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Supplier Code of Conduct


We, Us, Our – means Vortech Business Solutions Pty Ltd (ACN 091 134 486) as trustee for the Sankey Delta Trust (ABN 88 033 630 437) trading as Addax Business Solutions (ABN 88 091 134 486) or AOD (ABN 88 091 134 486) or AOD-Cloud (ABN 88 033 630 437) or QuokkaWorks (ABN 88 033 630 437) of Unit 5, 19 Wotan Street, Innaloo, Western Australia 6018 and related entities.

Policy Introduction

We expect all Suppliers to meet or exceed all applicable laws and regulations that are in force in the countries where We and our Suppliers operate. We encourage suppliers to go beyond legal compliance by committing to meet relevant international standards (such as those from the International labour Organization or applicable United Nations conventions) and to commit to continuous improvement.

The standards set forth in this Supplier Code of Conduct are intended to guide you as you fulfil your role as a supplier to us. They are not intended to change or replace any specific contractual requirements. Rather, this Supplier Code of Conduct establishes the basic principles for business conduct that We expect from Our suppliers. If Suppliers have agreed to stricter or more detailed requirements than this Supplier Code of Conduct, then We expect them to meet those contractual requirements.

This Supplier Code of Conduct has been created based on the principles We as an organisation expect our Suppliers to meet and in principle also meet internationally recognised standards such as the United Nations Declaration of Human Rights, the International labour Organization (ILO) Conventions, and  Section 54 of the Modern Slavery Act 2015 (MSA).

This Supplier Code of Conduct includes requirement in the following areas:produce further to the transparency in supply chain requirements of Section 54 of the Modern Slavery Act 2015 (MSA).

  • Ethics
  • Labour and Human Rights
  • Health and Safety
  • Environment
  • Management Systems
  • Topics


Our Suppliers shall conduct their business in accordance with the highest ethical standards.

Act Ethically

Our Suppliers shall conduct their business in accordance with the highest ethical standards and require the same compliance throughout their entire supply chain.

Our Suppliers shall demonstrate a zero-tolerance policy prohibiting any and all forms of corruption and bribery. All business dealings shall be transparently performed and accurately reflected within their records. Our Suppliers shall choose their business partners carefully and only after conducting a thorough background check and due diligence.

Our Suppliers’ monitoring and enforcement procedures must be sufficient to ensure compliance with all applicable anti-bribery and anti-corruption legislation of the countries in which they operate and with generally accepted international codes such as the provisions of the German Criminal Code, the U.S. Foreign Corrupt Practices Act (FCPA) and the Bribery Act 2010 in the United Kingdom of Great Britain.

In addition, Our Suppliers shall have a defined and enforceable policy for conducting business in an ethical manner. Formal policy on business conduct and compliance helps drive business ethically, honestly, and in full compliance with all laws and regulations.

Do not give or receive bribes

Our Suppliers shall not offer, give, receive, or solicit any bribes or other means to obtain any improper benefit or advantage. Our Suppliers shall not allow others to make improper payments for their benefit.

Disclose information truthfully

We expect that Our Suppliers shall disclose information truthfully and accurately as they pertain to their business activities, structure, financial situation, and performance in accordance with applicable laws, regulations, and prevailing industry practices.

Respect Intellectual Property Rights

Our Suppliers shall always respect Intellectual Property Rights. Any transfer of technology and know-how shall be carried out in a manner that protects Intellectual Property Rights.

Comply with fair business, advertising and competition laws

Our Suppliers shall understand and comply with all applicable fair business, advertising and competition laws including fair trading and antitrust laws.

Ensure that there are safe ways to report abuses

Our Suppliers shall create an environment where employees are comfortable raising concerns and shall have adequate “whistle-blower” or reporting channels available and feedback processes in place designed to ensure confidentiality and protection for employees and suppliers.

Avoid conflicts of interest

Our Suppliers shall avoid conflicts between them and Us by ensuring that they disclose any personal or outside business arrangements between their employees and themselves and any of Our employees or their families.

Source your materials responsibly

Our Suppliers must source materials from environmentally and socially responsible sources only. Materials, which either directly or indirectly contribute to a conflict, are unacceptable. Suppliers in this category must exercise due diligence regarding the source and chain of custody of their supplies.

Respect privacy

We expect that Our Suppliers comply with privacy and information security laws and regulatory requirements, where applicable, when processing, collecting, storing, transmitting, or sharing personal data related to customers, suppliers, consumers, and employees. Our Suppliers shall commit to protecting the reasonable privacy expectations of personal information of everyone you do business with.

Labour and Human Rights

Our Suppliers are to ensure that human resources are managed in accordance with internationally recognized principles of corporate responsibility.

Ensure that employment is freely chosen

Our Suppliers must not use forced, bonded, compulsory, or imprisoned labour.

Our Suppliers shall not force anyone into performing work and shall not be involved in any manner with human trafficking.

Do not use child labour

A “child” is any person who is younger than (i) 15 years old (or 14 where the law of the country permits); (ii) the minimum age for completing compulsory education in the country of employment; or (iii) the minimum age for employment in that country, whichever is the highest. Additionally, we expect Our Suppliers to refrain from hiring anyone under the age of 18 to carry out work which is likely to jeopardize their health, safety, or morals.

Provide adequate compensation and benefits

Our Suppliers shall ensure that their employees receive at least the minimum compensation, benefits and overtime payments required by law.

Provide employees adequate time off

Our Suppliers shall take all appropriate steps to ensure workweeks do not exceed the maximum working hours as defined by local laws or applicable collective agreements except in emergency or extraordinary situations with the consent of the employees.

Treat employees with respect and dignity

Our Suppliers shall treat all employees with respect and dignity, and ensure that they are protected from physical, sexual, verbal, or other forms of abuse, coercion, or harassment.

Do not discriminate in employment or hiring practices

Our Suppliers shall not discriminate in their employment or hiring practices. This includes discrimination based on race, colour, age, gender, gender identity or expression, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation, union membership, marital status, or any status or characteristic which does not relate to any individual’s qualifications or the inherent requirements for a position.

Allow freedom of association

Our Suppliers shall recognize their employees’ rights to join or refuse to join labour unions or associations and to bargain collectively as permitted by law.

Health and Safety

Our Suppliers shall provide their employees with a safe and healthy working environment in compliance with all applicable laws and regulations.

We expect Our Suppliers to have effective safety programs covering such areas as: human safety, emergency preparedness, chemical, physical, and biological agent exposure, ergonomics, which includes incident reporting and investigation.

Follow a Health & Safety policy & management system

Our Suppliers shall have adequate and appropriate Health & Safety policies and systems for the size and nature of their organisation.  Larger suppliers are expected to implement a Health & Safety management system (EHS).


Our Suppliers shall minimize the negative impacts their business operations have on the community, environment, and natural resources throughout their supply chain.

Comply with applicable laws

Our Suppliers shall adhere to all applicable laws, regulations.

Obtain necessary permits and observe reporting requirements

Our Suppliers must obtain, maintain, and keep current all applicable environmental permits, approvals, and registrations. Suppliers shall abide by and follow relevant operational and reporting requirements.

Do not pollute the environment or waste resources

Our Suppliers shall ensure that they identify the environmental impacts of their operations, products and/or services. In addition, and where possible, Our Suppliers shall investigate ways to improve energy efficiency and reduce greenhouse gas emissions and water consumption, as well as ways to minimize waste generation and promote reuse and recycling.

Our Suppliers shall endeavour to minimize air pollution and shall characterize, monitor, control and treat as required prior to discharge air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations.

Control any hazardous substances

Our Suppliers shall ensure that chemical and other materials – that pose a hazard if released to the environment – are identified and managed to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.

Implement proper waste management processes

Our Suppliers shall treat wastewater and solid waste generated from operations and sanitation facilities according to legal requirements and good environmental practices.

Follow an environmental management system

Where appropriate given the nature and scale of their business, Our Suppliers shall have a define an Environmental policy and implement an Environmental management system (EMS).

Management Systems

Our Suppliers have adequate management systems in place, which are designed to ensure compliance with this Code of Conduct.

Recognize and Protect Our Confidential Information

From time to time Our Suppliers may have access to Our Confidential Information and/or personal data that belongs to Our employees, customers, consumers, developers, and others. Our Suppliers shall recognize that information and take appropriate actions to protect it from misuse and unauthorized disclosure.

Our Suppliers should report any event of potential unauthorized disclosure promptly to Us. If you have questions, contact Us for help.

Commit to corporate, social and environmental responsibility

We encourage Our Suppliers to make corporate, social, and environmental responsibility statements, endorsed by executive management. These shall affirm your commitment to the values and topics addressed in this Code of Conduct and to their continuous improvement.

Understand your obligations

Our Suppliers shall ensure that they have adequate process in place for identifying, monitoring, and understanding applicable laws, regulations, and Our requirements, including the requirements of this Code of Conduct.

Assess and manage your risks

Our Suppliers shall have adequate processes in place for identifying risks (such as the environmental, health and safety, labour and human rights, ethics and legal compliance) associated with their operations and have appropriate procedural and controls to manage such risks and ensure regulatory compliance.

Communicate your expectations clearly and provide adequate training

Our Suppliers shall have sufficient processes in place to ensure that clear and accurate information about their policies, expectations, and performance, including the requirements in this Code of Conduct, is communicated to their employees, suppliers, and customers. In addition, Our Suppliers shall have sufficient training programs in place to ensure proper implementation.

Always strive for improvement

Our Suppliers shall periodically evaluate their conformity to the standards set forth in this Code of Conduct and maintain open discussions with Us in order to maintain continuous improvement and correct any deficiencies in a timely fashion.

Maintain proper documentation and records

Our Suppliers shall ensure that they and their suppliers have adequate process for the creation and maintenance of documents and records designed to ensure regulatory compliance and conformity to document along with appropriate confidentiality to protect privacy.

Violations of this Code of Conduct

Any violation of this Code of Conduct may result in corrective action. The appropriate action in a particular case depends on the nature and severity of the Code violation and the circumstances surrounding the situation.

Failure to comply with this Code and/or any additional requirements set forth by Us, or any applicable laws and regulations may result in the termination of any agreement as a supplier of ours and referral of the matter to local authorities.


Our Partners

  • Quokka Works