Human Rights Policy

1. Purpose

This policy states VelpasConn Pty Ltd’s commitment to respecting internationally recognised human rights across its own operations and its supply chain, and explains how that commitment is carried out through the rest of the Integrated Management System. It is the umbrella under which VelpasConn’s specific people-and-rights policies sit.

This policy states VelpasConn’s responsibility to respect human rights. It is informed by, and aligns VelpasConn’s conduct with:

• United Nations Guiding Principles on Business and Human Rights (2011): the corporate responsibility to respect human rights, supported by human rights due diligence and access to remedy.
• Universal Declaration of Human Rights (1948) and the core international human rights covenants.
• ILO Declaration on Fundamental Principles and Rights at Work (1998, amended 2022) and the ten ILO fundamental conventions covering freedom of association (C87, C98), elimination of forced labour (C29, C105), abolition of child labour (C138, C182), elimination of discrimination in employment (C100, C111), and a safe and healthy working environment (C155, C187).
• Fair Work Act 2009 (Cth): minimum entitlements, freedom of association, and protection from adverse action and discrimination.
• Anti-Discrimination Act 1991 (Qld) and the Sex Discrimination Act 1984 (Cth): freedom from discrimination, harassment, and the positive duty under Respect@Work.
• Human Rights Act 2019 (Qld): the 23 protected human rights. The Act binds Queensland public entities. VelpasConn is not itself a public entity, but recognises the Act can be relevant through a client’s obligations, through contract requirements, or where VelpasConn performs functions of a public nature for a public entity.
• Work Health and Safety Act 2011 (Qld): the right to a safe and healthy workplace, including freedom from psychosocial harm.
• Modern Slavery Act 2018 (Cth) and the Privacy Act 1988 (Cth) where it applies: addressed in detail by IMS-POL-014 Modern Slavery Policy and IMS-POL-008 Privacy Policy respectively.

2. Scope

This policy applies to:

• All VelpasConn workers: Directors, employees, apprentices, contractors, and labour-hire personnel.
• All VelpasConn operations: head-contract and subcontract works, office and yard operations, and procurement.
• All suppliers and business partners: direct suppliers VelpasConn contracts with, and the deeper supply chains behind the goods and services it buys.

Relationship to the rest of the IMS. This policy is the statement-level umbrella. The day-to-day controls live in the policies and procedures it draws together, set out in the map at section 6.

Where this policy and a more specific policy both speak to a topic, the specific policy governs the detail and this policy states the overarching commitment. The two are read together and do not duplicate each other.

3. Definitions

Term	Definition
Human rights	The basic rights and freedoms that belong to every person, as set out in the Universal Declaration of Human Rights, the core UN covenants, and the ILO fundamental conventions.
Responsibility to respect	The UN Guiding Principles standard that a business should avoid infringing the human rights of others and address adverse impacts it causes, contributes to, or is directly linked to.
Human rights due diligence	The ongoing process of identifying, preventing, mitigating, and accounting for how a business addresses its human rights impacts.
Salient human rights issues	The human rights at risk of the most severe negative impact through a business’s activities and relationships. The priority for action.
Rightsholder	A person or group whose human rights may be affected by VelpasConn’s operations or supply chain, including workers, labour-hire personnel, supply-chain workers, First Nations people, and affected community members.
Grievance mechanism	A process through which a person can raise a human rights concern and seek a remedy, without fear of retaliation.
Remediation or remedy	The action taken to make good a human rights harm, prioritising the affected person’s safety and wishes.

4. Policy Statement

VelpasConn respects the human rights of everyone affected by its work: its own people, the workers in its supply chain, and the communities around its sites. Where VelpasConn causes, contributes to, or is linked to a human rights harm, it acts to address it and to support access to a remedy.

Our commitments:

1. Respect across our footprint. VelpasConn respects internationally recognised human rights in its operations and expects the same through its supply chain, applied proportionately to its size and influence, and using its leverage with suppliers where it does not directly control an outcome.
2. No discrimination, equal opportunity. VelpasConn does not discriminate on the basis of race, sex, age, disability, religion, sexual orientation, gender identity, family responsibilities, or any other protected attribute, and provides equal opportunity in employment.
3. Freedom from modern slavery. VelpasConn does not tolerate modern slavery in any form, in its operations or its supply chain, as set out in IMS-POL-014 Modern Slavery Policy.
4. Fair work and freedom of association. Every worker is paid at least their lawful minimum and engaged under lawful conditions, and is free to exercise their lawful workplace rights under the Fair Work Act 2009 (Cth), including to join or not join a union and to take part in lawful bargaining.
5. Safe and healthy work. VelpasConn protects the physical and psychological health and safety of its workers, consistent with the Work Health and Safety Act 2011 (Qld) and the IMS safety framework.
6. Freedom from bullying, harassment, and victimisation. VelpasConn provides a workplace free of bullying, sexual harassment, and discrimination, as set out in IMS-POL-004 Workplace Behaviour Policy.
7. Privacy. VelpasConn handles personal information lawfully and respectfully, as set out in IMS-POL-008 Privacy Policy.
8. Respect for First Nations people and cultural heritage. VelpasConn respects the rights and heritage of Aboriginal and Torres Strait Islander people and meets its cultural-heritage duty of care under the Aboriginal Cultural Heritage Act 2003 (Qld) and the Torres Strait Islander Cultural Heritage Act 2003 (Qld) on its projects.
9. Respect for community rights. VelpasConn manages the effect of its work on neighbours and the community, and provides a way for them to raise concerns.
10. Access to remedy. Anyone affected by a human rights harm connected to VelpasConn can raise it through the channels in section 9, without retaliation, and VelpasConn works to remedy substantiated harm.
11. Expectations flow down. VelpasConn expects its suppliers and business partners to hold to these standards and to extend them to their own suppliers.

5. Salient Human Rights Risks

VelpasConn is a Queensland commercial and residential construction company operating as head contractor and subcontractor. For a business of this kind, the human rights most at risk of severe impact are:

Salient issue	Where it arises	Primary control
Work health and safety	Construction is high-hazard work; the right to life and to safe work is the most significant direct risk.	WHS framework (IMS-PRO-C series, SWIs, risk assessments)
Psychosocial health	Fatigue, bullying, harassment, and work pressure.	IMS-POL-003, IMS-POL-004; Qld Psychosocial Hazards Code of Practice
Modern slavery in the supply chain	Labour hire, cleaning, and imported building products (bricks, stone, timber, steel, solar PV, electronics, PPE).	IMS-POL-014; IMS-POL-012 section 8; IMS-PRO-814; IMS-FRM-016
Discrimination and harassment	Recruitment, engagement, and day-to-day conduct on site.	IMS-POL-004; IMS-POL-006
Rights of vulnerable workers	Visa holders and labour-hire workers are more exposed to underpayment and exploitation.	IMS-PRO-HR-001; licensed labour hire (IMS-POL-014 section 6)
First Nations rights and cultural heritage	Ground-disturbing work near culturally significant areas.	Cultural-heritage duty of care under the Aboriginal and Torres Strait Islander Cultural Heritage Acts 2003 (Qld); project intake screen (IMS-PRO-401)
Community rights	Noise, dust, access, and amenity effects on neighbours.	Stakeholder communication and complaints (IMS-PRO-C09)
Privacy	Worker and client personal information.	IMS-POL-008

VelpasConn’s response is proportionate to its size and to where it has the most control. The most controllable risks, its own workers’ safety and the labour it engages through others, get the most direct attention.

6. How VelpasConn Meets Its Human Rights Commitments

Human rights at VelpasConn are operationalised through the existing IMS rather than through this policy alone. This map is the practical answer to “do you have a human rights policy and how does it work.”

Human right or theme	VelpasConn instrument
Freedom from modern slavery, servitude, and forced labour	IMS-POL-014 Modern Slavery Policy; IMS-POL-012 section 8; IMS-PRO-814; IMS-FRM-016
Freedom from discrimination; equal opportunity; freedom from bullying and harassment	IMS-POL-004 Workplace Behaviour Policy; IMS-POL-006 Code of Conduct
Safe and healthy work (physical)	IMS WHS framework: IMS-PRO-C01 to C13, Safe Work Instructions, risk assessments
Safe and healthy work (psychosocial)	IMS-POL-003 Fatigue Management; IMS-POL-004; IMS-POL-010 Family and Domestic Violence
Fair pay, lawful conditions, freedom of association	IMS-PRO-HR-001; Fair Work Act compliance through payroll and engagement
Privacy and protection of personal information	IMS-POL-008 Privacy Policy
Right to raise concerns and seek a remedy	IMS-POL-007 Whistleblower Policy; section 9 of this policy
Rights of First Nations people and cultural heritage	Cultural-heritage duty of care under the Aboriginal and Torres Strait Islander Cultural Heritage Acts 2003 (Qld); IMS-PRO-401 project intake
Community and stakeholder rights	IMS-PRO-C09 Stakeholder Communication and Complaints

7. Human Rights Due Diligence

VelpasConn applies the UN Guiding Principles due-diligence approach, scaled to its size, through the controls it already operates:

1. Identify and assess. Human rights risks are considered at project intake (IMS-PRO-401), in WHS risk assessment, and in vendor prequalification (IMS-PRO-814, IMS-FRM-016). The salient risks are listed at section 5.
2. Integrate and act. Controls are built into the relevant procedures rather than bolted on: safe-work method statements for high-risk work, licensed labour hire only, modern-slavery onboarding questions for higher-risk vendors, and contract clauses that flow expectations down.
3. Track. Concerns raised, incidents, and corrective actions are recorded and reviewed, including at management review (IMS-PRO-901).
4. Communicate. VelpasConn answers client and tender questions about its human rights approach honestly, and reviews this policy as set out in section 14.

The supply-chain detail for modern slavery, the most significant supply-chain human rights risk, sits in IMS-POL-014 and IMS-POL-012 section 8.

8. Supplier and Business-Partner Expectations

VelpasConn expects every material supplier, subcontractor, and labour-hire provider to:

• respect the human rights of their workers and the workers in their own supply chains;
• pay at least lawful minimums, meet superannuation and workers’ compensation obligations, and engage workers under lawful and safe conditions;
• not use modern slavery, child labour, or unlawful discrimination, and not engage in sham contracting;
• hold a current Queensland labour-hire licence where they supply labour;
• take reasonable steps to extend these expectations to their own suppliers; and
• tell VelpasConn promptly if they become aware of a human rights harm connected to VelpasConn’s work.

These expectations are tested at prequalification (IMS-FRM-016) and written into Tier 3 and above contracts (IMS-POL-012 section 10). For modern slavery specifically, the detailed supplier controls sit in IMS-POL-014 section 7 and IMS-POL-012 section 8; this section states the broader human-rights expectation.

A supplier that will not meet them, or that is found to have an unremedied human rights harm in its operations, is not engaged again.

9. Raising Concerns and Access to Remedy

Anyone, a VelpasConn worker or a person in its supply chain or community, can raise a human rights concern. There is no requirement to be certain, and no penalty for a concern raised in good faith that turns out to be unfounded.

How to raise a concern:

• Directly to a supervisor, the Managing Director, or any Director.
• Through the reporting channel under IMS-POL-007 Whistleblower Policy. A disclosure may attract the statutory whistleblower protections under the Corporations Act 2001 (Cth) where it meets that Act’s criteria; the no-retaliation commitment below applies in any case.
• Externally, where a person prefers: for example 000 or the Queensland Police Service if anyone is in immediate danger, the Fair Work Ombudsman (pay and conditions), the Queensland Human Rights Commission (discrimination and Qld Human Rights Act matters), the Australian Human Rights Commission, or the Australian Federal Police (modern slavery and trafficking).

No retaliation. VelpasConn does not tolerate any detriment to a person because they raised a human rights concern in good faith, whether they are a VelpasConn worker or a worker in the supply chain. Retaliation is itself a breach of this policy and of IMS-POL-006 Code of Conduct.

Remedy. Where VelpasConn finds it has caused, contributed to, or is linked to a human rights harm, it responds on a victim-centred basis: the affected person’s safety and wishes come first, the cause is fixed, a corrective action is raised under IMS-PRO-1002, and any required notifications are made. Modern slavery harms follow the remediation steps in IMS-POL-014 section 10.

10. Training and Awareness

1. Induction. New workers are made aware of this policy and the right to raise a concern at induction (IMS-PRO-C08).
2. Toolbox awareness. Workers are briefed on the practical human rights risks relevant to their role, including signs of labour exploitation on site, through toolbox talks (IMS-PRO-C11).
3. Procurement awareness. Workers who engage suppliers and labour hire understand the due-diligence steps in sections 7 and 8.

Training is proportionate to role and grows with the business.

11. Roles and Responsibilities

Role	Responsibility
Managing Director	Owns this policy. Final decision-maker on a substantiated human rights harm. Approves remediation. Answers client and tender questions on VelpasConn’s human rights position.
Director (Executive)	Applies the policy within delegated authority. Escalates concerns to the Managing Director.
Project Manager	Applies human rights due diligence on assigned projects, including vendor and labour-hire checks and cultural-heritage duty of care.
Site Supervisor	Watches for human rights risks on site, including unsafe work and signs of labour exploitation, and raises concerns promptly.
All workers	Treat others with respect, understand the right to raise a concern, and report any human rights concern.

The Position-Name Register (IMS-REG-013) is the single source of truth for who holds each role.

12. Related Policies and Procedures

• IMS-POL-014 Modern Slavery Policy (supply-chain human rights; modern slavery detail).
• IMS-POL-004 Workplace Behaviour Policy (discrimination, bullying, harassment, EEO).
• IMS-POL-006 Code of Conduct (respect, integrity, the no-retaliation standard).
• IMS-POL-007 Whistleblower Policy (the channel and statutory protections in section 9).
• IMS-POL-008 Privacy Policy (personal information).
• IMS-POL-003 Fatigue Management and IMS-POL-010 Family and Domestic Violence (psychosocial safety).
• IMS-POL-012 Procurement Policy (section 8 supply-chain due diligence; section 10 contract clauses).
• IMS-PRO-HR-001 Casual Employment Classification and Labour Hire Engagement (fair-work and labour-hire controls).
• IMS-PRO-814 Subcontractor Management and Procurement and IMS-FRM-016 Subcontractor Pre-Qualification Questionnaire.
• IMS-PRO-401 Understanding the Organisation and its Context (project intake, cultural heritage screen).
• IMS-PRO-C09 Stakeholder Communication and Complaints (community concerns).
• IMS-PRO-1002 Nonconformity and Corrective Action.

13. References

International instruments:

• United Nations Guiding Principles on Business and Human Rights (2011).
• Universal Declaration of Human Rights (1948); International Covenant on Civil and Political Rights; International Covenant on Economic, Social and Cultural Rights.
• ILO Declaration on Fundamental Principles and Rights at Work (1998, amended 2022); ILO fundamental conventions C29, C87, C98, C100, C105, C111, C138, C155, C182, C187.

Legislation:

• Human Rights Act 2019 (Qld).
• Fair Work Act 2009 (Cth).
• Anti-Discrimination Act 1991 (Qld); Sex Discrimination Act 1984 (Cth); Disability Discrimination Act 1992 (Cth); Racial Discrimination Act 1975 (Cth); Age Discrimination Act 2004 (Cth).
• Work Health and Safety Act 2011 (Qld).
• Aboriginal Cultural Heritage Act 2003 (Qld); Torres Strait Islander Cultural Heritage Act 2003 (Qld).
• Modern Slavery Act 2018 (Cth).
• Privacy Act 1988 (Cth).

14. Policy Review

This policy is reviewed annually, and immediately when:

• A material change occurs in Australian human rights, anti-discrimination, work health and safety, or modern slavery law.
• A human rights concern raised under section 9 reveals a gap in the policy or the controls behind it.
• A major client or principal contractor sets a human rights requirement beyond what this policy provides.
• One of the policies or procedures this policy draws together (section 6) is restructured in a way that affects the human rights commitments.

The policy owner is the Managing Director.

This policy is part of the VelpasConn Pty Ltd Integrated Management System.