Policies - 360 Facilities

Through Actions, Not Words, We Are Unrivaled.

360 Facilities champions exceptional cleaning services, prioritizing a balanced work-life culture. Our guiding policies ensure professionalism, respect, and perpetual growth, embracing global best practices and freedom of association.

Work Health & Safety Policy

Purpose

360 Facilities Pty Ltd is committed to providing and maintaining a safe and healthy workplace for all employees, contractors, visitors, and other persons affected by our operations.

We recognise that the prevention of work-related injury and ill-health is fundamental to the success of our business and the wellbeing of our people.

Scope

This policy applies to all 360 Facilities workplaces, activities, and personnel, including subcontractors and visitors engaged in the provision of our commercial cleaning and facility management services.

Policy Statement

360 Facilities specialises in commercial cleaning and facility services, including:

General Cleaning
Builders Cleans
Pressure Washing
Steam Cleaning
Floor Strip & Sealing
Facility Cleaning Management

Our Work Health and Safety (WHS) Management System has been developed in accordance with ISO 45001:2018 – Occupational Health and Safety Management Systems and demonstrates our commitment to:

Fulfil legal and other requirements relevant to WHS.
Eliminate hazards and reduce risks to prevent injury and ill-health.
Continually improve the effectiveness of our WHS Management System.
Consult with and encourage participation of workers and, where applicable, their representatives in WHS decision-making.

We understand that maintaining a safe and healthy working environment is a key organisational responsibility.

All workers with management or supervisory duties are personally accountable for ensuring the health and safety of those under their direction.

Risk assessments and safe work procedures have been prepared in consultation with workers and are issued to ensure hazards are identified and controlled.

Worker Responsibilities

All workers, contractors, and visitors are expected to:

Follow safe work practices and instructions at all times.
Report hazards, incidents, or unsafe conditions immediately.
Take reasonable care for their own health and safety and that of others.
Participate in safety training, meetings, and consultation processes.

Objectives and Targets

WHS objectives and targets are established annually, based on:

The context of the organisation;
The needs and expectations of interested parties; and
Identified risks and opportunities.

Progress is reviewed regularly through inspections, audits, and management review meetings.

Resources and Training

360 Facilities will provide sufficient resources to:

Implement, maintain, and continually improve the WHS Management System;
Deliver ongoing training and competency development for all workers;
Promote early intervention, rehabilitation, and return-to-work programs.

Commitment to Continuous Improvement

Work Health and Safety is everyone’s responsibility.
Through leadership, communication, and participation, 360 Facilities aims to create a proactive safety culture that achieves our shared goal:

“A safe, healthy, and productive workplace for all.”

Compliance & Related Legislation

This policy aligns with:

Work Health and Safety Act 2012 (SA)
Work Health and Safety Regulations 2012 (SA)
Fair Work Act 2009 (Cth)
ISO 45001:2018 – Occupational Health and Safety Management Systems

Supporting Documents:

Risk Assessment Procedure
Incident & Hazard Reporting Procedure
Contractor Management Policy (CD-105)
Environmental Policy (CD-03)
Code of Conduct (CD-100)

Review & Continuous Improvement

This policy will be reviewed biennially or earlier if legislation, standards, or organisational needs change.

Feedback from employees, audits, and performance data will guide continual improvement.

Enviromental Policy

Purpose

360 Facilities Pty Ltd is committed to minimising environmental impact and promoting sustainability through the implementation of an Environmental Management System (EMS) aligned with ISO 14001:2015. Our goal is to deliver exceptional cleaning and facility-management services while protecting the environment, conserving resources, and supporting a sustainable future.

Scope

This policy applies to all 360 Facilities operations, employees, contractors, and subcontractors across Australia engaged in the delivery of cleaning, waste, and facility-management services.

Policy Statement

360 Facilities strives to operate in an environmentally responsible manner by:

Reducing pollution, waste, and emissions across all business operations.
Promoting the efficient use of energy, water, and cleaning resources.
Implementing processes that comply with or exceed relevant environmental legislation and standards.
Continuously improving environmental performance through innovation, training, and collaboration with sustainable partners.

Responsibilities

Management and Supervisors

Integrate sustainable practices into daily operations.
Ensure compliance with environmental laws, regulations, and contractual obligations.
Provide adequate training, supervision, and resources to meet environmental objectives.
Monitor and report on environmental performance through internal audits and reviews.

Employees and Contractors

Follow environmental procedures and actively support sustainability initiatives.
Use cleaning products, equipment, and materials responsibly to reduce waste.
Report spills, leaks, or incidents that may pose environmental risks.
Participate in training and improvement programs.

Compliance & Related Legislation

This policy is informed by and complies with:

Environment Protection Act 1993 (SA)
Environment Protection (Air Quality) Policy 2016 (SA)
Environment Protection (Waste to Resources) Policy 2010 (SA)
Work Health and Safety Act 2012 (SA)
ISO 14001:2015 – Environmental Management Systems
Fair Work Act 2009 (Cth) (in relation to environmental responsibilities at work)

Review & Continuous Improvement

This policy will be reviewed annually, or sooner if legislation, industry standards, or organisational objectives change. 360 Facilities is committed to preventing pollution, fulfilling all compliance obligations, and continually improving its Environmental Management System.

Equal Employment Oppourtunity And Harrassment Policy

Purpose

360 Facilities Pty Ltd is committed to ensuring employment, development, and promotion decisions are based solely on merit, capability, and performance — free from discrimination, bias, or prejudice. Our aim is to foster a fair and inclusive workplace where every individual is valued and given equal opportunity to contribute and succeed.

Scope

This policy applies to all 360 Facilities employees, contractors, and management across all stages of employment, including recruitment, selection, induction, training, performance appraisal, promotion, and termination.

Policy Statement

360 Facilities promotes Equal Employment Opportunity (EEO) in accordance with the Fair Work Act 2009 (Cth) and the Equal Opportunity Act 1984 (SA). All employment-related decisions must be made on objective criteria relating to skills, experience, and qualifications.

Discrimination, harassment, or victimisation based on any of the following protected attributes is strictly prohibited:

Sex, marital or parental status, pregnancy, breastfeeding, or lawful sexual activity
Gender identity or sexual orientation
Age, race, colour, national or ethnic origin
Religious or political belief or activity
Disability, medical condition, or impairment
Trade union membership or participation
Association with or relation to a person identified by any of these attributes

360 Facilities ensures that EEO principles are applied to:

Recruitment and selection
Placement and work assignments
Terms and conditions of employment
Access to training, transfer, or promotion opportunities
Decision-making, remuneration, and recognition
Counselling, discipline, or termination procedures

Responsibilities

Management and Supervisors

Must ensure all decisions are made on merit and free from unlawful discrimination.
Are responsible for promoting and maintaining an inclusive, respectful workplace.
Must address all complaints promptly and ensure complainants and witnesses are not victimised.

Employees and Workers

Must comply with this policy and treat others respectfully.
Must not engage in any form of discriminatory behaviour or harassment.
Must report suspected breaches to their direct supervisor, or if inappropriate, escalate to the next management level.

Compliance & Related Legislation

This policy complies with and is guided by:

Fair Work Act 2009 (Cth)
Equal Opportunity Act 1984 (SA)
Work Health and Safety Act 2012 (SA)
Fair Work Regulations 2009 (Cth)
Cleaning Services Award 2020 (MA000022)

Review & Continuous Improvement

This policy will be reviewed every two years, or earlier if there are legislative or organisational changes. 360 Facilities will continue to monitor workplace equity, review recruitment and management practices, and provide regular EEO awareness training to ensure compliance and continuous improvement.

Modern Slavery Policy

Purpose

360 Facilities Pty Ltd is committed to upholding human rights, ethical labour practices, and regulatory compliance across all operations and within every tier of our supply chain.

This policy outlines our proactive measures to identify, prevent, and eliminate modern slavery, forced labour, and human trafficking, while ensuring compliance with the Modern Slavery Act 2018 (Cth), the Fair Work Act 2009 (Cth), and relevant state-based labour hire and WHS legislation.

Scope

This policy applies to all employees, contractors, suppliers, and business partners engaged by 360 Facilities Pty Ltd throughout Australia and internationally.

It governs procurement, recruitment, supplier management, and compliance processes across our integrated cleaning and facilities-management operations.

Policy Statement

Although 360 Facilities does not currently meet the financial threshold for mandatory reporting under the Modern Slavery Act, we voluntarily align with its principles as part of our ethical business framework.

We believe every individual has the right to live and work in conditions of freedom and dignity, free from exploitation.

Our organisation maintains zero tolerance toward modern slavery and requires the same commitment from all entities within our supply chain.

Responsibilities

Management

Ensure systems and controls are in place to identify and mitigate the risk of modern slavery.
Approve and review suppliers through formal evaluation processes, including Cm3 prequalification where applicable.
Ensure all contracts contain clauses prohibiting forced or child labour and mandate compliance with Australian workplace laws.

Employees & Contractors

Must comply with this policy, report any suspected unethical practices, and complete annual Modern Slavery and Ethical Procurement training.

Suppliers & Subcontractors

Must adopt and maintain a Modern Slavery Policy or equivalent ethical sourcing procedure.
Must maintain accurate employment, wage, and age-verification records for all workers.
Must maintain Cm3 Work Health & Safety and compliance certification (or equivalent).

Key Commitments

Human Rights & Modern Slavery Prevention

360 Facilities prohibits all forms of human trafficking, slavery, servitude, forced or compulsory labour, debt bondage, deceptive recruiting, and child labour.
Our due-diligence framework includes:

Supplier pre-qualification questionnaires and risk assessments.
Contract clauses addressing ethical labour practices.
Supplier audits and site inspections in high-risk sectors such as PPE and consumables.
Annual risk reviews and non-conformance tracking.
Whistleblower and confidential reporting channels for suspected violations.

Fair Employment & Award Wages

We ensure every employee is remunerated in accordance with the National Employment Standards (NES) and the Cleaning Services Award 2020 (MA000022).
This commitment reflects our respect for workers’ rights, equality, and the principle of fair reward for labour.

Labour Hire Licensing Compliance

360 Facilities maintains full compliance with the Labour Hire Licensing Act 2017 (SA) and equivalent state legislation in Queensland and Victoria.
We hold current licences where required and monitor regulatory developments in all other jurisdictions to ensure ongoing compliance.
All labour hire partners must be licensed and verified before engagement.

Cm3 Work Health & Safety & Compliance Management

360 Facilities uses Cm3 Work Health & Safety & Compliance Management to ensure all contractors meet stringent standards for WHS, insurance, and competency.
Cm3 provides a secure, web-based system to prequalify, evaluate, and monitor contractor compliance.
By leveraging Cm3, 360 Facilities ensures:

Verification of licences, insurances, and safety documentation.
Continuous monitoring of contractor performance.
Demonstrated due diligence to clients through transparent reporting.
Enhanced safety, sustainability, and risk management across all operations.

Compliance & Related Legislation

This policy aligns with:

Modern Slavery Act 2018 (Cth)
Fair Work Act 2009 (Cth)
Work Health and Safety Act 2012 (SA) and Regulations 2012 (SA)
Labour Hire Licensing Act 2017 (SA) and related state frameworks
Environment Protection Act 1993 (SA)
ISO 9001:2015, ISO 14001:2015, ISO 45001:2018, ISO 41001:2018
Cm3 Contractor Safety Management Framework

Supporting Documents:

Code of Conduct (CD-100)
Corporate Social Responsibility Policy (CD-101)
Ethical Sourcing Policy
Whistleblower Policy
Supplier Evaluation Procedure
Opportunity for Improvement Form

Review & Continuous Improvement

This policy will be reviewed annually or upon significant regulatory or operational change.
Review findings, supplier audits, and Cm3 data will guide corrective actions and improvement measures.

360 Facilities remains committed to transparency, ethical operations, and continuous improvement in eradicating modern slavery and ensuring full compliance with labour and safety standards.

Indigenous Employment Policy

Purpose

360 Facilities Pty Ltd is committed to fostering meaningful engagement, employment, and professional development opportunities for Aboriginal and Torres Strait Islander peoples. This policy aims to build a culturally inclusive workplace, strengthen community partnerships, and provide long-term, sustainable employment pathways that create lasting social and economic benefits.

Scope

This policy applies to all 360 Facilities employees, contractors, subcontractors, and business partners. It forms part of the company’s broader commitment to diversity, inclusion, and reconciliation, and aligns with our Reconciliation Action Plan (RAP).

Policy Statement

360 Facilities recognises the cultural, social, and economic importance of Aboriginal and Torres Strait Islander communities. We are dedicated to creating opportunities that empower First Nations people through education, employment, leadership, and community collaboration.
Our approach is guided by respect, equality, and partnership — ensuring that Aboriginal and Torres Strait Islander peoples are valued participants in our business and industry.

Objectives & Principles

Our key Indigenous employment objectives are to:

Respect and support the cultural, social, and religious practices of Aboriginal and Torres Strait Islander peoples.
Enable participation in cultural and ceremonial activities.
Encourage the direct involvement of First Nations workers in setting personal and professional career goals.
Maximise employee development and transfer of job skills to promote independence, self-sufficiency, and job security.
Integrate Indigenous employment initiatives and training programs across all operations.
Strengthen relationships between Indigenous and non-Indigenous Australians through education, cultural awareness, and collaboration.

Reconciliation Action Plan (RAP)

360 Facilities’ Reconciliation Action Plan provides a structured framework to:

Recognise and celebrate Aboriginal and Torres Strait Islander cultures and histories.
Build meaningful and respectful relationships between Indigenous and non-Indigenous employees.
Create inclusive employment pathways and supplier engagement opportunities.
Actively participate in National Reconciliation Week and other key cultural initiatives.

Employment & Career Development

360 Facilities is dedicated to closing the employment gap by providing clear and supported career pathways for Aboriginal and Torres Strait Islander peoples through:

Targeted traineeships and apprenticeships.
Accredited training programs in cleaning management, workplace safety, project management, and auditing.
Mentorship and leadership programs to support professional progression.
Collaboration with Indigenous employment partners and community organisations.

2028 Roadmap – Changing 14 Lives

By 2028, 360 Facilities will support 14 individuals from disadvantaged or Indigenous backgrounds to complete structured traineeships in the following roles, achieving nationally recognised qualifications and meaningful careers:

Role	Key Qualifications & Certifications
Client Services Manager	Cert IV Cleaning Management • Cert IV Work Health & Safety • Cert IV Training & Assessment • Cert IV Project Management • Lead Auditor (Management Systems)
Business / Administration Manager	Cert IV Business Administration • Cert IV Project Management • Microsoft Certified Administrator • Adobe Illustrator Essentials
SHEQ & Work Health Safety Officer	Diploma of WHS • Cert IV Cleaning Management • Lead Auditor (Management Systems)
Specialised Services Technician	Cert IV Cleaning (Specialty Cleaning & Restoration) • Cert IV WHS • Cert IV Project Management • Amdecon CTS Decon Specialist Certification

This program supports 360 Facilities’ mission: “Impact a Life, Transform a Community.”

Fostering Sustainable Careers

360 Facilities’ commitment extends beyond job creation. We aim to nurture sustainable careers through:

Tailored recruitment strategies that remove barriers to employment.
Support structures for individuals facing social or economic disadvantage.
Ongoing training and career planning that empower individuals to achieve long-term success.
Partnerships that promote cultural awareness and reconciliation across all business operations.

Responsibilities

Management

Provide leadership and resources to support Indigenous employment programs and RAP objectives.
Foster relationships with Indigenous organisations and community networks.
Ensure culturally appropriate recruitment and engagement processes.

Employees & Contractors

Demonstrate respect for Aboriginal and Torres Strait Islander cultures and traditions.
Participate in cultural awareness programs and reconciliation initiatives.
Support inclusivity in daily operations and interactions.

Compliance & Related Legislation

This policy aligns with:

Fair Work Act 2009 (Cth)
Work Health and Safety Act 2012 (SA)
Equal Opportunity Act 1984 (SA)
Aboriginal and Torres Strait Islander Heritage Protection Act 1984 (Cth)
Closing the Gap Framework
360 Facilities Reconciliation Action Plan (RAP)
Cleaning Services Award 2020 (MA000022)

Review & Continuous Improvement

This policy will be reviewed annually or as required to ensure it remains aligned with community needs, legislative changes, and 360 Facilities’ reconciliation goals.
360 Facilities remains committed to building a workforce that reflects Australia’s diversity — empowering Indigenous people to build meaningful careers, transform communities, and create a shared future.

Freedom Of Association Policy

Purpose

It is the obligation of 360 Facilities Pty Ltd to enable fairness and representation at work and to prevent discrimination by recognising the right to freedom of association and representation. This policy protects individuals from unfair treatment and ensures that all employees are free to choose whether or not to associate with industrial or employee organisations.

Scope

This policy applies to all 360 Facilities employees, contractors, and subcontractors engaged in facility-management and cleaning operations across Australia.

Policy Statement

360 Facilities supports every worker’s right to freedom of association under the Fair Work Act 2009 (Cth) and relevant State and Territory legislation. This includes the right to:

Become, or not become, a member of an association;
Be represented, or not represented, by an association;
Participate, or not participate, in lawful industrial activities; and
Be free from discrimination, coercion, or disadvantage due to these choices.

360 Facilities will also ensure that personal information relating to workplace associations is managed in accordance with the Privacy Act 1988 (Cth).

Responsibilities

Managers and Supervisors

Must ensure that all workers are treated equitably and not exposed to a breach of freedom of association.
Must model appropriate behaviour, treat all complaints seriously, and ensure that employees or contractors raising concerns are not victimised.
Must maintain confidentiality in all investigations.

Employees and Workers

Must comply with this policy and act respectfully toward others regardless of their industrial association.
Must report any potential breach of this policy to their immediate manager or supervisor.
Must cooperate with investigations and maintain confidentiality during and after the process.

Compliance & Related Legislation

This policy is guided by:

Fair Work Act 2009 (Cth)
Work Health and Safety Act 2012 (SA)
Fair Work Regulations 2009 (Cth)
Privacy Act 1988 (Cth)
Cleaning Services Award 2020 (MA000022)

Review & Continuous Improvement

This policy will be reviewed every two years, or sooner if legislation or industrial instruments change, to ensure ongoing compliance with relevant laws and industry standards.

Industrial Relations Policy

Purpose

360 Facilities Pty Ltd is committed to maintaining a fair, cooperative, and productive workplace that supports open communication, mutual respect, and industrial harmony. Effective management of industrial relations ensures that all work is conducted in accordance with applicable legislation, awards, and agreements, while maintaining strong relationships with employees, unions, subcontractors, and clients.

Scope

This policy applies to all 360 Facilities employees, contractors, and subcontractors. It governs all workplace relations activities, including those involving enterprise agreements, employment conditions, and dispute resolution processes.

Policy Statement

It is the policy of 360 Facilities to operate its business in a manner that promotes a harmonious and respectful workplace. Management at all levels is responsible for ensuring that work is carried out efficiently, safely, and in compliance with relevant industrial instruments and legislation.

360 Facilities aims to ensure that all workplace matters are addressed with integrity, fairness, and in the best interests of both our employees and clients.

Aims and Objectives

To achieve and maintain sound industrial relations practices, 360 Facilities will:

Provide a safe and harmonious working environment that promotes cooperation, fairness, and productivity.
Comply with all applicable industrial relations laws, regulations, statutory obligations, awards, agreements, and codes of practice.
Monitor the industrial performance and activities of subcontractors and suppliers while maintaining open communication and respecting their right to independent arrangements.
Develop and enhance worker skills to promote engagement, efficiency, and professional growth in a changing work environment.
Recognise that client requirements may influence certain industrial arrangements and ensure alignment with client expectations while maintaining compliance.

Responsibilities

Management

Provide fair, reasonable, and transparent management of industrial issues.
Maintain open and cooperative relationships with employees, representatives, and unions.
Ensure that all company policies and procedures are applied equitably and without bias.
Promote communication and early resolution of workplace disputes to prevent escalation.
Foster an environment of mutual trust, respect, and accountability.

Employees and Subcontractors

Follow lawful and reasonable directions from management.
Communicate openly and respectfully when raising industrial concerns.
Participate in resolving disputes promptly and constructively.
Cooperate with industrial relations processes and abide by applicable workplace agreements and legislation.

Compliance & Related Legislation

This policy aligns with:

Fair Work Act 2009 (Cth)
Fair Work Regulations 2009 (Cth)
Work Health and Safety Act 2012 (SA)
Labour Hire Licensing Act 2017 (SA)
Cleaning Services Award 2020 (MA000022)
360 Facilities Integrated Management System (IMS)

Review & Continuous Improvement

This policy will be reviewed biennially or sooner if legislative or operational changes occur. Continuous improvement in industrial relations performance is a key focus of 360 Facilities’ management approach, ensuring fairness, compliance, and collaboration across all levels of the organisation.

Whistle Blower Policy

Purpose

360 Facilities Pty Ltd is committed to detecting and preventing illegal, unethical, or other undesirable conduct. We provide a safe mechanism for workers and other eligible persons to report concerns confidentially and without fear of reprisal so matters can be addressed promptly and fairly.

Scope

This policy applies to:

Current and former employees (permanent, casual, part-time).
Contractors, subcontractors, consultants, labour-hire workers, and suppliers providing goods/services to 360 Facilities (or who have previously done so).
Relatives, dependants, or spouses of any of the above.

Policy Statement

360 Facilities encourages anyone with reasonable grounds to suspect Potential Misconduct to Speak Up. We:

Prohibit victimisation, retaliation, or any detriment against a person for Speaking Up.
Protect confidentiality and, where lawful, anonymity.
Investigate disclosures appropriately and in a timely manner.
Take corrective and disciplinary action where misconduct is substantiated.

Disciplinary action (up to termination of employment/engagement) may be taken against anyone who causes detriment to a whistleblower or breaches confidentiality.

What You Can Report (Potential Misconduct)

Potential Misconduct includes (not limited to):

Breaches of law or regulation; criminal conduct; bribery/corruption.
Serious breaches of the 360 Facilities Code of Conduct or policies.
Conduct endangering health, safety, or the environment.
Fraud, false accounting, misleading or deceptive conduct.
Conflicts of interest or improper payments/donations.
Privacy breaches or unauthorised use of confidential information.
Modern slavery indicators in operations or supply chains.
Victimisation of a person who has, or is believed to have, Spoken Up.
Matters posing a danger to the public or the financial system.
Any deliberate concealment of the above.

You should provide as much detail as possible (people involved, dates, locations, evidence). You’re expected to have reasonable grounds; if a report is made in good faith but turns out incorrect, protections still apply. Deliberately false or malicious reports are misconduct and not protected.

Personal Work-Related Grievances

Personal employment grievances only about you (e.g., interpersonal conflicts, decisions about promotion, transfer, or performance management) are generally not covered.
However, a grievance may qualify if it includes Potential Misconduct (e.g., a legal breach punishable by ≥12 months’ imprisonment, danger to the public, or you suffer/threatened with detriment for Speaking Up).

How to Speak Up (Reporting Channels)

Primary contact – Whistleblower Protection Officer (WPO):

Role: protect whistleblowers, oversee intake, coordinate fair handling and confidentiality.
Contact: Whistleblower Protection Officer, 360 Facilities
- Email: hr@justfocus.com.au (confidential inbox)
- Title: HSEQ Manager (or delegate approved by the Managing Director)

Other options:

External legal practitioner (to obtain legal advice about whistleblower protections).
Regulators (e.g., ASIC, APRA, ATO) where legally permitted.

Anonymity & Confidentiality

You may report:

Confidentially (your identity known to WPO, protected from wider disclosure).
Partially anonymous (identity known only to the WPO; pseudonym used).
Anonymously (least preferred—may limit the investigation and support we can provide).

360 Facilities will protect your identity and only disclose it with your consent or where required/permitted by law. Investigation materials are stored securely with limited access.

Protections for Whistleblowers

Protection from detriment: No dismissal, demotion, discrimination, harassment, injury in employment, reputational or financial harm because you Spoke Up.
Confidentiality: Your identity and information likely to identify you will be protected.
Liability protection: You may be protected from civil, criminal, or administrative liability for making a protected disclosure (note: no immunity for any personal misconduct revealed).
Remedies: If you suffer detriment due to a failure to protect you, you may be entitled to compensation or other remedies. Seek independent legal advice if needed.

Reasonable management action (e.g., adjusting duties to reduce risk to you) is not detriment.

Investigation Process

Assessment – The WPO assesses whether the disclosure is within scope and how it should be addressed (informal resolution or formal investigation).
Investigation – Conducted promptly, fairly, and objectively. External specialists may be engaged where appropriate.
Confidentiality – Information is disclosed only as necessary and with safeguards to reduce the risk of re-identification.
Updates – If your identity is known and it’s appropriate, you’ll be informed when: the investigation commences, is in progress, and is finalised. (Investigation reports are not routinely shared.)
Outcomes & Actions – Findings are considered by senior management; corrective, disciplinary, contractual, or system controls are implemented as required.

If you believe confidentiality has been breached or you have suffered detriment, notify the WPO immediately; you can also contact a regulator or seek independent legal advice.

Responsibilities

WPO Whistleblower Protection Officer

Maintain secure reporting channels, protect identity/confidentiality, coordinate assessment/investigation, and monitor protection measures.

Leaders & Managers

Foster a Speak Up culture; act on concerns promptly; prevent and address any detriment.

All Workers & Suppliers

Comply with this policy; refrain from any retaliatory conduct; cooperate with investigations.

Compliance & Related Legislation

Corporations Act 2001 (Cth) – Whistleblower protections (Part 9.4AAA)
Taxation Administration Act 1953 (Cth) – Tax whistleblower provisions (where relevant)
Fair Work Act 2009 (Cth)
Privacy Act 1988 (Cth) and Australian Privacy Principles (APPs)
Work Health and Safety Act 2012 (SA)
360 Facilities Code of Conduct (CD-100), Privacy Policy (CD-107), Modern Slavery & Compliance (CD-106)

Review & Continuous Improvement

This policy will be reviewed biennially or earlier following legislative changes, regulator guidance, or lessons from investigations. Training, awareness, and process controls will be updated for continual improvement.

Management Of Contractors Policy

Purpose

The purpose of this policy is to ensure that all products, services, and external providers engaged by 360 Facilities Pty Ltd conform to our Health, Safety, Environment, and Quality (HSEQ) Management System requirements.
This policy ensures that all risks associated with contractor activities are identified, assessed, and controlled to protect the health and safety of workers, the environment, and other interested parties.

Key objectives include:

Ensuring procurement processes meet legal, regulatory, and HSEQ compliance obligations.
Managing hazards and risks arising from external provider activities.
Ensuring outsourcing arrangements support the intended outcomes of the HSEQ Management System and align with ISO 9001, ISO 14001, ISO 45001, and ISO 41001 standards.
Leveraging Cm3, Australia’s leading WHS prequalification platform, to assess and verify contractor compliance prior to engagement.

Scope

This policy applies to all procurement activities, suppliers, subcontractors, and external providers engaged by 360 Facilities.
It governs the evaluation, selection, engagement, and ongoing monitoring of all parties providing goods or services to the organisation or its clients.

Policy Statement

360 Facilities is committed to ensuring that all contractors and external providers operate safely, ethically, and in accordance with legislative and contractual requirements.
All suppliers and subcontractors must demonstrate their ability to deliver products and services that meet specified requirements and uphold our company’s HSEQ and corporate responsibility standards.

360 Facilities has the same duty of care to external providers as to its own workers, and conversely expects those providers to:

Act responsibly and comply with all relevant legal, regulatory, and HSEQ obligations.
Maintain valid Cm3 prequalification where required to verify capability and compliance prior to engagement.
Ensure their workers are competent, licensed, insured, and fit for duty.

Responsibilities

Management

Approve, monitor, and review all suppliers and contractors through documented evaluation processes, including Cm3 prequalification where applicable.
Ensure external providers meet competency, licensing, and insurance requirements.
Maintain records of evaluations, audits, and Cm3 verifications.
Conduct regular performance reviews and address non-conformances promptly.

Contractors and External Providers

Must maintain active Cm3 certification (or equivalent) demonstrating compliance with WHS and HSEQ standards prior to commencing work.
Must operate safely, meet client-specific requirements, and maintain current insurances.
Are responsible for providing their own PPE, safety, and environmental control equipment.
Must report all injuries, near misses, environmental incidents, or quality issues immediately.

Procurement & Evaluation Process

Before engagement, a Supplier Evaluation Form must be completed and approved.
The following requirements are communicated to all external providers:

Scope of products, services, and processes to be provided.
Approval requirements for products, methods, and equipment.
Required qualifications and competencies.
Performance monitoring and verification expectations.
Environmental requirements including waste minimisation and pollution prevention.

Evaluation Criteria:

Demonstrated capability and capacity to provide the required services.
Active Cm3 prequalification or equivalent WHS verification.
Safety history (LTIFR ≤ 5, no fatalities, no externally reportable incidents).
Environmental history (no external breaches).
Valid insurances – Workers Compensation, Public Liability, Professional Indemnity.
Current HSEQ documentation, Safe Work Method Statements (SWMS), and certifications.

Ongoing Monitoring and Performance

External providers are monitored regularly based on the risk level and scope of work.
Monitoring methods include:

Review of Cm3 status, documentation, and audit results.
Site inspections, performance reports, and client feedback.
Annual re-evaluation and recertification through Cm3 or internal review.

External provider approvals are valid for 12 months and must be renewed annually.

Non-Conformances

If an external provider fails to comply with HSEQ or Cm3 requirements, an Opportunity for Improvement Form will be issued.
Providers must respond with corrective actions and verification evidence within the required timeframe.
Failure to comply may result in:

Suspension or removal from approved supplier/Cm3 register.
Termination of contract.
Re-training, re-induction, or additional audits.

Common non-conformance sources include:

Unsafe work or breaches of safety procedures.
Environmental or quality incidents.
Inadequate documentation or expired Cm3 credentials.

Compliance & Related Legislation

This policy aligns with:

Work Health and Safety Act 2012 (SA)
Work Health and Safety Regulations 2012 (SA)
Fair Work Act 2009 (Cth)
Environment Protection Act 1993 (SA)
Labour Hire Licensing Act 2017 (SA)
ISO 9001:2015, ISO 14001:2015, ISO 45001:2018, ISO 41001:2018
Cm3 Contractor Safety Management Framework

Supporting Documents:

Supplier Evaluation Form
External Provider Approval Checklist
External Provider Induction Form
External Provider HSEQ Checklist
Opportunity for Improvement Form

Review & Continuous Improvement

This policy will be reviewed biennially or when legislative, operational, or Cm3 compliance requirements change.

Audit outcomes, Cm3 data, and management review findings will guide continuous improvement of contractor management, procurement, and supplier performance systems.

Drug & Alcohol Policy

Purpose

360 Facilities Pty Ltd is committed to providing a safe, healthy, and productive workplace for all employees, contractors, and visitors. The purpose of this policy is to ensure that no person’s work performance or safety is impaired by the influence of alcohol or drugs, including prescription medication that may affect alertness or coordination.

Scope

This policy applies to all 360 Facilities workers, including subcontractors, across all company worksites, offices, and client premises. It covers the use, possession, distribution, or influence of alcohol, illegal drugs, and the misuse of prescription or over-the-counter medications during working hours or while representing the company.

Policy Statement

360 Facilities recognises that the misuse of alcohol and other drugs can adversely affect a person’s health, safety, and work performance. Such impairment poses an unacceptable risk to the safety of individuals, co-workers, clients, and the public.

Accordingly:

Workers must present fit for duty at all times and free from the influence of alcohol or drugs.
Workers must not consume, possess, distribute, or sell alcohol or non-prescribed drugs in the workplace.
Prescription or over-the-counter medication that may cause drowsiness or impairment must be disclosed to a supervisor before work commences.
A supervisor who reasonably suspects a worker is unfit for duty due to impairment must not permit that worker to perform work until their fitness for duty is confirmed.
Any worker found to be in breach of this policy will be subject to disciplinary action, which may include counselling, suspension, or termination of employment for serious misconduct.

360 Facilities treats the misuse of drugs and alcohol as a serious breach of company and safety policy.

Responsibilities

Managers and Supervisors

Must enforce this policy and ensure that no impaired person undertakes work duties.
Must take prompt action when impairment is suspected, including removing the affected worker from the workplace and arranging appropriate assessment.
Must support workers seeking rehabilitation assistance through referrals to counselling or medical support services.

Employees and Contractors

Must take personal responsibility to ensure they are fit for duty and free from impairment.
Must comply with this policy and report any unsafe behaviour or suspected impairment immediately to a supervisor.
Must cooperate fully with any reasonable requests for testing, investigation, or counselling related to fitness for work.

Compliance & Related Legislation

This policy complies with:

Work Health and Safety Act 2012 (SA)
Work Health and Safety Regulations 2012 (SA)
Fair Work Act 2009 (Cth)
Road Traffic Act 1961 (SA) (where applicable to company vehicles)
Cleaning Services Award 2020 (MA000022)
ISO 45001:2018 – Occupational Health and Safety Management Systems

Review & Continuous Improvement

This policy will be reviewed biennially or earlier if required by legislative or operational changes. 360 Facilities is committed to continual improvement of workplace health, safety, and wellbeing practices and will provide ongoing education and assistance to workers regarding substance misuse and rehabilitation support.

Purpose

Scope

This policy applies to all 360 Facilities operations, employees, contractors, and subcontractors across Australia engaged in the delivery of cleaning, waste, and facility-management services.

Policy Statement

360 Facilities strives to operate in an environmentally responsible manner by:

Reducing pollution, waste, and emissions across all business operations.
Promoting the efficient use of energy, water, and cleaning resources.
Implementing processes that comply with or exceed relevant environmental legislation and standards.
Continuously improving environmental performance through innovation, training, and collaboration with sustainable partners.

Responsibilities

Management and Supervisors

Integrate sustainable practices into daily operations.
Ensure compliance with environmental laws, regulations, and contractual obligations.
Provide adequate training, supervision, and resources to meet environmental objectives.
Monitor and report on environmental performance through internal audits and reviews.

Employees and Contractors

Follow environmental procedures and actively support sustainability initiatives.
Use cleaning products, equipment, and materials responsibly to reduce waste.
Report spills, leaks, or incidents that may pose environmental risks.
Participate in training and improvement programs.

Compliance & Related Legislation

This policy is informed by and complies with:

Environment Protection Act 1993 (SA)
Environment Protection (Air Quality) Policy 2016 (SA)
Environment Protection (Waste to Resources) Policy 2010 (SA)
Work Health and Safety Act 2012 (SA)
ISO 14001:2015 – Environmental Management Systems
Fair Work Act 2009 (Cth) (in relation to environmental responsibilities at work)

Review & Continuous Improvement

Risk Management Policy

Purpose

360 Facilities Pty Ltd is committed to achieving the highest standards of health, safety, and operational excellence by ensuring that effective risk management is embedded in all activities and decision-making processes.

We recognise our moral and legal responsibility to provide a safe and healthy environment for workers, contractors, customers, and visitors while maintaining a proactive approach to identifying, assessing, and controlling risks across our operations.

Scope

This policy applies to all employees, contractors, visitors, and stakeholders engaged in 360 Facilities’ operations and activities. It encompasses all areas where work-related health, safety, environmental, financial, and reputational risks may arise.

Policy Statement

360 Facilities acknowledges that risk is inherent in all business functions and must be managed to:

Maximise opportunities, and
Minimise adverse impacts on people, the environment, assets, and reputation.

We are committed to ensuring that workplace hazards are identified, risks are assessed, and appropriate control measures are implemented to eliminate or minimise risks as far as is reasonably practicable.

Risk management is integrated into all organisational processes, forming part of our strategic planning, operational delivery, and continuous improvement framework.

Aims and Objectives

Our objectives are to:

Identify and assess potential hazards and risks in all work areas.
Eliminate risks to health and safety where reasonably practicable.
Where elimination is not practicable, implement controls to minimise risks.
Establish a consistent framework for assessing and prioritising risks in line with ISO 31000:2018.
Monitor, review, and continually improve our risk control measures.
Foster a culture of accountability, consultation, and continuous improvement.

Responsibilities

Management

Implement and maintain a risk management system consistent with legal and ISO requirements.
Ensure all work areas have current risk assessments and control measures in place.
Provide adequate resources, supervision, and training to enable safe work practices.
Review and update risk controls through audits, inspections, and consultation.

Workers and Contractors

Follow all safety procedures and risk control measures.
Report hazards, near misses, and incidents promptly.
Participate in risk assessments, consultation, and training.
Take reasonable care for their own health and safety and that of others.

Risk Management Process

To properly manage exposure to risks, 360 Facilities will:

Identify hazards that may give rise to risks.
Assess risks to determine potential consequences and likelihood.
Decide on appropriate controls to prevent or minimise harm.
Implement risk control measures using the hierarchy of control.
Monitor and review controls to ensure effectiveness and continual improvement.

Where elimination of a risk is not reasonably practicable, the Hierarchy of Controls will be applied in the following order of priority:

Elimination
Substitution
Engineering Controls
Administrative Controls
Personal Protective Equipment (PPE)

All decisions relating to risk control will be documented to support future reviews, compliance verification, and regulatory inspections.

Consultation and Training

Risk assessments and safe work procedures will be developed in consultation with workers who perform the tasks.

All workers will receive instruction and training in safe work practices and must adhere to these procedures at all times.

Compliance & Related Legislation

This policy aligns with:

Work Health and Safety Act 2012 (SA)
Work Health and Safety Regulations 2012 (SA)
ISO 45001:2018 – Occupational Health and Safety Management Systems
ISO 31000:2018 – Risk Management – Guidelines
360 Facilities Work Health & Safety Policy (CD-01)

Supporting Documents:

Risk Assessment Procedure
Safe Work Method Statements (SWMS)
Incident & Hazard Reporting Procedure
Consultation & Communication Procedure

Review & Continuous Improvement

This policy will be reviewed every two years or earlier if there are significant operational or legislative changes.

360 Facilities will continuously monitor and evaluate the effectiveness of its risk management framework to ensure continual improvement and alignment with best practice standards.

Secure Local Jobs Policy

Purpose

360 Facilities Pty Ltd is committed to maximising opportunities for local suppliers, workers, and service providers while fostering inclusive, socially responsible employment practices.

This policy ensures that our procurement, mobilisation, and workforce planning processes deliver tangible community and economic benefits in the regions where we operate.

Scope

This policy applies to all contracts, procurement activities, and workforce engagements undertaken by 360 Facilities across Australia.

It covers supplier engagement, subcontractor selection, and employment practices, with a specific focus on promoting local and inclusive participation in regional and municipal contracts.

Definition of a Local Supplier

A local supplier is defined as:

“A supplier of goods or services that maintains a workforce whose usual place of residency (i.e., where they normally live, sleep, and eat) is located within a 125 kilometre radius of where the goods or services are to be supplied.

If a capable local supplier does not exist within the 125 kilometre radius, the radius should be extended progressively to the local region until a suitable supplier is identified.”

Policy Statement

360 Facilities integrates social procurement and local participation principles into every stage of contract delivery. Our approach is built on three pillars:

Supporting Local Suppliers and Businesses
Creating Inclusive Employment Pathways
Delivering Sustainable Community Benefits

We believe that investing in local suppliers and disadvantaged job seekers not only strengthens local economies but also delivers long-term social value.

Optimising Opportunities for Local Suppliers

360 Facilities ensures that procurement activities:

Give preference to capable local suppliers whenever feasible.
Include early industry engagement to encourage participation and innovation.
Evaluate tenders based on social and economic benefit to the region, not price alone.
Assess local supplier performance using criteria such as reliability, safety, quality, and community impact.

Where local supply markets are underdeveloped, 360 Facilities works collaboratively with local business chambers, councils, and regional development authorities to build capacity.

Procurement Approach Based on Value and Risk

Procurement strategies are scaled according to value and business risk:

Low-Value / Low-Risk Purchases:
Preference is given to local suppliers where capability exists.
Simplified purchasing procedures are applied to promote regional participation.
High-Value / High-Risk Procurements:
Formal market engagement is conducted, ensuring that local suppliers are included in tender notifications and industry briefings.
Social and local benefit weightings are incorporated into evaluation criteria.

Engaging with Local Industry

Early engagement with local industry enables innovation, partnership, and improved service outcomes.

360 Facilities actively consults with local suppliers before procurement activities to:

Discuss objectives, constraints, and performance standards.
Identify available capacity and upcoming contract opportunities.
Support supplier development through information sessions and networking events.

This approach ensures capable local providers are available and prevents supply chain bottlenecks caused by overcommitment or limited local capacity.

Considering Local Benefits

When assessing suppliers, 360 Facilities considers the broader benefits they deliver to the local community, including:

Local job creation and apprenticeships.
Training and skill development initiatives.
Indigenous business engagement.
Procurement of local goods and services.
Community sponsorships or volunteer activities.

Inclusive Employment Strategy

360 Facilities is committed to providing employment pathways for individuals from diverse, disadvantaged, and underrepresented backgrounds, including:

Aboriginal and Torres Strait Islander peoples.
People with disabilities and NDIS participants.
Culturally and linguistically diverse groups.
Long-term unemployed individuals and youth.
Mature-aged workers and school leavers with disabilities.

Immediate Strategy for New Contracts

360 Facilities integrates inclusive employment into every new contract mobilisation through:

Partnering with Local Employment Resources

Collaborate with job service agencies such as APM, Q.I.T.E., and Indigenous employment networks.
Engage with disability support and social enterprise organisations.
Work with local Indigenous employment agencies to prioritise First Nations Australians.

Hosting Information Sessions

Organise 20–30 person engagement sessions for local agencies and jobseekers.
Deliver interactive workshops to connect participants with career opportunities.
Identify “diamonds in the rough” — individuals with untapped potential who thrive when provided with support and training.

Inclusive Recruitment Practices

Recognise that the cleaning and facility management sector provides strong entry-level career pathways.
Focus on loyalty, reliability, and personal growth rather than prior experience.

Supported Workers Program
360 Facilities integrates supported workers into suitable, low-risk cleaning and maintenance tasks that align with their abilities, including:

Monthly dusting of blinds and cobweb removal.
Fridge deep cleans and detailed hygiene work.
Outdoor litter collection and light grounds maintenance.

Work is typically structured into 4-hour shifts, which promote consistency, safety, and productivity while accommodating individual needs.

Demonstrated and Proven Employment Partnerships

360 Facilities has successfully mobilised regional council contracts across multiple states with employment support from APM, Q.I.T.E., and local Indigenous networks.
These partnerships have consistently delivered:

Full staffing on mobilisation.
Minimal turnover due to targeted local hiring.
Positive social and community outcomes recognised by clients.

Role of the Employment Engagement Specialist

Cassy House, Employment Engagement Specialist leads the coordination of inclusive employment initiatives for operations.Cassy works directly with job service providers to identify suitable candidates across key diversity groups, ensuring alignment with roster requirements and service standards.

Focus areas include:

Mature-aged workers.
First Nations people.
Culturally and linguistically diverse groups.
NDIS participants.
School leavers with disabilities.

Government Initiatives and Funding

360 Facilities leverages government-supported initiatives to reduce onboarding costs and improve employment sustainability, including:

Paid work trials and pre-employment placements.
Uniform and PPE rebates for new employees.
Wage subsidies and onboarding support agreements through approved agencies.
These programs help maintain a trained backup workforce familiar with site-specific requirements, ensuring consistency and continuity of service for clients.

Compliance & Related Legislation

This policy aligns with:

Fair Work Act 2009 (Cth)
Disability Discrimination Act 1992 (Cth)
Equal Opportunity Act 1984 (SA)
Aboriginal and Torres Strait Islander Employment Strategy (Commonwealth)
State Procurement and Local Industry Participation Frameworks
ISO 41001:2018 – Facilities Management Systems
ISO 9001:2015 – Quality Management Systems

Supporting Policies:

Corporate Social Responsibility (CSR) Policy (CD-101)
Equal Employment Opportunity (EEO) Policy (CD-06)
Indigenous Employment & Reconciliation Policy (CD-103)
Health and Wellbeing Policy (CD-39)

Review & Continuous Improvement

This policy will be reviewed biennially or upon any significant change in legislation, local procurement frameworks, or company operations.

Feedback from councils, suppliers, and employment partners will inform continuous improvement to ensure local engagement and inclusion remain at the forefront of 360 Facilities’ operations.

Health & Wellbeing Policy

Purpose

360 Facilities Pty Ltd is committed to fostering a safe, supportive, and healthy work environment that promotes the physical, psychological, and social wellbeing of all workers. Our goal is to integrate wellbeing principles into all work systems, practices, and culture, ensuring that every team member can thrive both personally and professionally.

Scope

This policy applies to all 360 Facilities employees, contractors, and subcontractors across all work locations. It aligns with our Work Health and Safety policies and forms part of our Integrated Management System, ensuring consistent application across all operations and worksites.

Policy Statement

360 Facilities will ensure that all work organisation, practices, and workplace culture value, enhance, and protect the health and wellbeing of all workers. We recognise that a healthy workforce contributes to higher productivity, reduced risk, and improved morale.

Responsibilities

Senior Management

Lead by example and promote health and wellbeing across all levels of the organisation.
Ensure the health of workers is valued and integrated into business decision-making.
Provide safe work environments and systems that minimise health risks and promote wellbeing.
Allocate resources and support for wellbeing initiatives.
Participate in and support the Health and Wellbeing Committee.

Human Resources Department

Develop and maintain human resources policies that promote workplace health and wellbeing.
Ensure work design and organisational systems prevent or minimise risks to worker health.
Facilitate access to wellbeing programs and support services.
Consult with the Health and Wellbeing Committee to ensure alignment with workplace needs.

Health and Wellbeing Committee or Representatives

Encourage long-term commitment to wellbeing across the business.
Assess workplace needs, implement programs, and evaluate outcomes.
Develop and review the Health and Wellbeing Action Plan annually.
Promote worker participation and maintain consultation with management.

Workers

Follow all procedures and policies implemented to support workplace health and wellbeing.
Participate actively in wellbeing programs and provide constructive feedback.
Contribute ideas and engage in initiatives that promote a healthy workplace.

Compliance & Related Legislation

This policy is informed by:

Work Health and Safety Act 2012 (SA)
Work Health and Safety Regulations 2012 (SA)
Fair Work Act 2009 (Cth)
ISO 45001:2018 – Occupational Health and Safety Management Systems
National Preventative Health Strategy 2021–2030

Review & Continuous Improvement

360 Facilities will maintain a Work Health and Wellbeing Action Plan that identifies goals, objectives, and initiatives. The plan will be reviewed annually by the Health and Wellbeing Committee to ensure it remains relevant and effective.

This policy will be reviewed every two years, or earlier if required by operational or legislative change. Through leadership, collaboration, and continuous improvement, 360 Facilities will build and sustain a workplace culture that promotes holistic wellbeing.

Corporate Social Responsibility Statement

Purpose

360 Facilities Pty Ltd operates under the principle of sustainability meeting the needs of the present without compromising the ability of future generations to meet their own. Our Corporate Social Responsibility (CSR) Policy reflects our commitment to ethical conduct, environmental protection, community development, and sustainable employment. It is built upon three pillars of sustainability: Social, Environmental, and Economic often referred to as People, Planet, and Prosperity.

Scope

This policy applies to all 360 Facilities employees, contractors, and business partners, and is intended to guide decision-making and actions across all levels of the organisation. CSR principles are embedded within every project, contract mobilisation, and operational process undertaken by 360 Facilities.

Policy Statement

At 360 Facilities, our CSR strategy is not about meeting arbitrary targets. Instead, it is about meaningful engagement with the communities we serve, identifying opportunities within each contract to deliver lasting social and economic value.
Our focus is on creating employment pathways, reducing environmental impact, and promoting ethical and sustainable practices that improve the lives of our employees, clients, and communities.

CSR Pillars

Career – Creating Employment Pathways

360 Facilities is dedicated to generating employment opportunities that foster long-term career growth, capability development, and local workforce participation. We commit to:

Offering structured career development, traineeships, and apprenticeships.
Ensuring fair and equitable pay in accordance with the Cleaning Services Award 2020 (MA000022) and National Employment Standards (NES).
Providing ongoing training, mentoring, and professional development.
Promoting Equal Employment Opportunity (EEO) and diversity within the workforce.

Community – Supporting Social and Economic Inclusion

360 Facilities actively collaborates with local organisations to increase community participation and economic inclusion. We commit to:

Partnering with Indigenous employment agencies, disability support programs, and youth job networks.
Prioritising recruitment from underrepresented and disadvantaged groups.
Supporting community-based initiatives such as mentoring, information sessions, and skill-building programs.
Partnering with organisations including:
- Deadly Services Mentorship Joint Venture – Indigenous career pathways.
- Minda SA and SDA Queensland – employment for individuals with disabilities.
- Indigenous Preferred Suppliers Circular Economy – promoting Indigenous-owned business participation.

Cause – Ethical Business and Sustainable Practices

360 Facilities is committed to conducting business ethically and responsibly. This includes:

Maintaining transparency and ethical sourcing across our supply chain.
Preventing modern slavery through supplier due diligence and monitoring.
Complying with all labour and safety laws, including Labour Hire Licensing where applicable.
Implementing safe work systems in line with ISO 45001:2018 and our WHS Management System.
Supporting charitable and community initiatives such as:
- Foodbank School Breakfast Program – addressing food insecurity.
- Ronald McDonald House Charities – assisting families facing serious illness.
- Employee Health and Wellbeing programs in collaboration with local fitness partners.

Responsibilities

Management

Integrate CSR principles into strategic and operational decision-making.
Provide leadership, resources, and accountability to ensure compliance with this policy.

Employees

Uphold CSR values through ethical behaviour, responsible conduct, and participation in community and environmental initiatives.

Contractors & Suppliers

Must align with 360 Facilities’ CSR and ethical sourcing expectations, including modern slavery prevention measures.

Compliance & Related Legislation

This policy aligns with:

Fair Work Act 2009 (Cth)
Work Health and Safety Act 2012 (SA)
Modern Slavery Act 2018 (Cth)
Environment Protection Act 1993 (SA)
Labour Hire Licensing Act 2017 (SA)
ISO 9001:2015, ISO 14001:2015, ISO 45001:2018, and ISO 41001:2018

Supporting Policies and Frameworks:

Modern Slavery Policy
Ethical Sourcing Policy
Equal Employment Opportunity (EEO) Policy
Health and Wellbeing Policy
Indigenous Employment Policy
Industrial Relations Policy
Secure Local Jobs Policy
Reconciliation Action Plan (RAP)

Review & Continuous Improvement

This policy will be reviewed annually to ensure alignment with current legislation, community priorities, and organisational goals. Feedback from stakeholders, clients, and community partners will inform continuous improvement of CSR initiatives.

360 Facilities remains committed to ethical business operations, sustainable growth, and creating measurable social value through every contract and partnership.

Code Of Conduct

Purpose

The purpose of this Code of Conduct is to define the expected standards of behaviour for all 360 Facilities employees, contractors, and subcontractors. It provides a clear guide to ethical conduct, professionalism, and accountability, ensuring that all personnel uphold 360 Facilities’ reputation for integrity, safety, and service excellence.

Scope

This Code applies to all workers engaged by 360 Facilities Pty Ltd, whether permanent, casual, or subcontracted, across all sites and operational areas. Compliance with this Code is a condition of employment or engagement.

Policy Statement

Every worker, regardless of their role, is expected to adhere to the following principles and demonstrate commitment to 360 Facilities in return for the organisation’s commitment to their safety, wellbeing, and professional development.

Commitment

To demonstrate commitment to 360 Facilities, workers must:

Conduct themselves in a manner that upholds the reputation of 360 Facilities.
Disclose and resolve any conflicts of interest.
Refrain from conducting private business during work hours.
Maintain confidentiality and not use company or client information for personal gain.
Decline inappropriate gifts or benefits from clients or suppliers.
Authorise and approve expenditure only when permitted.
Respect company property and ensure it is used responsibly.

Respect for Others

When dealing with customers, suppliers, and colleagues, workers must:

Treat others with dignity and respect.
Refrain from using language or behaviour that offends, harasses, or discriminates.
Observe the company’s smoke-free and drug-free workplace policies.
Comply with all workplace health and safety rules and the Work Health and Safety Act 2012.
Follow all reasonable and lawful instructions related to workplace safety and conduct.

Customer Service

When representing 360 Facilities, workers must:

Be honest, courteous, and helpful at all times.
Actively consult and listen to customers to understand their needs.
Provide accurate information and fulfil commitments.
Maintain a neat and professional appearance, including the wearing of uniforms where required.
Communicate clearly, professionally, and promptly.
Honour all commitments made to clients and avoid making promises that cannot be met.

Teamwork

360 Facilities promotes a culture of cooperation and mutual respect. Workers are expected to:

Be punctual and obtain prior approval before leaving early.
Accurately report and account for any absences.
Follow lawful and reasonable instructions.
Provide and accept constructive feedback.
Share information and support colleagues to achieve team goals.
Observe safe work practices and promptly report hazards, incidents, or unsafe behaviours.
Follow emergency procedures when required.

Results and Integrity

To maintain the quality and integrity of work, all workers must:

Observe both the letter and the spirit of all applicable laws and 360 Facilities policies.
Perform duties diligently and with due care.
Use company resources, materials, and equipment responsibly and efficiently.
Report any breaches of policy, misconduct, or unethical behaviour immediately.

Misconduct

Misconduct refers to behaviour that breaches the employment contract, workplace standards, or this Code of Conduct. It may result in disciplinary action, up to and including termination of employment. Misconduct includes, but is not limited to:

Breach of safety procedures.
Theft or unauthorised removal of property.
Violence, bullying, or harassment.
Sexual harassment or discrimination.
Neglect of duty or dishonesty.
Fraud or deliberate falsification of timesheets, records, or documents.
Being under the influence of alcohol, illegal substances, or undeclared prescription medication that impairs performance.
Malicious damage to company or employee property.
Inappropriate behaviour towards clients, suppliers, or members of the public.

Workers found in breach of this Code will be managed under the company’s Breach and Disciplinary Procedure.

Responsibilities

Managers and Supervisors

Ensure workers are aware of and understand this Code of Conduct.
Lead by example and enforce compliance with workplace standards.
Act promptly and fairly when addressing any breaches of conduct.

Employees and Contractors

Understand and comply with this Code and all company policies.
Report suspected breaches or misconduct to their supervisor or HR.
Represent 360 Facilities positively at all times.

Compliance & Related Legislation

This Code aligns with:

Fair Work Act 2009 (Cth)
Work Health and Safety Act 2012 (SA)
Fair Work Regulations 2009 (Cth)
Cleaning Services Award 2020 (MA000022)
360 Facilities Integrated Management System

Review & Continuous Improvement

This Code of Conduct will be reviewed every two years, or sooner where legislation, operational needs, or company structure changes. Continuous improvement in conduct and compliance is a key principle of the 360 Facilities management approach.