Policies, Procedures & Practices

Anti-Bribery and Anti-Corruption Policy

First Choice Industrial

1. Purpose

First Choice Industrial is committed to conducting business ethically, with integrity, and in compliance with all applicable laws and regulations in Australia. This Anti-Bribery and Anti-Corruption Policy outlines our zero-tolerance approach to bribery and corruption and provides guidance to employees, contractors, and business partners on expected standards of conduct.

2. Scope

This policy applies to all directors, officers, employees, contractors, consultants, and any third parties acting on behalf of First Choice Industrial.

3. Legal Framework

This policy is designed to ensure compliance with relevant Australian legislation, including but not limited to:

Criminal Code Act 1995 (Cth) – particularly provisions relating to bribery of domestic and foreign public officials
Corporations Act 2001 (Cth)
Any applicable state and territory anti-corruption laws

Failure to comply with these laws can result in severe civil and criminal penalties for both individuals and the company.

4. Policy Statement

First Choice Industrial strictly prohibits all forms of bribery and corruption. This includes offering, giving, soliciting, or accepting anything of value to improperly influence a business outcome or gain an unfair advantage.

5. What Constitutes Bribery and Corruption

Bribery and corruption may include, but are not limited to:

Offering or accepting cash payments, gifts, or hospitality to influence decisions
Providing or receiving kickbacks, secret commissions, or facilitation payments
Improperly influencing public officials or business partners
Using third parties to engage in corrupt practices on the company’s behalf

6. Gifts, Hospitality, and Benefits

Reasonable and appropriate gifts or hospitality may be permitted where they:

Are of nominal value
Are not intended to influence a decision
Are transparent and properly recorded

Excessive, frequent, or inappropriate gifts or benefits are strictly prohibited.

7. Dealings with Public Officials

Extra caution must be exercised when dealing with government officials. Employees and representatives must not:

Offer or provide any benefit to influence an official decision
Engage in facilitation payments (small payments to expedite routine government actions), as these are prohibited under company policy

8. Third-Party Relationships

First Choice Industrial may be held liable for corrupt conduct by third parties acting on its behalf. Therefore:

Due diligence must be conducted before engaging agents, contractors, or suppliers
Third parties must agree to comply with this policy
Suspicious conduct must be reported immediately

9. Record Keeping

Accurate and transparent records must be maintained for all transactions. False, misleading, or incomplete records are strictly prohibited.

10. Reporting and Whistleblowing

Employees and stakeholders are encouraged to report any suspected bribery or corruption. Reports can be made confidentially and without fear of retaliation.

First Choice Industrial is committed to protecting individuals who raise concerns in good faith.

11. Breach of Policy

Any breach of this policy may result in disciplinary action, including termination of employment or contracts, and may also expose individuals to criminal prosecution.

12. Training and Awareness

First Choice Industrial will provide ongoing training and communication to ensure all personnel understand their obligations under this policy.

13. Review and Compliance

This policy will be reviewed periodically to ensure it remains effective and compliant with Australian laws and best practices.

Business Code of Conduct

First Choice Industrial

1. Purpose

This Business Code of Conduct (“Code”) outlines the standards of behaviour and ethical principles expected of all personnel at First Choice Industrial. It reflects our commitment to integrity, professionalism, and compliance with Australian laws and regulations.

2. Scope

This Code applies to all directors, officers, employees, contractors, consultants, and any third parties acting on behalf of First Choice Industrial.

3. Our Values

First Choice Industrial is committed to:

Acting with honesty and integrity
Treating people with respect and fairness
Operating transparently and responsibly
Complying with all applicable laws and regulations
Maintaining a safe and inclusive workplace

4. Compliance with Laws

All personnel must comply with applicable Australian laws and regulations, including but not limited to:

Corporations Act 2001 (Cth)
Work Health and Safety Act 2011 (Cth) (and relevant state legislation)
Fair Work Act 2009 (Cth)
Competition and Consumer Act 2010 (Cth)
Privacy Act 1988 (Cth)
Criminal Code Act 1995 (Cth)

Failure to comply may result in disciplinary action and/or legal consequences.

5. Ethical Conduct

All personnel must:

Act honestly and in good faith
Avoid deceptive, misleading, or unethical practices
Not engage in fraud, bribery, or corruption
Comply with the company’s Anti-Bribery and Anti-Corruption Policy

6. Conflicts of Interest

Personnel must avoid situations where personal interests conflict, or appear to conflict, with the interests of First Choice Industrial.

Any actual, potential, or perceived conflict must be disclosed to management promptly.

7. Workplace Behaviour

First Choice Industrial is committed to providing a workplace that is:

Safe and compliant with health and safety laws
Free from discrimination, harassment, bullying, and unlawful conduct
Inclusive and respectful of diversity

All personnel must behave professionally and treat others with dignity and respect.

8. Work Health and Safety

All personnel must:

Take reasonable care for their own health and safety and that of others
Follow all workplace safety policies and procedures
Report hazards, incidents, or unsafe conditions promptly

9. Use of Company Resources

Company resources must be used responsibly and for legitimate business purposes.

Unauthorised use, theft, or misuse of company property, funds, or information is prohibited.

10. Confidentiality and Privacy

Personnel must:

Protect confidential business information
Comply with privacy laws when handling personal information
Not disclose sensitive information without proper authorisation

11. Fair Dealing and Competition

First Choice Industrial is committed to fair and lawful competition. Personnel must not:

Engage in anti-competitive conduct such as price fixing or collusion
Make false or misleading representations
Abuse market power or engage in unfair business practices

12. Gifts and Benefits

Personnel must not offer or accept gifts, hospitality, or benefits that could improperly influence business decisions or create a conflict of interest.

All gifts and benefits must comply with company policies and be reasonable, transparent, and lawful.

13. Environmental Responsibility

First Choice Industrial is committed to environmentally responsible operations and compliance with applicable environmental laws and regulations.

Personnel are expected to minimise environmental impact and report any environmental risks or incidents.

14. Reporting Misconduct

All personnel are encouraged to report suspected misconduct, breaches of this Code, or unlawful behaviour.

Reports can be made in accordance with the company’s Bribery and Corruption Self-Reporting Procedure or other reporting channels.

15. Whistleblower Protection

First Choice Industrial supports and protects individuals who report misconduct in good faith.

Retaliation against whistleblowers is strictly prohibited and may result in disciplinary action.

16. Breaches of the Code

Breaches of this Code may result in disciplinary action, including termination of employment or contracts, and may also lead to legal action.

17. Training and Awareness

First Choice Industrial will provide training and communication to ensure all personnel understand and comply with this Code.

18. Review

This Code will be reviewed periodically to ensure it remains current and aligned with legal requirements and best practices.

ESG and Corporate Social Responsibility (CSR) Policy

First Choice Industrial

1. Purpose

First Choice Industrial is committed to operating responsibly, ethically, and sustainably. This Environmental, Social, and Governance (ESG) and Corporate Social Responsibility (CSR) Policy outlines our approach to managing environmental impact, supporting our workforce and communities, and maintaining strong governance practices in compliance with Australian laws and aligned with internationally recognised standards.

2. Scope

This policy applies to all directors, officers, employees, contractors, suppliers, and any third parties acting on behalf of First Choice Industrial.

3. Commitment to ESG and CSR Principles

First Choice Industrial is committed to:

Conducting business ethically and transparently
Respecting human rights and fair labour practices
Protecting the environment and minimising our impact
Providing a safe and inclusive workplace
Complying with all applicable Australian laws and regulations
Aligning with internationally recognised frameworks, including:
- The Ten Principles of the UN Global Compact
- International Labour Organization (ILO) conventions
- UN Guiding Principles on Business and Human Rights (Ruggie Framework)

4. Legal and Regulatory Compliance

We comply with all relevant Australian legislation, including but not limited to:

Corporations Act 2001 (Cth)
Work Health and Safety Act 2011 (Cth) and applicable state laws
Fair Work Act 2009 (Cth)
Modern Slavery Act 2018 (Cth) (where applicable)
Environment Protection and Biodiversity Conservation Act 1999 (Cth)
Privacy Act 1988 (Cth)
Criminal Code Act 1995 (Cth)

5. Environmental Responsibility

First Choice Industrial is committed to minimising environmental impact by:

Complying with environmental laws and regulations
Reducing waste, emissions, and resource consumption where practicable
Promoting energy efficiency and sustainable practices
Managing environmental risks and incidents responsibly
Encouraging environmentally responsible behaviour among employees and suppliers

6. Labour and Human Rights

We are committed to upholding fundamental human rights and fair labour practices, including:

Prohibiting forced labour, child labour, and any form of exploitation
Providing fair wages and working conditions in accordance with Australian law
Respecting freedom of association and collective bargaining rights
Ensuring equal opportunity and prohibiting discrimination, harassment, and bullying
Complying with obligations under the Modern Slavery Act, where applicable

7. Workplace Health and Safety

The health, safety, and wellbeing of our people is a priority. We commit to:

Providing a safe and healthy work environment
Complying with all work health and safety laws and standards
Identifying, assessing, and managing workplace risks
Encouraging reporting of hazards, incidents, and near misses
Promoting a culture of safety and continuous improvement

8. Ethical Business Practices and Governance

First Choice Industrial maintains strong governance and ethical standards by:

Prohibiting bribery, corruption, and unethical conduct
Complying with applicable competition and consumer laws
Maintaining accurate financial records and transparency
Managing conflicts of interest appropriately
Implementing internal controls and risk management processes

9. Supply Chain Responsibility

We expect our suppliers and business partners to uphold similar ESG and CSR standards. This includes:

Conducting due diligence on suppliers where appropriate
Encouraging compliance with labour, human rights, and environmental standards
Addressing risks of modern slavery and unethical practices in the supply chain

10. Community Engagement

First Choice Industrial aims to contribute positively to the communities in which we operate by:

Acting as a responsible corporate citizen
Supporting local communities where feasible
Minimising negative social and environmental impacts

11. Reporting and Accountability

We are committed to transparency and accountability by:

Monitoring ESG and CSR performance where practicable
Encouraging reporting of concerns or breaches of this policy
Investigating and addressing issues promptly
Maintaining appropriate records and documentation

12. Training and Awareness

We will provide appropriate training and communication to ensure personnel understand this policy and their responsibilities.

13. Continuous Improvement

First Choice Industrial is committed to continually improving ESG and CSR performance through regular review, stakeholder engagement, and alignment with evolving best practices and legal requirements.

14. Review

This policy will be reviewed periodically to ensure it remains relevant, effective, and compliant with Australian laws and international standards.

Workplace Bullying and Harassment Policy

First Choice Industrial

1. Purpose

First Choice Industrial is committed to providing a safe, respectful, and inclusive workplace free from bullying, harassment, and unlawful discrimination. This policy outlines expected standards of behaviour and establishes processes for preventing and responding to workplace bullying and harassment in compliance with Australian law.

2. Scope

This policy applies to all directors, officers, employees, contractors, consultants, visitors, and any other persons interacting with First Choice Industrial workplaces or workers.

3. Legal Framework

This policy is aligned with applicable Australian legislation, including but not limited to:

Fair Work Act 2009 (Cth)
Work Health and Safety Act 2011 (Cth) and relevant state/territory laws
Sex Discrimination Act 1984 (Cth)
Racial Discrimination Act 1975 (Cth)
Disability Discrimination Act 1992 (Cth)
Age Discrimination Act 2004 (Cth)

Under Australian law, employers have a duty to provide a workplace that is safe and without risks to health, including psychological health.

4. Policy Statement

First Choice Industrial has zero tolerance for workplace bullying, harassment, sexual harassment, victimisation, or any form of inappropriate workplace behaviour.

All workers have the right to be treated with dignity and respect.

5. Definitions

5.1 Workplace Bullying

Workplace bullying is repeated and unreasonable behaviour directed toward a worker or group of workers that creates a risk to health and safety.

Examples include:

Verbal abuse or offensive language
Intimidation, threats, or humiliation
Deliberate exclusion or isolation
Unreasonable work demands or deadlines
Spreading rumours or malicious conduct

5.2 Harassment

Harassment includes unwelcome behaviour that offends, humiliates, or intimidates a person and is related to a protected characteristic such as sex, race, age, disability, or other attributes under Australian law.

5.3 Sexual Harassment

Sexual harassment is any unwelcome sexual advance, request for sexual favours, or conduct of a sexual nature that a reasonable person would anticipate may cause offence, humiliation, or intimidation.

6. What is Not Bullying

Reasonable management action carried out in a reasonable manner is not considered bullying. This may include:

Performance management
Disciplinary action
Allocation of work
Setting reasonable workplace expectations

7. Responsibilities

7.1 Management

Provide a safe workplace free from bullying and harassment
Implement and enforce this policy
Respond promptly to complaints
Ensure fair and confidential investigations

7.2 Managers and Supervisors

Model appropriate behaviour
Monitor workplace conduct
Address inappropriate behaviour early
Support affected individuals

7.3 Employees and Workers

Treat others with respect and professionalism
Not engage in bullying or harassment
Report inappropriate behaviour
Cooperate with investigations

8. Reporting Procedures

Any person who experiences or witnesses bullying or harassment is encouraged to report it promptly.

Reports can be made through:

Direct manager or supervisor
Senior management or company director
Designated HR or compliance contact (if applicable)
Confidential reporting channels (if available)

Reports may be made formally or informally.

9. Complaint Handling Process

First Choice Industrial will:

Acknowledge the complaint
Assess the nature and seriousness of the issue
Conduct a fair, impartial, and timely investigation
Maintain confidentiality where possible
Provide support to affected individuals
Take appropriate action based on findings

10. Confidentiality

All complaints and investigations will be handled confidentially, subject to legal and procedural requirements.

11. Protection from Victimisation

First Choice Industrial strictly prohibits victimisation or retaliation against anyone who:

Makes a complaint in good faith
Participates in an investigation

Any retaliation will be treated as a serious breach of this policy.

12. Disciplinary Action

Breaches of this policy may result in disciplinary action, including:

Warnings
Training or counselling
Suspension
Termination of employment or contract

Serious breaches may also result in legal action.

13. Support for Affected Persons

Support may include:

Access to management support
Referral to Employee Assistance Programs (if available)
Flexible work arrangements where appropriate

14. Training and Awareness

First Choice Industrial will provide training and awareness programs to ensure all personnel understand their rights and responsibilities under this policy.

15. Record Keeping

All complaints, investigations, and outcomes will be documented and securely stored in accordance with legal requirements.

16. Review

This policy will be reviewed periodically to ensure it remains effective and compliant with Australian laws and best practices.

Environmental Policy

First Choice Industrial

1. Purpose

First Choice Industrial is committed to minimising its environmental impact and operating in an environmentally responsible manner. This Environmental Policy outlines our commitment to compliance with environmental legislation, pollution prevention, sustainable resource use, and continuous improvement in environmental performance.

2. Scope

This policy applies to all directors, employees, contractors, suppliers, and any third parties acting on behalf of First Choice Industrial across all operations and activities.

3. Legal and Regulatory Compliance

First Choice Industrial is committed to full compliance with applicable Australian environmental laws and regulations, including but not limited to:

Environment Protection and Biodiversity Conservation Act 1999 (Cth)
State and Territory Environment Protection Acts and Regulations
Waste management and pollution control legislation
Local council environmental requirements and permits

We will also consider relevant international environmental principles where applicable.

4. Policy Statement

First Choice Industrial recognises its responsibility to protect the environment and is committed to:

Preventing pollution where practicable
Reducing environmental impacts from operations
Using resources efficiently
Complying with all applicable environmental obligations
Continually improving environmental performance

5. Environmental Principles

5.1 Pollution Prevention

We aim to prevent pollution at its source by:

Managing emissions to air, water, and land
Reducing hazardous substance use where possible
Implementing spill prevention and response procedures

5.2 Waste Management

We are committed to responsible waste management by:

Reducing waste generation at the source
Reusing and recycling materials where practicable
Ensuring safe disposal of waste in compliance with regulations
Proper handling of hazardous waste

5.3 Resource Efficiency

We will seek to improve efficiency in the use of:

Energy
Water
Raw materials
Packaging and consumables

5.4 Emissions and Climate Considerations

We aim to reduce greenhouse gas emissions by:

Improving energy efficiency
Encouraging sustainable transport and logistics practices
Considering environmental impact in operational decisions

6. Environmental Risk Management

First Choice Industrial will:

Identify and assess environmental risks associated with its operations
Implement appropriate controls to mitigate those risks
Maintain emergency response procedures for environmental incidents

7. Roles and Responsibilities

7.1 Management

Ensure environmental compliance across operations
Provide resources for environmental management
Promote a culture of environmental responsibility

7.2 Employees and Contractors

Follow environmental procedures and instructions
Report environmental hazards or incidents
Use resources responsibly

7.3 Supervisors and Managers

Monitor environmental performance within their areas
Ensure compliance with this policy
Address environmental issues promptly

8. Training and Awareness

First Choice Industrial will provide appropriate training to ensure employees understand:

Environmental responsibilities
Waste handling and resource efficiency practices
Incident reporting procedures

9. Incident Reporting and Response

All environmental incidents, including spills, leaks, or breaches of environmental obligations, must be reported immediately.

We will:

Respond promptly to minimise environmental harm
Investigate root causes
Implement corrective and preventive actions

10. Suppliers and Contractors

We expect suppliers and contractors to:

Comply with applicable environmental laws
Minimise environmental impacts in their activities
Support First Choice Industrial’s environmental objectives where relevant

11. Continuous Improvement

First Choice Industrial is committed to ongoing improvement of environmental performance by:

Reviewing environmental objectives and practices regularly
Monitoring compliance and performance
Adopting more sustainable technologies and processes where feasible

12. Communication and Transparency

We will communicate our environmental commitments internally and, where appropriate, externally, and encourage feedback to improve performance.

13. Record Keeping

Environmental records, including incident reports, waste tracking, and compliance documentation, will be maintained in accordance with legal requirements.

14. Review

This Environmental Policy will be reviewed periodically to ensure it remains relevant, effective, and compliant with Australian environmental laws and best practices.

Supplier Code of Conduct

First Choice Industrial

1. Purpose

First Choice Industrial is committed to conducting business ethically, responsibly, and in compliance with Australian laws and internationally recognised standards. This Supplier Code of Conduct sets out the minimum expectations for all suppliers, contractors, vendors, and service providers engaged by First Choice Industrial.

2. Scope

This Code applies to all suppliers and their employees, subcontractors, agents, and any third parties involved in providing goods or services to First Choice Industrial.

3. Legal and Regulatory Compliance

Suppliers must comply with all applicable laws and regulations in the jurisdictions in which they operate, including but not limited to Australian law where relevant, including:

Fair Work Act 2009 (Cth)
Work Health and Safety Act 2011 (Cth) (and state equivalents)
Competition and Consumer Act 2010 (Cth)
Modern Slavery Act 2018 (Cth) (where applicable)
Environmental Protection and Biodiversity Conservation Act 1999 (Cth)
Anti-bribery and corruption laws under the Criminal Code Act 1995 (Cth)

Suppliers must also comply with applicable local and international laws in their supply chain.

4. Ethical Business Conduct

Suppliers must conduct business ethically and must not engage in:

Bribery, corruption, or facilitation payments
Fraud, deception, or misrepresentation
Collusion or anti-competitive practices
Money laundering or illegal financial activity

5. Human Rights and Labour Standards

Suppliers must respect internationally recognised human rights principles, including those outlined in the UN Guiding Principles on Business and Human Rights and International Labour Organization (ILO) standards.

Suppliers must:

Prohibit forced labour, bonded labour, and human trafficking
Prohibit child labour in all forms
Provide fair wages, benefits, and working conditions
Respect freedom of association and collective bargaining rights
Ensure non-discrimination in hiring and employment practices
Treat all workers with dignity and respect

6. Modern Slavery

Suppliers must take active steps to identify, prevent, and address modern slavery risks within their operations and supply chains.

Where applicable, suppliers must comply with reporting obligations under the Modern Slavery Act 2018 (Cth).

7. Health and Safety

Suppliers must provide a safe and healthy working environment that complies with applicable workplace health and safety laws.

Suppliers are expected to:

Identify and manage workplace risks
Provide appropriate safety training and equipment
Report and investigate workplace incidents
Promote a culture of safety and continuous improvement

8. Environmental Responsibility

Suppliers are expected to:

Comply with applicable environmental laws and regulations
Minimise environmental impact of operations
Reduce waste, emissions, and resource consumption where practicable
Properly manage hazardous substances and waste
Support sustainable practices where feasible

9. Anti-Bribery and Anti-Corruption

Suppliers must not offer, promise, give, or accept any bribe or improper benefit to influence business decisions.

Gifts, hospitality, or other benefits must not be used to improperly influence business relationships with First Choice Industrial.

10. Conflicts of Interest

Suppliers must disclose any actual or potential conflicts of interest that may affect their relationship with First Choice Industrial.

11. Confidentiality and Data Protection

Suppliers must:

Protect confidential information belonging to First Choice Industrial
Use data only for authorised business purposes
Comply with applicable privacy laws, including the Privacy Act 1988 (Cth) where relevant
Implement appropriate safeguards against data breaches

12. Subcontracting

Suppliers must not subcontract work without prior written approval from First Choice Industrial.

Where subcontracting is approved, suppliers must ensure that subcontractors comply with this Supplier Code of Conduct.

13. Monitoring and Compliance

First Choice Industrial may assess supplier compliance through:

Self-assessments or declarations
Audits or inspections (where applicable)
Performance reviews and ongoing monitoring

Suppliers are expected to cooperate fully with any compliance review.

14. Reporting Concerns

Suppliers must report any suspected breaches of this Code, including unethical, illegal, or unsafe practices, to First Choice Industrial through designated reporting channels.

Reports will be treated confidentially where possible.

15. Breach of This Code

Failure to comply with this Supplier Code of Conduct may result in:

Corrective action requirements
Suspension of contracts
Termination of business relationships
Legal action where appropriate

16. Continuous Improvement

First Choice Industrial encourages suppliers to continuously improve their ESG, ethical, and compliance practices over time.

17. Acceptance

By supplying goods or services to First Choice Industrial, suppliers acknowledge and agree to comply with this Supplier Code of Conduct.