Bradken Limited Annual Report 2015 - page 13

Supply Chain Sustainability
As a global company, we understand our responsibility to
ensure we only engage with suppliers who have responsible
and ethical business practices. Relationships with our
supply partners are managed in accordance with contractual
arrangements, our Values, our Code of Conduct and our
Compliance Program.
To identify sustainability risks across our supply chain, we use
a risk-based approach to support our suppliers’ alignment
with our health, safety, environmental and business conduct
requirements which include zero tolerance of a number of
human rights infringements including child labour, inhumane
treatment of employees and forced or compulsory labour. We
conduct business fairly and ethically, respect human rights,
comply with all laws and regulations, and follow a rigorous
Code of Conduct.
Bradken fully supports the U.S. Government signed Dodd-
Frank Wall Street Reform and Consumer Protection Act (the
“Dodd-Frank Act”), which requires all U.S. publicly traded
companies to file disclosures and reports with the SEC
related to the use of “Conflict Minerals” in their products.
Risk Management
Bradken endorses a strong risk management culture which
is embedded throughout our global group of companies.
Our Risk Management Policy provides the framework for
embedding risk identification and management into all of
our business activities, functions and processes, which is
the basis of an active and consistent risk-based approach
to sustainability.
A Board appointed Audit & Risk Committee is responsible
for approving and reviewing the effectiveness of the
Group’s systems of internal control and risk management.
The Committee carries out periodic reviews of the
effectiveness of the Group’s risk management framework
which includes determining whether Management controls
are in place to identify risks, consequences, materiality and
mitigation steps for each risk considered to require Active
Management or Controlled Monitoring.
The Committee is responsible for reviewing the
effectiveness of the management of the Group’s material
risks through a regular risk reporting process which
examines the implementation and effectiveness of risk
mitigation steps and assesses whether internal audit plans
are addressing material risks appropriately.
Code of Conduct
Bradken has a formal Code of Conduct Handbook which
provides an ethical and legal framework for all employees
in the conduct of the Company’s business and defines
how we relate to our shareholders, employees, customers,
suppliers and the community.
We implement our Code of Conduct through a variety of
training and induction programs, with all new employees
receiving and signing-off once training has been completed.
In addition, we provide regular training and undertake
periodic audits of compliance across the Bradken Group.
We encourage employees to raise any beliefs in the
existence of actual or planned breaches of the law and/
or Company policies, which include threats to health and
safety or the environment, as well as society issues such
as bribery, fraud and corruption.
Bradken has also implemented programs in each of
its Divisions which allow employees to raise matters
anonymously, using a range of support functions. Once
received, complaints are investigated and feedback is
provided to the complainant. Strict mechanisms are in
place to allow complainants to remain anonymous whilst
receiving feedback.
Plant Closure Planning
As part of the ongoing organisational restructure of Bradken’s
business, plant closure planning is a key consideration in the
development and consolidation of our business operations.
We recognise the significant risks associated with poorly
managed closure activities and seek to minimise these
throughout the life cycle of our operations.
We require plant closure plans to be developed as part of our
major capital investments to ensure we understand potential
closure liabilities and have the opportunity to reduce them
during the design stage. The closure plans provide the
basis for estimating the closure costs and the associated
accounting for closure and rehabilitation obligations.
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