Supplier Code of Conduct


CDC is committed to ethical, sustainable and socially responsible procurement.

This Code sets out CDC’s expectations of its Suppliers, as trusted partners of CDC, in the areas of integrity, ethics and conduct, conflict of interest, corporate governance, labour and human rights, health and safety and environmental management.


In this Code:

Code means this Supplier Code of Conduct.
CDC means ComfortDelGro Corporation Australia Pty Ltd and all of its related entities in Australia.
Law means laws, regulations and rules.
Supplier means all businesses that are involved in supply of goods or services to CDC.
supply chain includes first tier direct suppliers and all sub-suppliers and subcontractors including, in the case of the supply of goods, down to the supplier of raw materials used in the production of those goods.
workers means all employees, including permanent, part time, contract and temporary workers engaged by CDC’s Suppliers or subcontractors, or otherwise in CDC’s supply chain.

1. Minimum requirements

CDC expects its Suppliers to operate in a manner that meets or exceeds the minimum expectations outlined in this Code and, in doing so, to:

  1. demonstrate suitable measures are in place to meet these requirements; and
  2. continuously strive to improve the standard of its business practices.

Fundamental to this Code is an expectation that Suppliers:

  1. operate in full compliance with all Laws, international and industry standards of the jurisdiction(s) in which they do business;
  2. respond to requests for information from CDC in a timely manner, including but not limited to questionnaires, interviews, site visits, audits and corrective action plans;
  3. provide a true and accurate account of their operations and supply chain when responding to requests for information from CDC;
  4. have processes in place for workers to report non-compliance with this Code anonymously and free of retribution or other unfavourable treatment; and
  5. remedy any non-compliance with this code as a matter of priority.

Suppliers should have in place policies and management systems that align with this Code and clear managerial responsibility for performance measurement and evaluation as well as continuous improvement.

2. Application of this Code

This Code applies to procurement activities of CDC regardless of the value of the goods or services procured. CDC expects Suppliers to understand and comply with the Code and to educate the Supplier’s related entities, subcontractors and extended supply chain about the principles and requirements of this Code.

3. Corrective action process

CDC recognises the importance of working collaboratively with its Suppliers to achieve compliance with this Code throughout the CDC supply chain.

Suppliers are expected to self-assess their compliance with the Code and take timely action to address any shortcomings reported or identified by such assessment. Suppliers are encouraged to raise any concerns, discuss and seek clarification of the Code from CDC’s GM Procurement or the primary CDC contact in relation to the goods or services the Supplier provides.

CDC reserves the right to periodically request evidence and confirmation of Suppliers’ compliance with the Code, including the provision of documents and records that support their compliance. Suppliers are expected to support CDC in reviewing compliance with the Code.

4. Standards expected of Suppliers

4.1 Integrity, ethics and conduct

CDC expects all aspects of its Suppliers’ business to be conducted in an ethical manner and in compliance with all applicable Laws.

4.1.1 Business integrity

CDC’s view is that bribery and corruption are unethical and unacceptable and are inconsistent with our values. Suppliers are expected to comply with all anti-bribery, anti-corruption, anti-money laundering, and modern slavery laws. Suppliers must not engage in, either directly or indirectly, fraudulent, corrupt, exploitative or collusive activities, and must employ reasonable measures and controls to ensure their workers and suppliers do not engage is such conduct either.

4.1.2 Record keeping and documentation

Suppliers are expected to maintain adequate records that accurately record all financial transactions and information regarding their business activities, labour, health and safety and environmental practices in accordance with applicable laws, policies and procedures. Disclosure of information is expected to be undertaken without falsification or misrepresentation.

4.1.3 Professional conduct

Suppliers are expected to conduct themselves in a manner that is fair, professional and to not act in a manner that may, by association, bring CDC into disrepute.

4.1.4 Confidentiality and privacy

Suppliers must not improperly use any private, confidential or commercially sensitive information in their possession relating to or in connection with their dealings with CDC. CDC expects Suppliers not to discuss or disclose dealings with CDC to the media without approval.

CDC expects Suppliers to protect personal privacy and comply with applicable privacy Law as well as secure data against unauthorised access or use in accordance with CDC’s standards.

4.1.5 Social media

CDC is committed to using social media platforms responsibly and being courteous and respectful of others. CDC expects its Suppliers to:

  1. refrain from disrespectful, unprofessional, harassing, defamatory, discriminatory and prohibited activity on social media platforms;
  2. not act or speak on CDC’s behalf or represent themselves as CDC or express any views attributable to CDC unless expressly authorised to do so by CDC; and
  3. not use CDC’s brands or logos except as expressly permitted by CDC in writing.

4.2 Conflicts of interest

CDC takes the view that all business activities should be undertaken with impartiality and any conflict of interest should be raised and managed.

Conflict of interest is a situation that may undermine the impartiality of a person because of the possibility of a clash between a person’s self-interest, professional interest or public interest.

4.2.1 Conflict of interest

Suppliers must:

  1. declare to CDC’s general manager of procurement or the primary CDC contact for the goods or services being provided, any situation that raises an actual, potential or perceived conflict of interest related to or in connection with the Supplier’s dealings with CDC; and
  2. avoid financial, business or other relationships which may compromise the performance of their duties under their business arrangement with CDC. Any conflicts of interest that cannot be avoided are expected to be declared and managed appropriately.

4.2.2 Anti-competitive conduct and innovation

Suppliers should encourage innovation and competition and must not act in a manner which involves a misuse of market power or would be otherwise improper (including, for example, collusive arrangements, price fixing or predatory pricing).

Where pricing is to be submitted to CDC in a competitive tender, Suppliers must determine their pricing independently and without communication with other tender respondents.

4.2.3 Gifts, Entertainment and Hospitality

Suppliers should never give or receive any gift, entertainment or hospitality that is intended to influence a decision made on behalf of CDC. CDC accepts that gifts and entertainment are sometimes offered out of good will or to express thanks. Suppliers should only give or accept gifts or entertainment if they are modest and nothing is expected in return.

4.3 Corporate governance

CDC expects Suppliers to manage their administration and risk systems in accordance with best practice corporate management practice as it is CDC’s view that this is key to ensuring a reliable supply chain.

4.3.1 Risk assessment and management

Suppliers should develop and maintain a process to identify, manage and control relevant risks associated with their operations. These include supply chain risks and risks relating to labour and human rights, health and safety, the environment, business ethics and corporate governance.

4.3.2 Critical incident management

Suppliers should:

  1. identify and assess potential critical incident, emergency situations and business continuity risk; and
  2. develop and implement emergency plans and response procedures that minimise harm to life, environment and property, while ensuring recovery and continuity of supply or services to CDC.

4.4 Labour and human rights

CDC believes that all workers in its supply chain deserve to be treated with dignity and respect. CDC therefore expects Suppliers to provide a fair and ethical workplace, upholding high standards of human rights that apply to all workers, with appropriate labour and human rights policies and practices applied in its business.

4.4.1 Discrimination, harassment and bullying

CDC is committed to providing a workplace free from discrimination, harassment and bullying. CDC’s Suppliers are expected to:

  1. comply with workplace Laws in respect of discrimination, harassment and bullying in their operations and supply chain;
  2. have and uphold reasonable standards of behaviour in the workplace which apply to all workers; and
  3. ensure its work environments are inclusive and its recruitment and employment practices are free from discrimination based on age, religion, culture, ethnicity, gender, sexual orientation, marital status, family responsibilities, disability or health status of workers in accordance with law.

4.4.2 Human rights and modern slavery

CDC is committed to preventing and ending all forms of modern slavery, child labour and human trafficking in our supply chain.

Suppliers are expected to provide goods and services in a manner consistent with applicable human rights obligations and to make all reasonable efforts to ensure businesses within their supply chain are not engaged in or complicit with human rights abuses such as forced child labour.

Consistent with relevant modern slavery legislation, Suppliers are expected to proactively identify, address and – where required by legislation – report on risks of modern slavery practices (defined broadly to include all forms of human trafficking, forced labour and slavery-like practices) in their business operations and supply chains. Suppliers must address any adverse impacts on human rights and/or working conditions arising from decisions made by the Supplier.

4.4.3 Prevention of involuntary and underage labour

Suppliers are expected to:

  1. ensure that all work is undertaken without coercion;
  2. not require children to engage in hazardous work which may cause harm to their health, safety or morals;
  3. not use any form of forced, bonded or indentured labour;
  4. employ only workers who are the applicable minimum legal age where the work is undertaken; and
  5. ensure identified forced and child labour impacts are remediated as soon as reasonably practicable.

All use of temporary and outsourced labour should be within the limits of the law. Suppliers are therefore expected to:

  1. use all reasonable endeavours to ensure that the third party recruitment agencies it uses are compliant with the provisions of this Code and applicable law; and
  2. be responsible for payment of all recruitment related fees and expenses in recruiting foreign contract workers either directly or through third party agencies.

4.4.4 Working hours, wages and benefits

Suppliers must:

  1. comply with all applicable Laws and industrial instruments with respect to wages, working hours and workers compensation insurance;
  2. ensure that workers are correctly engaged and classified as either employees or independent contractors and treated as such;
  3. ensure that all workers receive their legally mandated minimum wages, benefits, superannuation, leave entitlements and time off for legally recognised holidays; and
  4. pay workers’ wages as required under applicable laws in a timely manner and not be expected to use wage deductions as a disciplinary measure. All overtime is expected to be reasonable and paid at the rate and in accordance with the applicable laws.

4.4.5 Subcontractor payment terms

CDC wants to do business with Suppliers that offer payment terms to subcontractors that are no less favourable than those provided to the Supplier by CDC (unless otherwise mutually agreed with the subcontractor).

In particular, CDC expects Suppliers to promptly process, manage and finalise all legitimate claims for payment made by its suppliers and subcontractors.

Suppliers must keep a register of subcontractors. This register must be made available to CDC upon request.

4.4.6 Freedom of association and collective bargaining

Suppliers are expected to freely allow workers to associate with others, form and join (or refrain from joining) industrial organisations or associations of their choice and bargain collectively, or engage in any lawful industrial activity without interference, discrimination, retaliation or harassment.

Suppliers must ensure worker representative are not discriminated against and have regular access to carry out their representative functions in the workplace.

4.5 Health and safety

Worker health, safety and wellbeing is important to CDC. Suppliers are expected to provide a healthy and safe work environment and integrate sound health and safety management practices into its business.

4.5.1 Workplace health and safety management

Suppliers must comply with all applicable laws relating to workplace health and safety in their operations and supply chain.

Suppliers are expected to:

  1. have processes in place to prevent and minimise occupational health and safety hazards; and
  2. provide workers with job related training and consult with employees in relation to the provision of information and training.

4.5.2 Environmental management

CDC cares for our environment and is committed to a sustainable future.

CDC expects Suppliers to:

  1. comply with relevant environmental protection Laws and standards; and
  2. establish programs that seek to minimise the environmental impact of their operation and supply chain and maintain environmentally responsible policies and practices.

4.5.3 Environmental impacts

Suppliers must comply with all applicable laws and regulations relating to the environment, including any management and reporting obligations. Suppliers are expected to manage the environmental impact of their operations by:

  1. ensuring the safe storage, transportation and disposal of hazardous substances including hazardous waste;
  2. maintaining policies and practices for the efficient use of energy, water and natural resource consumption; and
  3. maintaining policies and practices that reduce the risk of pollution, loss of biodiversity, deforestation, damage to ecosystems and greenhouse gas emissions

5. Continuous Improvement

The standards of conduct described in this Code are important to the ongoing success of CDC. Where applicable, CDC will support Suppliers in the establishment of leading practices in order to meet and exceed the standards outlined in this Code.

As a Supplier to CDC the Supplier’s role begins, but does not end, with understanding this Code. If any ethical or legal compliance issues arise that raise any questions, the Supplier has the responsibility to notify CDC immediately.


This Code will be reviewed annually.

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