OVERVIEW

1. Purpose and application

(a) This Supplier Code of Conduct (Code) sets out the minimum standards, practices and expectations that Are Media Pty Limited ACN 053 273 546 and its related bodies corporate including Are Direct Pty Ltd, Are Media Limited and Are Direct NZ Limited (Are Media) has on the individuals or entities (including consultants) that supply goods and services (including throughout their own supply chains) (Suppliers) to Are Media.

(b) Are Media is committed to doing business with responsible Suppliers who meet Are Media’s social, ethical and environmental expectations outlined in this Code.

(c) Suppliers should read, understand and ensure that their business and supply chain meet the standards outlined in this Code. Suppliers should also communicate this Code to any of their related entities, their own suppliers and subcontractors who support them in supplying to Are Media, to ensure awareness, understanding and compliance with this Code.

2. Compliance with relevant legislation

(a) In addition to any specific terms referenced within this Code, Suppliers are expected to comply with all relevant legislation and standards.

(b) Suppliers are encouraged to not only exceed minimum requirements and expectations outlined in this Code, and compliance with all applicable laws and standards, but in addition, take responsibility for continuous improvement of social, environmental and ethical standards within their business and that of their supply chain.

ENVIRONMENTAL EXPECTATIONS

3. Environmental laws, permits and reporting

(a) Are Media is committed to the continual sustainability and protection of the environment, aiming to lessen impact on the environment where possible.

(b) Are Media is certified for Chain of Custody under both the Forest Stewardship Council® (FSC) and the Program for the Endorsement of Forest Certification (PEFC) to promote environmentally, socially and economically viable forest management. Are Media is also part of the National Environmental Sustainability Agreement (NESA), a product stewardship scheme for print media approved by Australian Government.

(c) Are Media is committed to ongoing compliance with the Australian Illegal Logging Prohibition Act 2012 and Illegal Logging Prohibition Amendment Regulation 2012, and expects Suppliers’ commitment to complying with such legislation, where applicable.

(d) Suppliers are expected to comply with all applicable local and national environmental laws, standards and notices from regulators, whilst maintaining and complying with all necessary environmental permits, approvals and registrations.

4. Enhancing environmental sustainability

(a) Are Media support the re-use and recycling of products in the community, and expect Suppliers to demonstrate their commitment to protecting and enhancing environmental priorities by (but not limited to):

(i) managing environmental impacts on supply chains and operations; and

(ii) waste minimisation and recycling.

SOCIAL EXPECTATIONS

5. Workplace health and safety management

(a) Are Media is committed to ensuring health, wellbeing and safety within the workplace and continuous improvement of all safety management systems.

(b) Suppliers are to ensure they:

(i) comply with all relevant workplace health and safety laws and regulations;

(ii) are taking all reasonable steps to identify any workplace hazards and minimise risks; and

(iii) take steps to make sure their employees understand and follow health and safety policies, procedures and standards and proactively engage with relevant industry bodies and unions where applicable.

6. Fair treatment of employees

(a) Are Media aims to undertake its procurement process with integrity, honesty and accountability and wants to do business with Suppliers who also commit to the same values and support the welfare of their employees and the community more generally.

(b) Suppliers are expected to:

(i) respect the workplace rights and entitlements of every employee, including the recognition of rights of employees to be members of trade unions;

(ii) ensure compliance with all relevant workplace laws, regulations and industrial instruments;

(iii) ensure the fair pay of all employees, complying with and meeting minimum wage requirements and conditions;

(iv) ensure there is no unlawful discrimination; and

(v) commit to a workplace free of bullying, victimisation and harassment.

(c) Suppliers must not require their employees to work hours exceeding their prevailing work hours set by local law, whilst also ensuring, in accordance with the International Labour Organisation standards, employees are not required to work more than 60 hours per week including overtime (except where extraordinary business circumstances exist and the employee has provided their consent).

7. Workplace diversity

(a) Are Media encourages diversity, equity and inclusion, and ultimately values Suppliers who promote diversity within their supply chain and workplace through, for example and not limited to, differences in gender, age, sexuality, religion, (dis)ability and life experience.

(b) Are Media values Suppliers who have policies and practices in place to ensure diversity and equal opportunities for all people where possible.

8. Human rights and modern slavery

(a) Are Media does not tolerate any instances of modern slavery within workplaces.

(b) Are Media annually publishes a modern slavery statement outlining its commitment to identifying risks of modern slavery in operations and supply chains, and taking action to continually address and minimise such risks.

(c) Suppliers must make all reasonable efforts and exercise due diligence to reasonably assure that the businesses within their supply chains are not engaged in, benefitting from or complicit with human rights exploitations including but not limited to slavery, forced labour, the worst forms of child labour and other forms of modern slavery practice as defined in the Modern Slavery Act 2018 (Cth).

(d) Are Media requires Suppliers to:

(i) review Are Media’s modern slavery statement;

(ii) prohibit any involvement in forced labour or other forms of modern slavery in their business and in their supply chain;

(iii) comply with all applicable modern slavery laws;

(iv) conduct appropriate risk assessments;

(v) where required by law, have in place a modern slavery statement, and where not required by law, consider developing a voluntary modern slavery statement; and

(vi) where relevant, establishing policies, procedures and practices which address modern slavery risks within supply chains.

9. Reporting mechanisms

(a) Suppliers should have in place an internal policy with processes for employees, or their suppliers to report on any concerns they have regarding unethical, improper or illegal conduct in connection with the relevant Supplier’s business, which may include but is not limited to, health and safety breaches, environmental concerns or any modern slavery risks.

(b) Such internal policy should allow for anonymous reporting of any allegations of misconduct without fear of repercussions.

ETHICAL EXPECTATIONS

10. High standards of conduct

(a) Are Media values honesty and integrity and is committed to high ethical standards, placing these same expectations on its Suppliers.

(b) Suppliers, their employees and contractors are expected ensure they act in a respectful and lawful manner and in a way which does not bring their business and governance into disrepute.

11. Business integrity

(a) Suppliers must comply with all applicable competition, anti-bribery, anticorruption and anti-money laundering laws and regulations, and must not engage in any indirect or direct, fraudulent, corrupt or collusive activities.

(b) Suppliers are to have appropriate policies & procedures in place to monitor compliance with the above laws and regulations.

12. Managing conflicts of interest

(a) Suppliers must take appropriate steps to ensure any conflicts of interest (whether actual, reasonably perceived or with the potential to arise in the future) which exist between Are Media and the Supplier, their employees, or any of their other representatives, are disclosed to Are Media as soon as possible.

13. Required standards

(a) All goods and services provided by Suppliers must, where applicable, meet relevant compliance requirements and Australian Standards or international standards as required.

14. Record keeping and handling of confidential information

(a) Any confidential or commercially sensitive information relating to or in connection with the Supplier’s dealings with Are Media, is not to be improperly used.

(b) Suppliers must take a diligent approach to ensure confidential or commercially sensitive information relating to or in connection with the Supplier’s dealings with Are Media is managed in accordance with any policies and confidentiality agreements.

(c) 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.

15. Good business practices

(a) To avoid disputes and promote a good working relationship, Suppliers are to ensure their business is conducted in a way which promotes a collaborative relationship with all buyers and suppliers.

16. Employee inducements

(a) Suppliers are to respect Are Media’s code of conduct and must not try to influence any of Are Media’s employees’ decisions through the use of any inducements such as the offering of gifts, benefits or making any improper payments.

17. Data and privacy

(a) Are Media is committed to protecting the privacy of personally identifiable information and expect Suppliers to:

(i) comply with all applicable data protection, privacy and information security laws and regulations;

(ii) only use data from Are Media which is required by the Supplier to deliver the products and services they have been engaged to provide;

(iii) take all reasonable steps to protect all personal information and data;

(iv) notify Are Media of any suspected data breaches; and

(v) have their own privacy policies and processes in place for any data breaches.

EFFECTIVE MANAGEMENT AND ASSESSMENT

18. Review and audit

(a) Suppliers should review their own compliance with this Code on a regular basis to ensure ongoing compliance and remedial action if and when required.

(b) Are Media may elect to conduct assessment on any Supplier’s practices to ensure they are adhering with this Code. Are Media aims to work closely with Suppliers

to identify any areas of improvement moving forward when it comes to complying with this Code.

19. Grievance mechanisms

(a) Suppliers must have procedures in place to allow employees to bring workplace concerns to their attention. Such procedures are to be communicated with employees in an accessible and culturally appropriate manner.

20. Suspected breaches of the Code

(a) In the event of a suspected breach of this Code by any Suppliers, Are Media may request additional documentation or information demonstrating compliance from the Supplier. Are Media may also request access to the Supplier’s premises where reasonably required to carry out an assessment and compliance audit of the Supplier’s operations.

(b) Are Media expects Suppliers to assist and cooperate with them in a timely manner when it comes to the requesting of information, documentation or access to the Supplier’s premises in the event of a suspected breach of this Code.

(c) Are Media expects and encourages suppliers to communicate this Code with their supply chain and business, and support their supply chain, if and when required, to rectify any non-compliance or deficiencies.

(d) Are Media take this Code seriously and any material non-compliance may result in the termination of the Supplier’s business relationship with Are Media.

21. Reporting on suspected breaches

(a) Any concerns regarding suspected breaches or breaches of this Code are to be directed and reported to Are Media as soon as possible.

(b) Are Media does not tolerate any corrupt, illegal or other undesirable conduct by Suppliers and does not condone victimisation of an individual or group who intends to report on or have reported on such conduct.

(c) Any concerns regarding the suspected breach or breach of this Code will be assessed fairly against the potential or actual impact of the non-compliance, and Are Media will take a proportionate response, aiming to offer support in the first instance where possible, or establish a remediation plan with the Supplier to address any actual or potential non-compliance.

 

Adopted: 4 December 2024