1. Introduction

This Supplier Code of Conduct ("Code") sets out the minimum standards that all suppliers of Estia Health Ltd ABN 37 160 986 201 or any of its subsidiaries, including Estia Investments Pty Ltd ABN 87 164 350 387 ("Estia Health") are expected to meet and adhere to, reflecting our commitment to conduct business ethically, responsibly, and with the utmost respect for human rights.

This Code applies to all suppliers, contractors, consultants, agents and other providers of goods and services ("Suppliers") who do business with Estia Health.

By entering into a contract with Estia Health, Suppliers agree to make all reasonable endeavours to:

  • comply with this Code and
  • ensure that their employees, subcontractors, and agents also adhere to its principles.

Suppliers are expected to read and consider Estia Health's core values, policies, and guidelines outlined on the website at https://www.estiahealth.com.au/about-us/

  1. 2. Compliance with Laws and Regulations

2.1         Suppliers shall comply with all applicable laws, regulations, and standards, including but not limited to those relating to privacy, competition, taxation, anti-corruption, environment, Modern Slavery legislation, Work Health and Safety (WHS) legislation, discrimination laws, employment laws, and if appropriate ASX and ASIC reporting requirements, Task Force on Climate-Related Financial Disclosures (TCFD) reporting, and best practice sustainability commitments.

Suppliers shall promptly inform Estia Health of any changes in legal requirements that may impact their compliance obligations under this Code.

  1. 3. Ethical Conduct and Integrity

3.1         Suppliers shall maintain the highest standards of ethical conduct and integrity in all aspects of their business activities.

 3.2        Suppliers shall avoid any conflicts of interest that may compromise their ability to act in the best interests of Estia Health or their ability to fulfil their contractual obligations. Where conflicts do arise, Suppliers should disclose them promptly and work to resolve them responsibly.

3.3         Suppliers shall not engage in any form of bribery, corruption, or unethical business practices.

Suppliers must commit to fair competition and business practices. This includes compliance with all applicable laws and regulations related to competition and trade practices, and avoiding any form of anti- competitive behaviour, such as collusion, cartel behaviour, or abuse of market power.

  1. 4. Labour and Human Rights

4.1         Suppliers shall prohibit forced labour, child labour, and any form of human trafficking, abuse or exploitation within their own operations and their supply chains.

4.2         Suppliers shall provide fair and safe working conditions, including fair wages, reasonable working hours, and adequate health and safety measures, in compliance with applicable laws and regulations.

4.3         Suppliers must respect and uphold human rights in all of their operations, including freedom of association and the right to collective bargaining. Suppliers should promote equal opportunities for all and support diversity and inclusion.

  1. 5. Managing Employee Health and Safety, Welfare, and Preventing Bullying, Harassment, and Discrimination

5.1         Suppliers shall prioritize the health, safety, and welfare of their employees and take proactive measures to ensure a safe working environment. This includes having appropriate systems in place to prevent accidents and harm to health arising out of, linked with, or occurring in the course of work.

5.2         Suppliers shall implement policies and procedures to prevent bullying, harassment, and discrimination in the workplace based on factors such as race, colour, religion, gender, sexual orientation, age, disability, or any other protected characteristic.

 5.3        Suppliers shall promptly address and investigate any reported incidents of bullying, harassment, or discrimination and take appropriate corrective actions.

5.4         Suppliers shall provide training and awareness programs to their employees to promote a respectful and inclusive work environment.

  1. 6. Environmental Responsibility

6.1         Suppliers shall implement environmentally responsible practices throughout their operations and supply chain, including responsible sourcing, waste management, natural resource use, energy efficiency, and emissions reduction.

6.2         Suppliers shall comply with all applicable environmental laws and regulations and work towards continuous improvement in their environmental performance. Where feasible, Suppliers should also strive to use renewable resources, promote biodiversity, and support the transition to a low-carbon economy.

  1. 7. Product Quality and Safety

7.1         Suppliers should ensure that their products and services are safe, reliable, fit for purpose, and meet all relevant regulatory requirements and industry best practices. They should be transparent and proactive in reporting any quality issues or defects that could impact Estia Health and should take prompt action to resolve them.

7.2         Suppliers shall promptly address any product quality or safety issues and cooperate with Estia Health in implementing effective recall procedures, if necessary.

  1. 8. Confidentiality and Data Protection

8.1         Suppliers shall maintain the confidentiality and security of all sensitive information or data, including confidential, proprietary, and personal information relating to Estia Health. Suppliers should implement robust systems and processes to secure such information, prevent unauthorised access or disclosure, and ensure compliance with all applicable privacy and data protection laws, ensuring that sensitive is collected, processed, stored, transferred, and disposed of securely and appropriately.

8.2         Suppliers should only use sensitive information for the purpose for which it was provided and should not be used for personal gain or any other improper purpose.

  1. 9. Supply Chain Integrity

9.1         Suppliers should strive to promote the principles of this Code within their own supply chains. They should monitor their direct suppliers for compliance with applicable laws and ethical standards and should take appropriate action where non-compliance is identified. Suppliers are encouraged to engage with their suppliers in a constructive and collaborative manner, to improve their social, environmental, and ethical performance.

  1. 10. Monitoring

10.1       Suppliers should establish appropriate management systems and controls to ensure compliance with this Code.

10.2       Estia Health or an agent acting on its behalf, reserves the right to monitor Supplier compliance with this Code through audits, assessments, or any other reasonable means.

10.3       Suppliers shall cooperate with Estia Health's monitoring activities, including providing access to relevant facilities, records, and personnel.

10.4       Suppliers must report any non-compliance with this Code to Estia Health immediately. In the event of non-compliance, the Supplier must develop and implement a corrective action plan to remediate the issue promptly.

10.5       Non-compliance with this Code may result in various consequences, depending on the nature and severity of the violation. This may include requests for corrective action, suspension of current work, termination of the business relationship, and potential legal action.

  1. 11. Grievances and Complaints

11.1       Suppliers shall maintain an appropriate means for their employees and other relevant parties to raise concerns or queries relating to the conduct of the business. Suppliers should create an environment where employees feel comfortable raising concerns without fear of retaliation.

 11.2      Suppliers shall implement appropriate measures to promptly address any reported concerns and take appropriate corrective actions.

11.3       Suppliers, employees of Suppliers or sub-contractors are able raise concerns about any actual or suspected breach of this Code by email to procurement@estiahealth.com.au. Estia Health will treat all reports confidentially, investigate them thoroughly and impartially, and take appropriate corrective action.

11.4       Estia Health also operates a confidential “Say Something” whistleblower Hotline Service as an additional method of support to raise concerns of suspected or actual misconduct, including breaches of the Code. This service is run by an independent third-party provider. Concerns can also be raised anonymously without giving any personal information. Concerns can be raised via email, online through the website, by phone or by email to:

Phone: 1300 304 550

Website: https://saysomething.stoplinereport.com/

Conclusion

By doing business with Estia Health, Suppliers confirm their acceptance of this Code and commit to uphold its principles. Estia Health believes in fostering a transparent, ethical, and sustainable supply chain. This Code serves as a guide to our values and expectations, and we appreciate our suppliers' commitment to upholding these standards.

This Code is a living document and will be reviewed periodically to ensure it continues to align with evolving societal expectations, legal requirements, and best practices in corporate responsibility and sustainability.

Note: This Supplier Code of Conduct does not create any contractual rights for Suppliers or third parties. All business relationships with Estia Health are subject to the terms and conditions of the relevant contracts and purchasing agreements.