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Work Health Safety Policy

 

1.0 Overview and purpose

Work Health and Safety (WHS) is of paramount importance to Bendigo and Adelaide Bank

The Group values their people and their well-being. The Group is committed to providing safe and healthy workplaces for all their workers, customers and other visitors. The Group aims to have injury free Workplaces and to comply with all WHS legal requirements.

The Group takes all reasonably practicable steps to ensure that it does not expose its workers, customers or other visitors to risks to their health and safety from the conduct of its business. This approach is supported by the Operational Risk Management Framework and related policies.

2.0 Policy statement
What does the Group do to meet its commitment to WHS?

A proactive approach to WHS is critical. To meet our commitment, the Group takes all reasonably practicable steps to ensure the health and safety of persons affected by its business or undertaking, through the development, implementation and enforcement of policies and procedures.

These policies and procedures will provide for the following objectives so far as reasonably practicable.

  • The provision and maintenance of a safe work environment.
  • The provision and maintenance of safe systems of work including safe plant and structures.
  • The safe use, handling and storage of plant, structures and substances.
  • The provision of appropriate information, training, instruction or supervision of all workers as necessary for them to perform their role safely.
  • The identification of any hazards and associated risks at workplaces.
  • The prompt implementation of risk control strategies to eliminate risks and, where that is not reasonably practicable, to minimise those risks so far as reasonably practicable.
  • The provision of adequate welfare facilities at workplaces.
  • Monitoring the health of workers and conditions at the workplace for the purposes of preventing illness and injury.
  • Active participation in raising and resolving WHS issues.
  • The promotion of active rehabilitation and return to work programs with the aim of ensuring a full return to pre-injury duties wherever possible.

The Group recognises the importance of consultation between management and workers in matters relating to WHS and also engaging in consultation with other entities as necessary to ensure that common safety matters are the subject of consultation, co-operation and co-ordination.

BEN may also provide directions, advice or assistance to other entities associated with BEN in the management of health and safety matters by those entities, to assist them in the protection of the health and safety of their workers and others to whom they owe duties, so far as reasonably practicable.

Note: This may include Rural Bank, Community Bank® companies and Agencies.
BEN also has articulated a set of responsibilities for its board and committees to assist in managing WHS. These are described in section 4 of this policy.

Are there any additional responsibilities for some roles? Additional responsibilities apply to Workers, Health and Safety Representatives, the Senior Manager WHS, Managers and Officers. These are set out in section 4 of this policy. The responsibilities of Group Operational Risk are also set out in section 4.
3.0 Scope
Scope

The Policy applies to all Group workplaces and to all Group workers.

4.0 Responsibilities for specified roles
Workers and Others

Everyone at a workplace, including workers and others, are responsible for taking reasonable care for their own health and safety and taking reasonable care that their acts or omissions do not adversely affect the health and safety of themselves or others.

Workers are also responsible for complying with the Group’s WHS policies and procedures, and for following the Group’s Incident, Near Miss & Hazard Reporting Guidelines.

Health and Safety Representatives

The Group’s health and safety representatives represent the health and safety interests of the members of their designated work group. BEN recognises the important role of HSRs and encourages their election to designated work groups. All reasonable support and assistance will be given to HSRs in exercising their rights and responsibilities.

Powers and functions of HSRs may vary slightly from jurisdiction to jurisdiction but generally, HSRs have the following primary responsibilities:

  • Take reasonable steps to keep themselves informed on WHS issues and encourage consultation between workers and management.
  • Provide advice, raise awareness or assist in the resolution of WHS issues within their designated workgroup or work area.
  • Accompany WHS Inspectors during inspections of their designated work group.
  • Assist management to identify hazards, assess risks and implement risk control measures.
  • Direct that work ceases to occur where there is an immediate and significant threat to the health and safety of a worker.
  • Participate in WHS consultative forums and/or local WHS Committees in relation to WHS issues that affect their work group.
Senior Manager, WHS

The BEN Senior Manager, WHS has the following responsibilities:

  • Assisting the Group in the implementation of this WHS policy.
  • The ongoing review of this WHS policy and WHS procedures, and making recommendations for any amendments.
  • Periodic reporting about WHS matters that will assist duty holders under this policy to fulfil their duties.
  • Monitoring, reviewing and analysing all reported injuries and hazards arising from the Group, Rural Bank and Community Bank® companies, and determine whether appropriate corrective actions have been put in place.
  • Ensuring the reporting of notifiable incidents to external regulators, under the WHS legal requirements in the relevant State or Territory.
Managers

Managers within the Group with direct reports have the following responsibilities.

  • Demonstrating appropriate leadership behaviours in relation to WHS.
  • Making sure all necessary WHS instruction, information, training or supervision is provided to their reports so that individuals can safely perform their expected roles.
  • Making sure there are regular WHS inspections of the workplace so that hazards are identified and controlled.
  • Requiring people within their team to comply with relevant WHS policies and procedures, and to use the safety management tools available to them effectively.
  • Adopting the BEN process of hazard identification, risk management and incident investigation.
  • Promoting effective WHS consultation with Group workers, health and safety representatives and contractors so that WHS information is disseminated and WHS issues are identified and resolved in a timely manner.

In addition:

  • Managers must not organise or take, threaten to organise or take, or authorise or coerce others to take, any action against a health and safety representative exercising their powers or performing a required function of that role, or treat the health and safety representative less favourably because of the role they undertake.
  • A Manager who engages a contractor to provide services will confirm, as far as is reasonably practicable, that all workers providing the services receive all necessary WHS information, instruction, training or supervision to safely perform the services.
Group Operational Risk

Group Operational Risk has the following responsibilities.

  • Documenting the Operational Risk Management Policy and the Operational Risk Management Framework.
  • Independent monitoring and reporting of operational risk and loss events for the Group.
  • Development, implementation and maintenance of operational risk management tools to assist the identification, evaluation, control and treatment of operational risk across the Group.
  • Maintenance of databases for recording operational events identified throughout the Group.
  • Support and maintenance of the risk registers.
  • Recommending education and training in relation to operational risk management practices and processes.
  • Ongoing maintenance of the Operational Risk Management Framework.
Officers

Officers within the Group will exercise due diligence over WHS compliance. This requires taking reasonable steps to ensure the Group entity for which they have responsibility complies with its WHS duties and obligations.

Note: These obligations may extend to workers employed or engaged by entities other than Group entities.

Due diligence includes taking reasonable steps to do each of the following.

  • Acquire and keep up-to-date knowledge of work health and safety matters within the entity.
  • Gain an understanding of the nature of the operations of the entity, and generally of the hazards and risks associated with those operations.
  • Ensure that the entity has available for use, and uses, appropriate resources and processes to eliminate or minimise risks to health and safety from work it carries out.
  • Ensure that the entity has appropriate processes for receiving and considering information regarding WHS incidents, near misses, hazards and risks and responding in a timely way to that information.
  • Ensure that the entity has, and implements, processes for complying with its duty under applicable WHS legislation.
  • Verify the provision and use of the above resources and processes.
5.0 Responsibilities of BEN committees and the Board
Regional WHS Committee

The Regional WHS Committee is a national BEN committee, comprising elected Group health and safety representatives from across Australia and the Manager Health, Safety and Wellbeing, with responsibilities set out in a charter.

Note: At the date of this policy, the responsibilities are as follows.

  • Providing a communication and consultation mechanism for the Group’s, Rural Bank’s and Community Bank® companies’ workers, including input into the development of WHS policies and procedures.
  • Assisting in the consultation process by receiving and disseminating WHS information to and from designated working groups, Divisional WHS Committees and the Group WHS and Security Management Committee.
  • Monitoring the progress of WHS initiatives being implemented across BEN and considering their effectiveness.
  • Reviewing regional WHS training achievements and requirements.
  • Receiving updates on WHS legislation.
Operational RegRisk Committee

The Operational Risk Committee is a sub-committee of the Executive Committee. It reports to the Executive Committee, with its responsibilities set out in a charter.

Note: At the date of this policy, the responsibilities relevant to WHS are as follows.

  • Monitoring the operational risk profile of the Group and branches of Community Bank® companies.
  • Monitoring the occurrence and treatment of significant loss events and compliance breaches, including WHS.
  • Considering any significant treated risks resulting from various types of risk assessment (including WHS and security reviews) and where appropriate approve the acceptance of this level of risk.
  • Considering the results of monitoring of key operational risks of the Group and the branches of Community Bank® companies.
  • Monitoring the development of operational risk policies and frameworks (including operational risk appetite and tolerances) with principles approved by the BEN Board Risk Committee
  • Monitoring regulatory and legal changes impacting the Group and providing oversight and guidance on the program of regulatory change
  • Directing the appropriate recording of any risk (including material WHS risks) to the business unit risk register where resolution of an escalated issue remains unresolved
  • Referring any particular WHS matters to the Group WHS & Security Management Committee as appropriate.
Group WHS and Security Management Committee

The Group WHS and Security Management Committee is a sub-committee of the Executive and reports to the Executive Committee, with its responsibilities set out in a charter.

Note: At the date of this policy, the responsibilities are as follows.

  • Providing effective leadership in WHS and security.
  • Receiving and considering information on the performance and continuous improvement of WHS and Security within BEN.
  • Reviewing, endorsing and/or approving WHS and Security operational strategies, plans, standards, procedures and guidelines.
  • Reporting and/or referring matters (including recommendations) to the BEN Executive relating to the:
    • BEN WHS Policy;
    • BEN WHS Quarterly Performance Report;
    • BEN WHS Continuous Improvement Plan; and
    • Any other WHS or Security issue it considers appropriate.
  • Considering, advising and taking action on issues referred to it by the Executive Committee and of its own initiative.
  • Receive and consider reports in relation to WHS and security issues within the Group, the branches of Community Bank companies and Agencies.
  • Considering, advising and taking action on matters that are escalated from a Divisional level
Executive Committee

The Executive Committee is a committee established by the BEN Managing Director. It is responsible for the following in relation to WHS.

  • Receiving and considering the BEN WHS Report.
  • Receiving and considering any recommendations made by the Group WHS and Security Management Committee.
  • Endorsing recommendations regarding health and safety, or the implementation of new policies or procedures as appropriate.
  • Recommending key WHS policies to the Board Governance & HR Committee.
  • Referring matters for consideration to the Group WHS and Security Management Committee.
  • In relation to resources, responding to any specific requests, or acting on its own initiative, to ensure that sufficient resources are available within the Group to undertake effectively all necessary WHS measures.
  • Exercising due diligence, by taking reasonable steps to ensure that BEN is meeting its WHS legal obligations.

Note: This may include in respect of employees employed or engaged by entities other than Group entities.

The Committee also makes recommendations to the Board Governance & HR Committee on any changes to WHS practices that the Committee regards as necessary or desirable, for consideration by the Board Governance & HR Committee as appropriate.

Board Governance & HR Committee

The Governance & HR Committee is a committee of the BEN Board, with its responsibilities set out in a charter.

Note: At the date of this policy, the responsibilities relevant to WHS are as follows.

  • Receiving and considering the BEN WHS Report.
  • Considering recommendations of management in relation to key WHS policies and amendments to those policies and making recommendations to the Board.
  • Considering recommendations of management in relation to changes to the Operational Risk Management Framework which relate to WHS and approving any changes.

Note: Changes to the Framework must also be approved by the Board Risk Committee.

  • Receiving and considering any recommendations proposed by management on changes to WHS practices.
  • Exercising due diligence, by taking reasonable steps to ensure that BEN is meeting its WHS legal obligations.

Example: This may include in respect of employees employed or engaged by entities other than Group entities.

Board Risk Committee

The Risk Committee is a committee of the BEN Board, with its responsibilities set out in a charter. Its purpose is to provide assistance to the Board in relation to oversight of risk, taking into account the risk profile and appetite of the Group, the overall business strategy and management expertise. This includes the establishment, implementation, review and monitoring of risk systems and policies for Operational risk, including regulatory compliance and business continuity. This includes approving any changes to the Operational Risk Management Framework.

Note: Changes to the Framework which relate to WHS must also be approved by the Board Governance & HR Committee.

Note: At the date of this policy, additional responsibilities relevant to WHS are as follows.

  • Overseeing the establishment and implementation of risk management systems, and monitoring and reviewing those systems currently in place, relating to operational risk. This includes setting risk tolerance levels and recommending related/new policies to the Board for approval.
  • Monitoring and reviewing the operational risk profile and loss events across the Group (including Moderate and Extreme rated WHS loss events).
  • Providing oversight on the treatment of significant regulatory compliance risks and breaches. This includes oversight of escalation and rectification decisions.
  • Reviewing the activities and reporting of the management Operational Risk Committee.
  • Receiving the Operational risk report including analysis of significant risks, trends, risk profile (existing, new and emerging risks), operational risk loss summary incorporating analysis of significant operational losses and related treatment plans for the Group.
  • Receiving a consolidated overview of the risk and compliance declarations (six-monthly).
  • Annually, review and recommend to the Board any changes to the “Risk Appetite Statement”. At the date of this policy, in relation to WHS, the Risk Appetite Statement says: “The Group will not knowingly accept operational risk that improperly endangers the safety of its staff, customers, partners, contractors or other third parties”.
Board

The responsibilities of the BEN Board are set out in a charter.

Note: At the date of this policy, the responsibilities relevant to WHS are as follows.

  • Exercising due diligence, by taking reasonable steps to ensure that BEN is meeting its WHS legal obligations.

Example: This may include in respect of employees employed or engaged by entities other than Group entities.

  • Receiving and considering the following.
  • The BEN WHS Report.
  • Any WHS policies recommended by the Governance & HR Committee.
  • Any other matters brought forward by the Governance & HR Committee.
  • Responding to any specific requests for resources, to ensure that sufficient resources are available within the Group to allow them to undertake all necessary WHS measures effectively.

In addition, the charter provides for the Board to receive and consider recommendations from the Risk Committee annually on any changes to the “Risk Appetite Statement”.

6.0 Definitions and Interpretation

Related documents include the Operational Risk Management Framework.

Other documents relating to WHS are available from the BEN Intranet.

7.0 Definitions and Interpretation
Agencies

means third parties with an agency agreement with BEN, operating under the brand “Bendigo Bank”, to refer business or to provide day-to-day banking services.

BEN

means a report prepared on a quarterly basis by the Industrial Relations and Safety Department and provides information on the following.

  • Health and safety performance of the Group, Community Bank® companies and Rural Bank.
  • The measures taken or under way to ensure legal compliance and continual WHS improvement by the Group, Community Bank® companies and Rural Bank.
  • Details of WHS incidents or near misses which have occurred at Group and Rural Bank Workplaces and at branches of Community Bank® companies.
  • Current WHS escalation processes, particularly in relation to key WHS risks at Workplace, and branch security risk assessments for Community Bank® companies.
  • Other matters which may need to be brought to attention of BEN Officers as they may arise, from time to time.
Group

means:

  • Current WHS escalation processes, particularly in relation to key WHS risks at Workplace, and branch security risk assessments for Community Bank® companies.
  • Bendigo Bank agencies;
  • Bendigo Bank franchises (including Community Bank® branches); and
  • Bendigo and Adelaide Bank Related Entities that are not an ADI.

In the case of Related Entities who are ADIs (eg. Rural Bank Limited) its relevant Policy is to be considered and appropriately aligned to the intent of the Group’s Policy with Group Risk providing oversight. If there is a compelling reason for a Related Entity Policy to be materially different to the Group’s Policy then this needs to be submitted to the Group’s relevant risk forum for endorsement or otherwise.

Officer

means each of the following.

  • A person who is director or secretary of a Group entity.
  • A person who makes, or participates in making, decisions affecting the whole, or a substantial part of, the business of a Group entity.

Example: Executive Committee members.

  • A person who has the capacity to affect significantly the financial standing of a Group entity.
  • A person in accordance with whose instructions or wishes the directors of the Group entity are accustomed to act.
WHS

means Work Health & Safety.

Worker

means any person engaged or who is caused to be engaged by a Group entity, or whose work activities are influenced or directed by the Group.

Example: This may include workers employed or engaged by other entities.

This includes each of the following.

  • An employee of a Group entity.
  • A contractor engaged by a Group entity.
  • A sub-contractor, caused to be engaged by a Group entity.
  • A volunteer performing work for a Group entity.
  • A person seconded to or from a Group entity.
Workplace

means any place where work is carried out by a worker. In the case of a worker, it includes any place where the worker goes, or is likely to be, while at work.

Example: This may include vehicles (during travel for work), and homes (if a worker is working from home).

8.0 Review

This Policy is to be reviewed every two years by People & Performance and Group Operational Risk, for recommendation through the Executive Committee and Board Governance & HR Committee for approval by the Board. The Policy will be reviewed in July 2015.