Human Rights Policy
1. Introduction
Suprima Bakeries Pty Ltd (“the Company”) is committed to respecting, protecting, and promoting human rights across all operations, workforce practices, procurement activities, and supply chain relationships.
The Company aligns its operations with internationally recognised human rights standards, including the:
- United Nations Guiding Principles on Business and Human Rights (UNGPs)
- Universal Declaration of Human Rights
- International Labour Organization (ILO) Conventions
- Australian legislation, including the Modern Slavery Act 2018 (Cth), Fair Work Act 2009 (Cth), and applicable work health and safety laws
The Company is committed to preventing, mitigating, and remediating adverse human rights impacts linked to its operations and business relationships.
Human rights due diligence is embedded into operational decision-making, procurement practices, and supplier management. This Policy forms part of the Company’s integrated governance framework and must be read in conjunction with related policies, including the AUS Business Ethics Policy, AUS Whistleblower Policy, AUS Grievance & Appeal Policy, AUS Recruitment and Selection Policy, AUS Workplace Discrimination and Harassment Policy, and Work Health and Safety (WHS) Policy.
2. Scope
This Policy applies to all directors, officers, employees, contractors, labour hire workers, apprentices, trainees, and any third-party suppliers or service providers engaged by or acting on behalf of the Company. It applies across all Company-controlled operations and extends to all tiers of the supply chain where the Company has either direct or indirect leverage.
All parties within scope are required to comply with this Policy as a condition of engagement. Compliance is monitored through internal review processes, supplier assessments, and audit mechanisms.
3. Governance, Accountability and Enforcement
Compliance with Suprima Bakeries integrated governance policies collectively establish mandatory standards of conduct, reporting pathways, investigative processes, and corrective action mechanisms. Managers are responsible for ensuring these policies are consistently applied and integrated into day-to-day operations.
All employees and business partners are required to comply with this Policy. Non-compliance, including failure to cooperate with investigations or audits, may result in disciplinary action up to and including termination of employment or contract. Supplier non-compliance may result in suspension, corrective action plans, or termination of the commercial relationship.
The Company maintains documented evidence of compliance, including training records, grievance records, supplier audits, and corrective action tracking, which are made available for audit purposes upon request.
4. Core Human Rights Commitments
4.1 Respectful Workplace, Non-Discrimination and Conduct Standards
The Company maintains zero tolerance for discrimination (including direct, indirect, and systemic discrimination), harassment, bullying, victimisation, or any form of workplace abuse.
Employment decisions are based on merit and must not be influenced by protected attributes under applicable legislation.
Workplace conduct is actively monitored, and breaches are promptly investigated and documented in accordance with Company procedures.
4.2 Safe and Healthy Work Environment (Integrated WHS System)
The Company is committed to providing and maintaining a safe and healthy workplace in accordance with applicable WHS legislation. The Company systematically identifies hazards, assesses risks, and implements effective controls to eliminate or minimise workplace risks, including physical and psychosocial hazards.
The Company ensures workers are consulted on health and safety matters and are encouraged to report hazards or incidents without fear of reprisal. WHS performance is monitored through incident reporting systems, risk registers, and regular workplace inspections.
4.3 Prohibition of Forced Labour and Ethical Recruitment
The Company maintains zero tolerance for all forms of forced labour, modern slavery, human trafficking, debt bondage, or involuntary labour.
Employment is strictly voluntary, and all workers retain freedom of movement and the unrestricted right to terminate employment in accordance with legal notice requirements. The Company does not retain original personal identity documents, passports, or financial security deposits as a condition of employment.
The Company prohibits all recruitment fees charged to workers directly or indirectly. All recruitment is conducted through transparent, documented, and ethical processes in accordance with the Recruitment and Selection Policy. Recruitment agencies and labour providers are subject to due diligence, contractual obligations, and ongoing monitoring.
4.4 Child Labour and Young Workers Protection
The Company strictly prohibits child labour in all forms. No person under the age of 15 years, or under the applicable legal minimum age, will be employed.
Young workers under the age of 18 are not permitted to perform hazardous work or work that may negatively impact their health, safety, or development. Where legally permitted, young workers engaged through apprenticeships, traineeships, or structured programs are subject to enhanced supervision, restricted duties, and controlled working hours to ensure safety and compliance.
4.5 Fair Employment Conditions and Freedom of Association
The Company ensures that all employees receive fair wages, lawful working hours, rest breaks, and statutory entitlements in accordance with applicable legislation and industrial instruments and Suprima Enterprises Agreement.
The Company respects the right of employees to freedom of association and collective bargaining without interference, discrimination, or retaliation. Workers are free to communicate openly with management or elected representatives regarding workplace conditions.
4.6 Supply Chain Human Rights Compliance and Monitoring
The Company requires all suppliers, contractors, and business partners to comply with this Policy and applicable human rights legislation.
Supplier compliance is assessed through a risk-based due diligence framework that includes onboarding assessments, contractual obligations, and periodic monitoring. High-risk suppliers may be subject to audits, including SMETA-aligned audits.
Where non-compliance is identified, the Company requires corrective action plans with defined timelines. Failure to implement corrective actions may result in suspension or termination of the business relationship. All supplier compliance activities are documented and retained for audit verification.
4.7 Legal and Regulatory Compliance
The Company complies with all applicable Australian legislation, including workplace relations, health and safety, anti-discrimination, privacy, and modern slavery laws.
Where international human rights standards exceed local legal requirements, the Company applies the higher standard where it is lawful and reasonably practicable to do so.
4.8 Human Rights Due Diligence and Risk Management System
The Company implements a structured, risk-based human rights due diligence system consistent with the UN Guiding Principles (UNGPs). This system includes identification of actual and potential human rights risks, integration of findings into operational and procurement decision-making, implementation of mitigation measures, tracking of effectiveness, and communication of outcomes.
4.9 Grievance Mechanism and Worker Voice
The Company provides accessible, transparent, and confidential grievance mechanisms for all workers and stakeholders.
Reports may be made through multiple channels including supervisors, HR, union representatives, or designated reporting systems. All grievances are acknowledged, recorded, and investigated in a timely and impartial manner. The Company ensures that no retaliation, victimisation, or adverse treatment occurs as a result of raising a concern in good faith.
Grievance records, investigation outcomes, and corrective actions are documented and retained.
4.10 Whistleblower Protection
The Company maintains strong protections for whistleblowers in accordance with applicable legislation and internal policy. Individuals who report concerns in good faith are protected from retaliation, dismissal, demotion, or any other adverse treatment. Any breach of whistleblower protections is treated as a serious misconduct matter.
4.11 Remediation and Corrective Action
Where the Company identifies that it has caused or contributed directly to adverse human rights impacts, it will provide or contribute to appropriate remediation. This may include corrective action, process changes, or other appropriate solutions.
Where impacts occur within the supply chain, the Company will engage suppliers to implement corrective actions within defined timeframes. Failure to remediate may result in suspension or termination of the relationship. All remediation actions are tracked and verified for effectiveness.
4.12 Training, Communication and Awareness
All employees receive human rights training at induction and at regular intervals thereafter.
The Company ensures that workers are informed of their rights and obligations in a manner that is accessible and understandable. Training records are maintained and made available for audit verification.
4.13 Privacy and Data Protection
The Company respects the privacy rights of individuals and manages personal information in accordance with applicable privacy legislation. Personal data is collected only for legitimate business purposes, stored securely, and accessed only by authorised personnel.
5. Monitoring, Audit and Continuous Improvement (SMETA 4-Pillar Alignment)
The Company maintains a structured monitoring system to assess compliance with this Policy. This includes internal reviews, supplier assessments, grievance analysis, and participation in external audits such as SMETA.
Audit findings are documented, tracked, and addressed through corrective action plans. The effectiveness of corrective actions is reviewed to ensure continuous improvement. The Company retains all relevant records to demonstrate compliance and supports full audit transparency.
6. Policy Review
This Policy is reviewed at least every three years, or more frequently where required due to legislative changes, audit outcomes, or risk changes.
Updates are approved by senior management and communicated to stakeholders.
7. References
This Policy is informed by internationally recognised frameworks, applicable legislation, and internal Company policies, including the:
- United Nations Guiding Principles on Business and Human Rights
- Universal Declaration of Human Rights
- International Labour Organisation Conventions No. 138 and No. 182
- Fair Work Act 2009 (Cth)
- Modern Slavery Act 2018 (Cth)
- AUS Recruitment Policy and Procedures
- AUS Business Ethics Policy
- AUS Whistleblower Policy
- AUS Grievance & Appeal Policy
- AUS Workplace Discrimination and Harassment Policy & Procedures
- AUS WHS Policy Statement
- Suprima Bakeries Enterprise Agreement
- SP 9.1 Approved Supplier Procedure
Further Information and Advice
For further information, contact Human Resources on 02 8796 9300.