Supplier Code of Conduct


In keeping with our company values, vision and the work that we do, Arowana is committed to the highest standards of ethical conduct, social responsibility and environmental sustainability for ourselves, and those we work with.

Consequently, Arowana takes care in selecting and fostering relationships with suppliers that operate in compliance with recognised local, national and international laws, regulations, standards and appropriate codes of practice. Suppliers that provide their workers with dignity, respect and safe working conditions, to act fairly and ethically, and be environmentally responsible wherever and whenever they supply products or perform services for us.

Ethical Requirements

  1. Labour rights, working hours and accommodation- Suppliers must respect human rights of those in their business operations and comply with all labour laws including the ability for individuals to choose employment freely and working hours, provide suitable accommodation where required and ensure that wages comply with relevant laws.
  2. Child Labour – Suppliers must ensure that they do not engage in unlawful employment or exploitation of children and are compliant with relevant global conventions.
  3. Human Trafficking – Suppliers must comply with UN Guiding Principles on Human Rights and the Modern Slavery Act (Cth). Arowana expects that Suppliers incorporate policies and practices into their business.
  4. Discrimination – Suppliers must not discriminate on the basis of age, gender, disability, ethnicity, marital status, sexual orientation or any other status protected by law.
  5. Freedom of Association – Suppliers must allow workers to freely associate with others, form and join (or refrain from joining) industrial organisations or associations of their choice, or engage in any lawful industrial activity without interference, discrimination retaliation or harassment.
  6. Improper Payments – Suppliers must not engage in any form of corruption, bribery or fraud. This includes the giving or receiving of gifts or unlawful incentives to influence a commercial outcome.
  7. Fair Trade – Suppliers must actively promote fair trade and ethical practices relevant to the goods or services provided.
  8. Conflicts – Suppliers are to avoid all conflicts of interest. This includes acting honestly and ethically in accordance with any laws pertaining to anti-competitive practices, intellectual property rights, privacy protection of company and personal data.

Health and Safety Requirements

Arowana expects Suppliers to comply with all Health and Safety regulations including:

  1. Providing a clean, healthy, hygienic and safe work environment for their employees that meets or exceeds legal standards in the jurisdiction of the relevant workplace.
  2. Documenting and distributing safety procedures to support a ‘no incident goal’.
  3. The ability for workers to easily report any safety concerns that may lead to injury or harm.
  4. Equipping workers with relevant tools and training to conduct their work safely.

Environment and Sustainability Requirements

Arowana expects Suppliers to actively work to minimise harm to the environment in accordance with applicable regulations. Minimum expectations include:

  1. Maintaining relevant policies and procedures to assist in reducing any environmental impact.
  2. Actively encourage employees and any affected third parties to practice ways of reducing harm to the environment.
  3. Abiding by any laws and regulations pertaining to the movement and disposal of hazardous materials.
  4. If the Supplier has a manufacturing facility, that it complies with any environmental laws.

Questions or Concerns

Arowana expects that Suppliers will have an avenue for their employees and other relevant parties to raise concerns or queries. Where a concern is raised, the expectation is that it will be investigated promptly, thoroughly and if necessary, anonymously. Where permitted by law, and if relevant to Arowana’s business dealings, Suppliers must inform Arowana of the concerns.

Arowana also has mechanisms available to raise concerns. Concerns and questions can be raised:

  1. Directly with the Supplier’s vendor manager; or
  2. As per our Whistleblower Policy by reporting your concern
    • by mail, marked “To the Attention of the Whistleblower Protection Officer”
    • in person or by phone to any Director of the Company’s Board, or the Company Secretary or the Company’s auditors
    • sending an email to [email protected]

Any reported concern may be made anonymously, and it will be investigated and actioned appropriately by Arowana.

Ongoing Reporting Obligation

Arowana reminds Suppliers that by agreeing to the Code they have an ongoing obligation while supplying products and/or services to Arowana to report any compliance concerns (including Modern Slavery concerns) with us. 

Compliance attestation

Arowana may request an attestation from Suppliers affirming compliance with this Code. Such attestations may include the completion of questionnaires and the review of related certification, records, permits or any other appropriate documentation. 

Further information

Any officer requiring further information should contact Human Resources or any member of the Management Team.  

Policy Review

The Company may make changes to this policy from time to time to improve the effectiveness of its operations.