who reflect a diversity of knowledge, experience and backgrounds helps DHCC Australia achieve its business objectives, increased productivity and creativity and creates more sustainable business practices. Diversity can include:

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• Age
• Ethnicity
• Family or carer’s responsibilities
• Marital status
• National extraction
• Physical or mental disability
• Political opinion
• Pregnancy
• Race
• Religion
• Gender
• Sexual preference
• Union Membership

2. Inclusion

Inclusion is the key to unlocking the potential of a diverse workforce. In an inclusive environment, employees of DHCC Australia feel respected and appreciated enough to contribute all their strengths and promote innovation and creativity fully. These unique skills and perspectives benefit our organisation and strengthen our business outcomes.

Employee wellbeing is essential to talent retention and gives DHCC Australian an edge when it comes to competing for talent and maintaining top employees.

At DHCC Australia, we are committed to promoting a workplace that is inclusive to all, in keeping with the principles of EEO. These are summarised in our Fair Treatment Policy Statement, which is to be explained to all new employees and volunteers as part of their induction program.




3. Discrimination

Discrimination can manifest itself in many forms in the workplace. Creating a respectful and inclusive workplace is essential to enabling our employees to strive and meet their goals.

Discrimination against employees for personal characteristics that they have (or are perceived to have) will not be tolerated and are illegal under EEO and anti-discrimination legislation:

Please refer to our Equal Employment Opportunity and Anti-Bullying and Harassment Policy.




4. Freedom of Association and Collective Bargaining

Anti-discrimination laws extend to the rights of collective bargaining and freedom of association. DHCC Australia adopts an open attitude towards the lawful actions of trade unions and their organisational activities.

Workers’ representatives should have access to carry out their representative functions in the workplace and will not be discriminated against.




Dealing with Discrimination in the Workplace

Initially, if you, as an employee, believe that you have been excluded or discriminated against, follow the procedures outlined below:

The Executive GM of Client Services is responsible for:

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1. If you can, make it very clear to the offender that their behaviour is unacceptable. This usually means confronting the person and asking them to stop.
2. If you would like assistance, information or mediation support, then contact your Manager or your Contact Officer.
3. If you feel the situation is serious and beyond your individual control or has not been resolved through steps 1 and 2, you can make a formal written complaint.

Employees who witness exclusion or discrimination also have an obligation to deal with the behaviour they have observed by reporting it to their Manager or their Contact Officer.




Formal Complaints and Complaint Investigation

Where a situation is not able to be resolved through mediation, the employee has the option of making a formal written complaint to the Executive GM of Client Services. The written complaint must contain the names of those the complaint is made against, a description of the situation(s) or incident(s) that have led to the complaint, dates of the incidents and the names of any witnesses.

The Executive GM of Client Services is responsible for complaint investigation. In the event of a formal written complaint being made, the situation will be investigated in accordance with our Issues and Disputes Policy.




Complaint Resolution

Please refer to our Issues and Disputes Policy for information on the resolution of complaints. A complaint may be made to the Fair Work Commission or, where applicable, the relevant State Equal Opportunity and Human Rights Authority or the appropriate State Health and Safety Authority.




Responsibilities

At DHCC Australia, we take our diversity and inclusion responsibilities very seriously and place the following expectations on our employees:

The Executive Manager Corporate Services is responsible for:

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• Ensuring a Diversity and Inclusion Program is provided for all employees
• Confirming DHCC Australia’s commitment to providing an inclusive and diverse workplace free from discrimination, harassment and bullying by reissuing the Fair Treatment Policy Statement
• Reminding managers and employees of their responsibilities in the workplace
• Reinforcing the Diversity and Inclusion Policy, including the complaints resolution processes.
• All responsibilities listed for Managers below.

Managers are responsible for:

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• Promoting and developing a work environment that values diversity and is inclusive to all people
• Ensuring the Fair Treatment Policy Statement is displayed on the intranet
• Monitoring the work environment to ensure that acceptable standards of respect, tolerance and conduct are consistently displayed
• Apply ethical decision-making in the circumstances related to employment and diversity and inclusion targets
• Taking action if unacceptable standards of conduct are observed.

All Managers will operate under the following code of conduct:

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• All complaints will be treated seriously and sympathetically under the strictest confidence
• All complaints will be investigated impartially – both sides will be fairly and fully investigated
• No action will be taken until the matter is fully investigated and the Managing Director or their delegate has been informed
• Complainant, respondents and witnesses will not be victimised in any way.

The Contact Officer is DHCC Australia’s organisational representative for EEO matters relating to harassment and bullying. The Contact Officer role is currently performed by the Head of Talent. Their responsibilities are to:

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• Be the first point of contact for people who have concerns about inappropriate behaviour and to provide support for these people
• Act impartially when involved in investigating complaints of discrimination, harassment or bullying in the workplacee
• Know the company procedures for resolution of complaints
• Maintain confidentiality
• Assist the employee in the resolution of the complaint.

The Contact Officer will operate under the following code of conduct:

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• All complaints will be treated seriously and sympathetically under the strictest confidence
• All complaints will be investigated impartially – both sides will be fairly and fully investigated
• No action will be taken until the matter is fully investigated and the Managing Director or his delegate has been informed
• Complainant, respondents and witnesses will not be victimised in any way.

Employees have an obligation to ensure their own behaviour and the behaviour of other employees does not contravene legislation and this policy.

Employees are responsible for:

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• Treating all colleagues, clients and others in the workplace fairly and with respect.
• Respecting the diversity of colleagues, clients and others in the workplace.
• Promoting and modelling appropriate standards of behaviour at all times.
• Reporting any incidents of harassment or bullying they may see happening around them to their Manager or Contact Officer.
• Ensuring that if involved in complaints, confidentiality is maintained.

All non-employees, such as clients, customers, visitors and contractors, have an obligation to ensure their behaviour in the workplace does not contravene legislation. Any discrimination or exclusion by these non-employees will not be tolerated and may lead to termination of contracts or suspension of services, as appropriate. Should anyone observe unacceptable behaviour by one of DHCC Australia’s employees or non-employees, or directed towards one of our employees, it is his or her responsibility to deal with the offence by notifying their Manager or their Contact Officer immediately.




Non-Compliance and Policy Breaches

Employees who are not fully compliant with DHCC Australia’s Anti-Harassment and Bullying Policy will be provided with additional information, instruction training or supervisory support in keeping with our Training and Development Policy and Performance Improvement Policy.

Employees who are in blatant breach of DHCC Australia’s Anti-Harassment and Bullying Policy and who have subsequently placed the company at risk will be subject to disciplinary action that may lead to termination of employment in keeping with our Performance Improvement Policy.

OKAY
• Corporate Social Responsibility

DHCC Australia Corporate Social Responsibility Policy




BACKGROUND

At DHCC Australia, we take our responsibility to be an active and positive corporate citizen very seriously. We commit to complying with all local and international laws with regard to prohibited business practices whilst constantly striving to minimise our impact on the environment, protect human rights and demonstrate best practices in regards to ethical trading within our local community and globally.




PURPOSE

This Corporate Responsibility Policy summarises DHCC Australia’s commitment to acting ethically and responsibly in all areas of its operations. It is to be used as a guide by managers and employees to set up and maintain systems and procedures that allow DHCC Australia to demonstrate best practices.

DHCC Australia takes an ongoing approach to continually be more ethical and responsible in the way we conduct business. Corporate Social Responsibility affects every level of our organisation, and we welcome suggestions and advice from all our employees.

This policy is also closely linked to our Environmental Sustainability Policy, Diversity and Inclusion Policy, and Anti-Slavery Policy.




SCOPE

This policy applies to all DHCC Australia employees and contractors.




POLICY

Legislation relating to harassment and bullying covers all persons in the workplace, including:

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• Job applicants
• Probationers
• Full-time and part-time employees
• Casual or Temporary employees
• Apprentices and trainees
• Interns and unpaid workers
• Contract workers.

Workplace participants who work on the same premises but for different employers.

The “workplace” is defined as a place at which the workplace participant works or otherwise attends in connection with being a workplace participant. This includes workplace activities and functions that may be conducted at a location other than the normal place of business, e.g. the client’s premises, conference facilities, social events.




1. Corporate Governance

DHCC Australia commits to complying with all legislation regarding unethical business practices such as bribery and corruption. DHCC Australia maintains internal protocols to safeguard against such practices. We understand the necessity for transparency for stakeholders and commit to the timely disclosure of any information that could adversely affect the good or services provided to partners.

DHCC Australia commits to providing timely disclosure to partners regarding material ESG matters concerning the organisation in accordance with prevailing industry practices.

DHCC Australia will not engage with any sanctioned countries, persons, goods or services as designated by the UN Security Council or other sanction authorities.

At DHCC Australia, we are committed to ensuring that all our business is conducted to the highest ethical, professional and legal standards. We continually review all policies and business practices to promote development and explain our policies to all new employees and volunteers as part of their induction program.




2. Environmental Conservation

DHCC Australia is committed to meeting all legal regulations concerning environmental protection and management. We acknowledge that minimising our negative impact on biodiversity and reducing our usage of non-renewable resources are essential to being a responsible global citizen.

We encourage and support all our employees, suppliers and partners to reduce their impact on the environment through their work and in their everyday lives.

For more information, please refer to our Environmental Sustainability Policy.




3. Human Rights

DHCC Australia is committed to limiting the risk of human rights abuses within our organisation and throughout our supply chains. As an employer, we provide a respectful environment for all workers, free from discrimination, abuse, and exploitation.

We commit to comply with all legislation regarding human rights, and fair employment practises in accordance with existing international standards.

Abuse, intimidation, harassment are prohibited within our organisation and those we do business with. DHCC Australia has a zero-tolerance stance on the tolerance or inaction against human rights abuses if they uncovered in our organisation.

In conjunction with our Anti-Bullying and Harassment Policy, there are procedures in place which allow violations, misconduct, or grievances to be reported by workers and addressed without fear of reprisal.

When read in conjunction with the Anti-Slavery Policy and the Diversity and Inclusion Policy, this policy also provides a mechanism for dealing with the risk of modern slavery or other human rights abuses, should they be discovered. This policy is also closely linked to our Anti-Bullying and Harassment Policy.




4. Ethical Trading

DHCC Australia acknowledges the role organisations can play in creating employment and training opportunities as well as sustainable growth, and inclusion.

We endorse diversifying our procurement procedures and increasing indirect engagement with minority businesses which can help build sustainable enterprises.

DHCC Australia is committed to ensuring visibility throughout our supply chains and training will be provided to relevant people on environmental and social issues affecting the logistics supply chain.




RESPONSIBILITIES

At DHCC Australia, demonstrating our commitment to our corporate social responsibility is the responsibility of every employee or partner at every level. We place the following expectations on our employees:

The Executive GM of Client Services is responsible for:

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• For developing, reviewing and implementing policies, procedures and guidelines regarding our corporate social responsibilities
• Monitoring ESG risks and making policy changes accordingly
• Reminding managers and employees of their responsibilities in the workplace
• Reinforcing Policies, including the complaints resolution processes.
• All responsibilities listed for Managers below.

Managers are responsible for:

• Promoting and developing a work environment that adheres to our Environmental Sustainability policy and our other employment-related policies
• Ensuring the Policy Statement is displayed on the intranet
• Monitoring the work environment to ensure that acceptable standards of respect, tolerance and conduct are consistently displayed
• Taking action if unacceptable standards of conduct are observed.

All Managers will operate under the following code of conduct:

• All complaints will be treated seriously and sympathetically under the strictest confidence
• All complaints will be investigated impartially – both sides will be fairly and fully investigated
• No action will be taken until the matter is fully investigated and the Managing Director has been informed
• Complainant, respondents and witnesses will not be victimised in any way.

The Contact Officer is DHCC Australia’s organisational representative for matters relating to corporate social responsibility. The Contact Officer role is currently performed by the EGM Client Services. Their responsibilities are to:

• Be the first point of contact for people who have concerns regarding the way DHCC Australia is conducting business.
• Act impartially when involved in investigating complaints of discrimination, harassment or bullying in the workplacet
• Know the company procedures for resolution of complaints
• Maintain confidentiality
• Assist the employee in the resolution of the complaint.

The Contact Officer will operate under the following code of conduct:

• All complaints will be treated seriously and sympathetically under the strictest confidence
• All complaints will be investigated impartially – both sides will be fairly and fully investigated
• No action will be taken until the matter is fully investigated and the Managing Director or his delegate has been informed/li>
• Complainant, respondents and witnesses will not be victimised in any way.

Employees have an obligation to ensure their own behaviour and the behaviour of other employees does not contravene legislation and this policy.

Employees are responsible for:

• Treating all colleagues, clients and others in the workplace fairly and with respect
• Respecting the diversity of colleagues, clients and others in the workplace
• Reporting any incidents of abuse they may see happening around them to their Manager or Contact Officer
• Ensuring that if involved in complaints, confidentiality is maintained
• Reduce their impact on the environment through their work and in their everyday lives.

All non-employees, such as clients, customers, visitors and contractors have an obligation to ensure their own behaviour does not contravene our ESG policies. Any serious non-compliance may lead to termination of contracts or suspension of services, as appropriate. Should anyone observe unacceptable behaviour by one of DHCC Australia’s employees or non-employees, or directed towards one of our employees, it is his or her responsibility to deal with the offence by notifying their Manager or their Contact Officer immediately.




MORE INFORMATION

Please contact your Manager if you require additional information in relation to this policy.

Please note that this Policy summarises some of the rights and obligations which are created by the legislation. The Policy is not intended to go beyond the legislation. This Policy is not a term of any contract, including any contract of employment, and does not impose any contractual duties on DHCC Australia. This Policy may be varied by DHCC Australia from time to time.

OKAY
• Environmental sustainability

DHCC Australia Environmental Sustainability Policy




Background

DHCC, Australia is committed to meeting all legal regulations concerning environmental protection and management. We also acknowledge our responsibility to continuously assess and improve environmental risks within our organisation and supply chains. We demonstrate our commitment to managing resource scarcity and preventing climate change by developing and measuring against quantitative milestones to reduce our environmental impact.




Purpose

This Environmental Sustainability policy summarises DHCC Australia’s commitment to building a sustainable enterprise. It is to be used as a guide by the Board and managers to set up and maintain measurable environmental management plans to reduce impacts and dependencies on natural resources and report back on progress.




Scope

This policy applies to all DHCC Australia employees and contractors.




Policy

At DHCC Australia, we are committed to actively managing Environmental Social and Governance risks and acknowledge the effect our operations can have on the environment.
We understand the importance of taking a measurable and sustainable approach to our operation and supply chain, not just for the good of the environment but for the growth and resilience of our organisation.
Our attention to environmental, social and economic responsibility includes voluntarily exceeding legal requirements and to be innovative and demonstrate leadership on the issues that are important to us and our stakeholders.
As an organisation, we commit to:

• Compliance with all applicable environmental protection laws at the locations in which we operate
• The application of sound environmental management systems which set targets for environmental management and continuous improvement
• Communicating to all stakeholders our commitment to the environment
• Set, monitor and review environmental objectives and targets for operations
• Engage employees and support them in practical ways so they can reduce their environmental footprints
• Engage with stakeholders to further DHCC Australia’s understanding of its direct and indirect environmental impacts and contribute to the development of public policy and regulation




Responsibilities

At DHCC Australia, we take environmental responsibilities seriously and place the following expectations on our team:
The Board is responsible for:

• Reviewing targets and environmental management systems to ensure continuous improvement 
• Outlining sustainable practices.

The Executive GM of Client Services is responsible for:

• Ensuring an Environmental Sustainability Program is provided for all employees
• Confirming DHCC Australia’s commitment to providing a workplace that supports Environmental Sustainability
• Ensuring the Environmental Sustainability Policy is displayed on the intranet
• Reminding managers and employees of their responsibilities in the workplace
• All responsibilities listed for Managers below.

Managers are responsible for:

• Promoting and developing a work environment that values environmental sustainability
• Monitoring the work environment to ensure that acceptable standards of sustainability are implemented
• Taking action if the policy is not being complied with.

Employees have an obligation to ensure their own behaviour and the behaviour of other employees does not contravene legislation and this policy.
Employees are responsible for:

• Actions and behaviours that drive environmental policy compliant.

All non-employees, such as clients, customers, visitors and contractors, have an obligation to ensure their own behaviour in the workplace does not contravene legislation or this policy. Should anyone observe unacceptable or illegal behaviour by one of DHCC Australia’s employees or non-employees, it is his or her responsibility to deal with the offence by notifying their Manager or their Contact Officer immediately.




Non-Compliance and Policy Breaches

Employees who are not fully compliant with DHCC Australia’s Environmental Sustainability Policy will be provided with additional information, instruction training or supervisory support in keeping with our Training and Development Policy and Performance Improvement Policy.
Employees who are in blatant breach of DHCC Australia’s Environmental Sustainability and who have subsequently broken the law or placed the company at risk will be subject to disciplinary action that may lead to termination of employment in keeping with our Performance Improvement Policy.

OKAY
• Anti-slavery compliance

DHCC Australia Anti-Slavery Policy




BACKGROUND

DHCC Australia values human rights and is committed to limiting the risk of modern slavery within our organisation and throughout our supply chains. As an employer, we provide a respectful environment for all workers, free from discrimination, abuse, and exploitation.

The term modern slavery is used to describe situations where coercion, threats or deception are used to exploit victims and undermine or deprive them of their freedom.

DHCC Australia is committed to combatting modern slavery by enforcing the global labour standards specified by the International Labour Organisation's eight ILO Core Conventions.




PURPOSE

As an organisation working in a globalised economy, it is our responsibility to practice due diligence to prevent modern slavery and other human rights abuses from entering our organisation directly or indirectly.

This anti-slavery policy defines slavery in the 21st century. It is to be used as a guide by managers and employees to create measurable plans of action to protect our workforce and supply chain from modern-slavery and report on progress.

This policy is also closely linked to our Diversity and Inclusion Policy.




SCOPE

This policy applies to all DHCC Australia employees working for the company in any capacity. This includes our supply chain, consultants and subcontractors.




EXAMPLES OF SLAVERY

Australia aims to be a global leader in the fight against exploitation. The Modern Slavery Act of 2018 is the first legislation to define modern slavery. The Act defines modern slavery as including eight types of serious exploitation:

• trafficking in persons
• slavery
• servitude
• forced marriage
• forced labour
• debt bondage
• deceptive recruiting for labour or services
• the worst forms of child labour.




POLICY

DHCC Australia is committed to combating modern slavery as defined above, in both our operation and supply chains. Before commencing employment, DHCC Australia ensures all employees are legally entitled to work and that no child, involuntary or forced labour is used. This includes bonded or indentured labour, involuntary prison labour, slavery or trafficking of persons.

We will review relevant original documentation for all workers, including employment agency staff to validate that they have the legal right to perform the work before employment.

Workers will never be required to lodge deposits or leave their identity papers with DHCC Australia or the client companies for whom they work.

In addition, we support and uphold the eight-core conventions of the International Labour Organisation. These are summarised in our Employee and Suppliers’ Code of Conduct which is to be explained to all new employees and volunteers as part of their induction program.

1. Freedom of Association and Protection of the Right to Organise Convention
2. Right to Organise and Collective Bargaining Convention
3. Forced Labour Convention, 1930
4. Abolition of Forced Labour Convention, 1957
5. Minimum Age Convention, 1973
6. Worst Forms of Child Labour Convention, 1999
7. Equal Remuneration Convention, 1951 (No. 100)
8. Discrimination (Employment and Occupation) Convention, 1958.




ETHICAL TRADING

DHCC Australia will:

• promote complaint mechanisms and whistleblowing procedures that will enable workers to raise complaints about abuses
• promote direct and long-term employment rather than sub-contracting and overreliance on temporary labour
• formalise relationships with suppliers and other business partners and encourage suppliers to establish such relationships with their own suppliers.

Where an incident of modern slavery has occurred within our business or is at risk of occurring, it must be reported immediately. A quick reaction to cut ties with an associated entity could put the well-being of workers at risk. Whistle-blowers will be protected and supported as the situation is thoroughly investigated. DHCC Australia has a zero-tolerance policy to inaction and coverup.

During the investigation, the safety of the suspected victim will be paramount. It has been proven that removing workers from an explosive situation without support can lead to re-exploitation, deportation or violence. Due to this risk, DHCC Australia will seek the support of the government or trusted partner to investigate the situation and be advised on a course of action that is safest for those who are being exploited. If safe to do so, DHCC Australia will then cooperate with law enforcement who will ensure the situation is investigated, the victims protected, and the perpetrators held to account.




COMPLAINT RESOLUTION

Where an employee believes there has been a breach of this policy, they should complain to their manager in the first instance. If this complaint is not addressed or resolved then they should raise this issue with a member of the Senior Leadership Team. A complaint may be made to the Fair Work Commission or, where applicable, the relevant State Equal Opportunity and Human Rights Authority or the relevant State Health and Safety Authority.




RESPONSIBILITIES

The due diligence to prevent the exploitation of human rights is taken very seriously and we place the following expectations on our employees:

The Head of Talent is responsible for:

• Ensuring a Modern Slavery Awareness Program is provided for all employees
• Supporting the eight core conventions of the International Labour Organisations in the workplace
• Reinforcing the Anti-Slavery Policy, including the complaints resolution processes.
• Escalating complaints or suspicions of modern slavery whilst protecting the informant and suspected victims
• All responsibilities listed for Managers below.

Managers are responsible for:

• Promoting and developing a work environment that is free from discrimination, abuse, and exploitation
• Ensuring the Anti-Slavery Statement is displayed on the intranet
• Monitoring the work environment to ensure that there is no knowledge of exploitation or slavery in the workplace or suppliers
• Reporting complaints or suspicions of Modern Slavery in the workplace or supply chains whilst protecting the informant and suspected victims
• Taking action if unacceptable standards of conduct are observed.

All Managers will operate under the following code of conduct:

• Ensure that the investigation is conducted with the suspected victims' safety as the main priority
• Ensure that mitigation is worker focused
• All complaints will be treated seriously and sympathetically under the strictest confidence
• All complaints will be investigated impartially – both sides will be fairly and fully investigated
• No action will be taken until the matter is fully investigated and the Managing Director has been informed
• Complainant, respondents and witnesses will not be victimised in any way.

The Contact Officer is DHCC Australia’s organisational representative for matters relating to modern slavery. The Contact Officer role is currently performed by the Head of Talent. Their responsibilities are to:

• Be the first point of contact for people who have suspicions about exploitation
• Maintain confidentiality and protect the informant
• Protect the safety of a suspected victim as a first priority when involved in investigating reports of suspected slavery or exploitation
• Educate employees about the nature and prevalence of modern slavery
• Know the company procedures for receiving tip-off or complaints
• Reporting complaints or suspicions of modern slavery in the workplace or supply chains.

The Contact Officer will operate under the following code of conduct:

• All complaints will be treated seriously and under the strictest confidence
• All complaints will be investigated impartially – both sides will be fairly and fully investigated
• No action will be taken until the matter is fully investigated and the Managing Director has been informed
• Complainant, respondents and witnesses will not be victimised in any way
• The health and safety of the victim will be the priority.

Employees have an obligation to ensure their own behaviour and the behaviour of other employees does not contravene legislation and this policy.

Employees are responsible for:

• Reporting complaints or suspicions of modern slavery in the workplace or supply chains while protecting the informant and suspected victims
• Ensuring that if involved in complaints, confidentiality is maintained
• Treating all colleagues, clients and others in the workplace fairly and with respect
• Respecting the diversity of colleagues, clients and others in the workplace
• Promoting and modelling appropriate standards of behaviour at all times.

All non-employees, such as clients, customers, visitors and contractors have an obligation to ensure their own behaviour in the workplace does not contravene legislation. Any undisclosed knowledge or inaction to allow modern slavery to exist from non-employees will not be tolerated and may lead to termination of contracts or suspension of services, as appropriate. Should anyone observe unacceptable behaviour by one of DHCC Australia’s employees or non-employees, or directed towards one of our employees, it is his or her responsibility to deal with the offence by notifying their Manager or their Contact Officer immediately.




NON-COMPLIANCE AND POLICY BREACHES

All employees must read, understand and comply with the policy. Everyone working with DHCC Australia is responsible for combating modern slavery wherever it is encountered. Inaction is never acceptable. We will support anyone who raises genuine concerns in good faith, even if the accusation turns out to be false. DHCC Australia has safeguards to protect whistle-blowers.

Employees who are not fully compliant with DHCC Australia’s Anti-Slavery Policy will be provided with additional information, instruction training or supervisory support in keeping with our Training and Development Policy and Performance Improvement Policy.

Employees who are in blatant breach of DHCC Australia’s Anti-Slavery Policy and who have subsequently placed the company at risk will be subject to disciplinary action that may lead to termination of employment in keeping with our Performance Improvement Policy.




MORE INFORMATION

Please contact your Manager if you require additional information in relation to this policy.

Please note that this Policy summarises some of the rights and obligations which are created by the legislation. The Policy is not intended to go beyond the legislation. This Policy is not a term of any contract, including any contract of employment, and does not impose any contractual duties on DHCC Australia. This Policy may be varied by DHCC Australia from time to time.

Note: Current policy is under review.

OKAY
• DHCC Australia Protective Data Security Policy

DHCC Australia Protective Data Security Policy

Background

DHCC Australia’s protective data security is based on the Victorian Protective Data Security Standards (VPDSS) issued under Parts 4 and 5 of the Privacy and Data Protection Act 2014.




Objectives

The Policy is designed to help DHCCA staff and contractors:

• manage client information throughout our lifecycle (creation to disposal),
• manage client information across all the security areas (governance, information, personnel, Information Communications Technology (ICT), physical).
• manage security risks to the confidentiality, integrity and availability of client information,
• manage external parties with access to client information,
• share client information with others where appropriate with confidence; and
• minimise security incidents.




Standard 1 – Information Security Management Framework

This policy forms part of the documentation of DHCCA’s information security management framework (e.g., strategy, policies, procedures) covering all security areas.

• DHCCA’s information security management framework aligns with our risk management framework.
• Executive management defines information security functions, roles, responsibilities, competencies and authorities.
• Executive management owns, endorses and sponsors DHCCA’s ongoing information security program(s) including the implementation plan.
• DHCCA identifies information security performance indicators and monitors information security obligations against these.
• Executive management commits to providing sufficient resources to support DHCCA’s ongoing information security program(s).
• DHCCA sufficiently communicates our information security management framework and ensures it is accessible.
• DHCCA documents our internal control library that addresses our information security risks.
• DHCCA monitors, reviews, validates and updates the information security management framework.




Standard 2 – Information Security Value

DHCCA's Information Management Framework incorporates all security areas.
DHCCA:

• identifies, documents and maintains our information assets in an information asset register (IAR) in consultation with our stakeholders.
• uses a contextualised VPDSF business impact level (BIL) table to assess the security value of client information.
• identifies and documents the security attributes (confidentiality, integrity and availability business impact levels) of our information assets in our information asset register.
• applies appropriate protective markings to information throughout our lifecycle.
• manages the aggregated (combined) security value of client information.
• continually reviews the security value of client information across the information lifecycle.
• manages externally generated information in accordance with the originator’s instructions.
• manages the secure disposal (archiving/destruction) of client information in accordance with our security value.




Standard 3 – Information Security Risk Management

DHCCA conducts security risk assessments and determines treatment plans in accordance with our risk management framework covering all the processes to manage information security risks including risk identification, analysis, evaluation and treatment. DHCCA:

• records the results of information security risk assessments and treatment plans in our risk register.
• considers information security risks in organisational planning.
• communicates and consults with internal and external stakeholders during the information security risk management process.
• governs, monitors, reviews and reports on information security risk (e.g., operational, tactical and strategic through a risk committee.




Standard 4 – Information Access

DHCCA documents an identity and access management policy covering physical and logical access to client information based on the principles of least-privilege and need-to-know. DHCCA:

• documents an identity and access management policy covering physical and logical access to client information based on the principles of least-privilege and need-to-know.
• documents a process for managing identities and issuing secure credentials (registration and de-registration) for physical and logical access to client information.
• implements physical access controls (e.g., key management, swipe card access, visitor passes) based on the principles of least-privilege and need-to-know.
• implements logical access controls (e.g., network account, password, two-factor authentication) based on the principles of least-privilege and need-to-know.
• manages the end-to-end lifecycle of access by following provisioning and de-provisioning processes.
• limits the use of, and actively manages, privileged physical and logical access and separates these from normal access (e.g., executive office access, server room access, administrator access).
• regularly reviews and adjusts physical and logical access rights taking into account operational changes.




Standard 5 – Information Security Obligations

DHCCA documents our information security obligations and communicates these to all persons with access to client information (e.g., policies, position descriptions). DHCCA’s information security training and awareness content covers all security areas. DHCCA：

• delivers information security training and awareness to all persons with access to client information, upon engagement and at regular intervals thereafter in accordance with our training and awareness program and schedule.
• provides targeted information security training and awareness to persons in high risk functions or who have specific security obligations (e.g., executives, executive assistants, procurement advisors, security practitioners, risk managers).
• DHCCA reviews and updates the information security obligations of all persons with access to client information.
• All persons with access to client information acknowledge their information security obligations at least annually (e.g., during performance development discussions, attending security briefings, completing security training).
• DHCCA monitors, reviews, validates and updates our information security training and awareness program and schedule.




Standard 6 – Information Security Incident Management

DHCCA：

• documents and communicates processes and plan(s) for information security incident management covering all security areas.
• articulates roles and responsibilities for information security incident management.

DHCCA’s information security incident management processes and plan(s) contain the five phases of:

• Plan and prepare.
• Detect and report.
• Assess and decide.
• Respond (contain, eradicate, recover, notify); and
• Lessons learnt.

DHCCA records information security incidents in a register. DHCCA’s information security incident management procedures identify and categorise administrative (e.g., policy violation) incidents in contrast to criminal incidents (e.g., exfiltrating information to criminal associations) and investigative handover.
DHCCA regularly tests our incident response plan(s) at least annually.




Standard 7 – Information Security Aspects of Business Continuity and Disaster Recovery

DHCCA:

• documents and communicates business continuity and disaster recovery processes and plans covering all security areas.
• identifies and assigns roles and responsibilities for information security in business continuity and disaster recovery processes and plans.
• regularly tests our business continuity and disaster recovery plan(s) at least annually.




Standard 8 – Third Party Arrangements

DHCCA’s information security policies, procedures and controls cover the entire lifecycle of third-party arrangements (e.g., contracts, MOUs and information sharing agreements).

DHCCA:

• includes requirements from all security areas in third party arrangements (e.g., contracts, MOUs and information sharing agreements) in accordance with the security value of the client information.
• undertakes an information security risk assessment of the third party's service offering and addresses any residual risks prior to finalising the arrangement.
• identifies and assigns information security roles and responsibilities in third party arrangements (e.g., contracts, MOUs and information sharing agreements).
• establishes, maintains and reviews a register of third-party arrangements (e.g., contracts, MOUs and information sharing agreements).
• monitors, reviews, validates and updates the information security requirements of third-party arrangements and activities.
• documents our information release management requirements (e.g., social media, news).
• manages the delivery of maintenance activities and repairs (on-site and off-site).
• applies appropriate security controls upon completion or termination of a third-party arrangement (e.g., contracts, MOUs and information sharing agreements).




Standard 9 – Information Security Reporting to Clients

DHCCA notifies clients of incidents that have an adverse impact on the confidentiality, integrity or availability of client information with a business impact level (BIL) of 2 (limited) or higher.




Standard 10 – Personnel Security

DHCCA's personnel security policies and procedures address the personnel lifecycle phases of:

• Pre-engagement (eligibility and suitability),
• Engagement (ongoing and re-engagement), and
• Separating (permanently or temporarily).

DHCCA:

• verifies the identity of personnel, re-validates and manages any changes as required.
• undertakes pre-engagement screening commensurate with our security and probity obligations and risk profile.
• manages ongoing personnel eligibility and suitability requirements commensurate with our security and probity obligations and risk profile.
• manages personnel separating from DHCCA commensurate with our security and probity obligations and risk profile.
• develops security clearance policies and procedures to support roles requiring high assurance and/or handling security classified information.
• undertakes additional personnel screening measures commensurate with the risk to support roles requiring high assurance and/or handling security classified information.
• actively monitors and manages security clearance holders.




Standard 11 – Information Communications Technology (ICT) Security

DHCCA manages security documentation for our ICT systems (e.g., system security plans).

DHCCA:

• manages all ICT assets (e.g., on-site and off-site) throughout their lifecycle.
• conducts a security assessment for authorising systems to operate prior to transmitting, processing or storing client information.
• undertakes risk-prioritised vulnerability management activities (e.g. patch management, penetration testing, continuous monitoring systems).
• documents and manages changes to ICT systems.
• manages communications security controls (e.g., cabling, telephony, radio, wireless networks).
• verifies vendors’ security claims before implementing security technologies.
• manages security measures (e.g., classification, labelling, usage, sanitisation, destruction, disposal) for media.
• manages standard operating environments (SOEs) for all ICT assets, including end user access devices (workstations, mobile phones, laptops), network infrastructure, servers and Internet of Things (IoT) commensurate with security risk.
• manages security measures for email systems.
• logs system events and actively monitors these to detect potential security issues (e.g., intrusion detection/prevention systems (IDS/IPS)).
• uses secure system administration practices.
• designs and configures the ICT network in a secure manner (e.g., segmentation, segregation, traffic management, default accounts).
• manages a process for cryptographic keys (e.g., disk encryption, certificates).
• uses cryptographic controls for confidentiality, integrity, non-repudiation and authentication commensurate with the risk to information.
• manages malware prevention and detection software for ICT systems.
• segregates emerging systems from production systems (e.g., physical and/or logical) until their security controls are validated.
• manages backup processes and procedures (e.g., schedule, isolation, storage, testing, retention).
• manages a secure development lifecycle covering all development activities (e.g. software, web-based applications, operational technology (Supervisory Control and Data Acquisition/Industrial Control Systems (SCADA/ICS)).
• manages security measures for enterprise mobility (e.g., mobile device management, working from home).




Standard 12 – Physical Security

DHCCA

• plans and documents physical security measures.
• applies defence-in-depth physical security measures.
• selects physical security measures commensurate with the business impact level of the information.
• has scalable physical security measures ready for activation during increased threat situations.
• implements physical security measures when handling information out of the office.
• manages physical security measures throughout their lifecycle.

OKAY
• DHCC Australia COVID-19 Statement

DHCC Australia COVID-19 Statement




DHCC Australia’s number one priority is the wellbeing of our clients and team members. We are now enforcing strict policy as follows:

Staff who have recently returned from international travel are required to delay their return to office or client premises until after a minimum period of 14 days since their arrival back in Australia.

All members of our DHCC Australia Team should be aware of the heightened need to self-monitor, and if they develop symptoms consistent with the COVID-19 infection, they should isolate themselves and seek medical advice.

Where an employee’s circumstances fall within the above criteria, DHCC Australia asks, if you are well, to work remotely. If you become unwell, stay home and please contact your manager or the Head of Talent. Assistance will be provided for any staff to work remotely where required.

Regular updates are available from https://www.health.gov.au/health-topics/novel-coronavirus-2019-ncov.

DHCC Australia is monitoring advice from relevant government authorities as the situation regarding the spread of COVID-19 continues to unfold and will comply with any government directives as they apply. For this reason, further advice may follow.

We encourage everyone to follow the guidance of the Australian Health Department on how to protect yourself.

OKAY

We have an Employee Assistance Program in place to support any staff in need.