Subcontract to Arokin

When a subcontractor's guard stands at a door under an Arokin engagement, the client sees Arokin. This Code sets the standard a subcontractor accepts when working with Arokin Pty Ltd, so that the service a client receives is the same whoever supplies the person delivering it.

This Code applies to every subcontractor engaged by Arokin, to their directors and managers, and to every person they deploy under an Arokin engagement. Acceptance of this Code is a condition of onboarding, and continued compliance is a condition of every engagement.

Engagement requirements

Before supplying any services, and continuously during an engagement, a subcontractor must hold and maintain:

The subcontractor must notify Arokin in writing within two business days if any licence or insurance above is suspended, cancelled, refused renewal or allowed to lapse, or if the subcontractor becomes subject to regulatory action affecting its ability to operate. Documents are re-verified on expiry and at least annually.

Personnel standards

Every person a subcontractor deploys under an Arokin engagement must:

• Hold a current security licence of the correct class for the work performed, issued in the state or territory of the work
• Hold current first aid and any other credential the site, the client or the licensing conditions require
• Have their legal right to work in Australia verified by the subcontractor before deployment
• Arrive on time, briefed for the site, in the agreed uniform or dress standard, and fit for duty
• Comply with site orders, venue conditions and lawful directions given by Arokin's supervisor or the client
• Work calmly and professionally, using de-escalation first and force only where lawful, proportionate and necessary
• Remain free of alcohol and unlawful drugs on duty, consistent with the Arokin Drug and Alcohol Policy

Arokin may require the removal of a deployed person from a site where their conduct, licensing or presentation does not meet this Code. Removal from site is operational, not disciplinary; the subcontractor remains responsible for their own personnel processes.

Lawful engagement of workers

The subcontractor must:

• Pay every worker no less than their lawful entitlement under the applicable modern award or industrial instrument and the Fair Work Act 2009 (Cth), including superannuation
• Engage workers in the correct legal form, and not disguise an employment relationship as independent contracting
• Never charge a worker a fee for a shift, withhold wages against invented debts, or retain a worker's passport, licence or other identity documents
• Comply with the Arokin Modern Slavery and Ethical Sourcing Policy, watch for the exploitation indicators it describes, and report any concern to Arokin

No further subcontracting

The subcontractor must not subcontract any part of an Arokin engagement to another entity without Arokin's prior written consent. Where consent is given, this Code applies to the further subcontractor in full, and the first subcontractor remains responsible for compliance down the chain.

Work health and safety

The subcontractor holds its own duties under the Work Health and Safety Act 2011 (NSW) and must:

• Induct its personnel into the site-specific risks and controls for each deployment
• Provide any personal protective equipment its personnel require, to the standard in the Arokin Personal Protective Equipment Policy
• Report every notifiable incident, injury or near miss connected to an Arokin engagement to Arokin's supervisor on the same shift, and cooperate with the Arokin Incident Management Plan
• Manage fatigue across its rosters so that no person is deployed unfit to work, consistent with the Arokin Fatigue Management Plan

Conduct towards people

The subcontractor and its personnel must treat colleagues, client staff, patrons and the public with dignity and respect, and must comply with the standards in the Arokin Equal Employment Opportunity Policy and the Workplace Behaviour and Anti-Harassment Policy while engaged on Arokin work. Discrimination, harassment, bullying and victimisation are not tolerated from any person on an Arokin engagement, whoever employs them.

Records, information and audit

The subcontractor must:

• Keep accurate records of the licensing, credentials, right-to-work verification, rosters and pay of personnel deployed under Arokin engagements
• Make those records available to Arokin on reasonable notice where needed to verify compliance with this Code, a client requirement or a regulator's inquiry
• Handle any personal information obtained during an engagement in accordance with the Privacy Act 1988 (Cth), and use client and site information only for the engagement
• Not make media comment, social media posts or marketing claims about a client, a venue or an incident connected to an Arokin engagement without written consent

Raising concerns

A subcontractor, or any of its workers, may raise a concern about conduct on an Arokin engagement with the Arokin supervisor or directly with the Director at operations@arokin.group. Concerns about serious misconduct may attract the protections described in the Arokin Whistleblower Policy, which extends to suppliers, subcontractors and their employees. No one will be disadvantaged for raising a concern in good faith.

Breaches

Where a subcontractor breaches this Code, Arokin may, depending on seriousness: require a corrective action plan, suspend rostering, remove personnel from site, terminate the engagement, or decline future engagements. Conduct that may breach licensing law is reportable to the relevant licensing authority, and conduct that may be a criminal offence will be referred to NSW Police. Nothing in this Code limits Arokin's rights under the engagement contract or at law.

Acknowledgement

Each subcontractor accepts this Code in writing during onboarding, and re-acknowledges it when the Code is revised. The current version is provided with the onboarding pack and is available from operations@arokin.group at any time.

Review

This Code is reviewed at least every two years, and sooner if legislation changes, if an incident or audit reveals a gap, or if client requirements change. The Director approves each revision.

Arokin Pty Ltd does not tolerate modern slavery in any form, in its own operations or in its supply chain. Arokin is not currently required to publish a modern slavery statement under the Modern Slavery Act 2018 (Cth), which applies to entities with annual consolidated revenue of at least one hundred million dollars. This policy is adopted voluntarily because the standard is right, because the security industry carries known labour-supply risks, and because the clients and principal contractors we work with are entitled to know where we stand.

This policy applies to all Arokin personnel, to every subcontractor engaged by Arokin, and to the suppliers of goods and services we purchase. It applies to conduct at every Arokin workplace, including client venues and sites.

What modern slavery means

Modern slavery describes situations where coercion, threats or deception are used to exploit people and deprive them of their freedom. It includes conduct dealt with under the Modern Slavery Act 2018 (Cth) and the Criminal Code Act 1995 (Cth), such as:

• Slavery, servitude and forced labour
• Debt bondage, where a person works to repay a debt on terms they cannot realistically satisfy
• Human trafficking
• Deceptive recruiting for labour or services
• The worst forms of child labour

Modern slavery also sits at the extreme end of a spectrum of labour exploitation. Conduct short of slavery, such as systematic underpayment, sham contracting, withholding of identity documents or coercive control of accommodation, is a warning indicator and is treated seriously under this policy even where it is not itself a modern slavery offence.

Why this matters in security work

Security is a labour-supply industry. The known risk patterns are specific and Arokin watches for them directly:

• Long subcontracting chains, where the entity rostering a guard is several steps removed from the entity that pays them
• Sub-award payment, cash-in-hand arrangements and unpaid trial shifts
• Workers engaged as contractors when they are in substance employees
• Recruitment fees charged to workers, or wages withheld against invented debts
• Visa holders pressured with threats about their immigration status
• Retention of passports, licences or other identity documents by an engager

Our commitments

Arokin commits to:

• Engaging personnel directly wherever practicable, and paying in accordance with the applicable industrial instruments and the Fair Work Act 2009 (Cth)
• Verifying the identity, right to work and security licensing of every person deployed under our master licence, as set out in the Right to Work (VEVO) Policy and the Licence and First Aid Verification Procedure
• Conducting due diligence on every subcontractor before engagement, including verification of their ABN, their own security master licence, their insurances and their completed Subcontractor's Statement
• Requiring every subcontractor to accept the Subcontractor Code of Conduct, which carries these obligations into their own workforce
• Refusing to engage, and disengaging from, any entity that Arokin reasonably believes is involved in modern slavery or serious labour exploitation
• Preferring suppliers who can demonstrate their own ethical sourcing standards
• Training managers who engage labour or suppliers to recognise the warning indicators listed in this policy

Due diligence on subcontractors

Before a subcontractor supplies personnel under an Arokin engagement, Arokin verifies:

Engagements are not confirmed until each check is complete. Checks are refreshed when a document expires and at least annually for ongoing arrangements.

Raising a concern

Any person, including a subcontractor's worker, who suspects modern slavery or serious labour exploitation connected to Arokin's operations or supply chain should report it to their supervisor or directly to the Director at operations@arokin.group. Reports may be made anonymously. Reports made in good faith will never result in victimisation or disadvantage, and may attract the protections described in the Whistleblower Policy.

Where a report suggests a person is in immediate danger, contact NSW Police on 000 first. Concerns about modern slavery can also be raised with the Australian Federal Police or the Australian Border Force.

Responding and remediation

Where Arokin identifies modern slavery or serious labour exploitation connected to its operations or supply chain, it will:

1. Act first to protect the affected person, prioritising their safety and, where they wish it, connecting them with the appropriate authorities and support services.
2. Suspend the implicated engagement while the matter is examined.
3. Where the engager is willing and able to remediate, require a corrective plan with evidence and a deadline.
4. Where they are not, terminate the engagement.
5. Report conduct that may be a criminal offence to the appropriate authority.
6. Review how the risk entered the supply chain and correct the gap in our own checks.

Responsibilities

Legislative framework

This policy is informed by, among others:

• Modern Slavery Act 2018 (Cth)
• Criminal Code Act 1995 (Cth), divisions 270 and 271
• Fair Work Act 2009 (Cth)
• Security Industry Act 1997 (NSW)
• Migration Act 1958 (Cth)

Where this policy and the law differ, the law prevails.

Review

This policy is reviewed at least every two years, and sooner if legislation changes, if a concern raised under it reveals a gap, or if Arokin's engagement model changes. The Director approves each revision.

People who speak up about wrongdoing protect everyone who works with Arokin, the clients we serve and the public in our venues. Arokin Pty Ltd is not required by the Corporations Act 2001 (Cth) to maintain a whistleblower policy, because that obligation applies to public companies and large proprietary companies. We maintain one anyway, because the whistleblower protections in Part 9.4AAA of the Corporations Act apply to companies of every size, and because a person deciding whether to report misconduct should be able to read, in plain terms, what will happen when they do.

This policy applies to reports about Arokin Pty Ltd, its officers and its personnel, and to conduct connected with Arokin's operations, including conduct by or affecting subcontractors.

Who can make a protected disclosure

Under the Corporations Act, protection can extend to a current or former:

• Officer or employee of Arokin
• Individual who supplies services or goods to Arokin, paid or unpaid, including a subcontractor
• Employee of a supplier or subcontractor of Arokin
• Associate of Arokin
• Relative, dependant or spouse of any of the above

You do not have to identify yourself to make a report or to qualify for protection. Anonymous reports are accepted and investigated so far as the information allows.

What can be reported

A report is protectable where the person has reasonable grounds to suspect misconduct, or an improper state of affairs or circumstances, in relation to Arokin. Examples relevant to our operations include:

• Dishonest, fraudulent or corrupt conduct, including falsified rosters, invoices or incident records
• Unlicensed persons performing security activities, or misrepresentation of licensing
• Deliberate breaches of work health and safety duties, or concealment of incidents
• Underpayment of workers, sham contracting or other serious labour exploitation, including conduct described in the Modern Slavery and Ethical Sourcing Policy
• Offering or accepting secret commissions or improper inducements
• Conduct that breaks a law of the Commonwealth or a state, or represents a danger to the public
• Victimisation of a person for having made, or proposing to make, a report

A personal work-related grievance, such as a disagreement about a roster, a promotion decision or an interpersonal conflict, is generally not covered by the statutory whistleblower protections. Those matters are handled under the Equal Employment Opportunity Policy and the Workplace Behaviour and Anti-Harassment Policy. A grievance that also involves the kinds of misconduct listed above, or victimisation for reporting, can still be protected.

How to make a report

1. Report to the Director, in person, by phone or at operations@arokin.group. Mark written reports "Confidential - Whistleblower".
2. If the report concerns the Director, or you do not wish to raise it internally, the Corporations Act permits protected disclosures to the Australian Securities and Investments Commission (ASIC), and in specific circumstances to a legal practitioner for advice about the whistleblower provisions.
3. Reports may be made anonymously. If you provide a means of contact, we can seek clarification and keep you informed; if you do not, we will still assess and act on the information provided.

Protections

A person who makes a report covered by this policy:

• Has their identity kept confidential. Identifying information is disclosed only with the person's consent, or to ASIC, the Australian Federal Police or a legal practitioner as the Corporations Act permits. Information likely to identify the person may otherwise be used only where reasonably necessary to investigate, with all reasonable steps taken to protect their identity.
• Must not be victimised. Dismissal, demotion, harassment, discrimination, injury or any other detriment caused because of an actual or suspected report is unlawful under the Corporations Act, attracts civil and criminal penalties, and will be treated by Arokin as serious misconduct in its own right.
• Cannot be subjected to civil, criminal or administrative liability for making the protected disclosure itself. Deliberately reporting information known to be false is not protected and is a breach of this policy.

How reports are handled

1. The report is acknowledged promptly where a contact channel exists.
2. The Director, or an appropriate person where the Director is conflicted, assesses whether the matter falls under this policy and how it will be investigated.
3. The investigation is proportionate, objective and fair. A person whose conduct is questioned is given the substance of the concerns and a fair opportunity to respond before findings are made, in a manner that protects the reporter's identity.
4. Records are kept securely and access is restricted to those who need it.
5. On conclusion, the reporter is told the outcome where practicable and appropriate. The level of detail may be limited by privacy and legal obligations.
6. Where the investigation identifies misconduct, Arokin acts under the relevant policy, up to termination of employment or engagement and referral to NSW Police or the appropriate regulator.

Responsibilities

Availability of this policy

This policy is provided to personnel at induction, is included in the policy pack issued to clients and principal contractors, and is provided to subcontractors during onboarding.

Legislative framework

This policy is informed by, among others:

• Corporations Act 2001 (Cth), Part 9.4AAA
• Taxation Administration Act 1953 (Cth), which provides parallel protections for reports about tax affairs
• Fair Work Act 2009 (Cth)

Where this policy and the law differ, the law prevails.

Review

This policy is reviewed at least every two years, and sooner if legislation changes or if the handling of a report reveals a gap. The Director approves each revision.