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Statement - AST 11.08.01 - Supplier Code of Conduct 

1.0 Our Expectations of Suppliers 

Altus Group is committed to conducting business ethically, responsibly, and in alignment with legal, human rights, and environmental standards. Our suppliers are critical to upholding these commitments and supply chains.

2.0 Scope and Compliance 

This Code applies to all suppliers, including their employees, contractors, and business partners. Suppliers must ensure awareness and adherence to these standards throughout their operations and promptly report any known or suspected breaches to Altus Group. Where contractual terms differ from this Code, the more stringent requirement will apply. 

3.0 Ethical Conduct and Business Integrity 

Suppliers must: 

  1. Comply with all applicable laws, including those related to anti-corruption, money laundering, and financial crime.

  2. Compete fairly and avoid practices such as bid-rigging, price-fixing, and misuse of market power.

  3. Refrain from offering, accepting, or requesting gifts, entertainment, or favours that could improperly influence business decisions.

  4. Disclose any actual or perceived conflicts of interest immediately.

  5. Maintain accurate, complete, and legally compliant records.

  6. Notify Altus Group of any significant legal or regulatory changes that may impact compliance with this Code.

3.1 Labour and Human Rights 

Altus Group expects suppliers to uphold the UN Guiding Principles on Business and Human Rights and the Ten Principles of the UN Global Compact. Suppliers must: 

  1. Prohibit all forms of forced, bonded, or child labour, and ensure that employment is freely chosen. 

  2. Ensure working conditions, wages, and hours comply with local laws and support worker wellbeing. 

  3. Respect the right to freedom of association and collective bargaining. 

  4. Provide a safe, inclusive, and harassment-free workplace, free from discrimination based on personal characteristics. 

  5. Promote equal opportunity and fair treatment in hiring, development, and advancement. 

3.2 Health, Safety, and Substance Management 

Suppliers must comply with all relevant health and safety laws and uphold Altus Group’s safety management standards. 

  1. Workplaces must be free from hazards, and all incidents or injuries must be recorded and mitigated appropriately. 

  2. Employees and subcontractors must be fit for duty and not under the influence of drugs or alcohol while performing work duties. Reasonable drug and alcohol testing policies should be implemented where appropriate. 

3.3 Environmental Responsibility 

Suppliers must comply with all environmental regulations and implement practices that minimise negative impacts. This includes promoting sustainable resource use, reducing waste and emissions, and supporting responsible sourcing. 

3.4 Privacy and Confidentiality 

Suppliers must protect personal and confidential data using appropriate safeguards in accordance with applicable privacy laws. Any suspected or confirmed data breaches must be reported immediately to Altus Group. 

3.5 Grievance and Whistleblower Protection 

Suppliers must ensure employees can raise concerns without fear of retaliation. Altus Group encourages the reporting of any unethical, unlawful, or unsafe conduct via its confidential whistleblower channels: 

  • Phone: +61 2 8887 6968 

  • Email: speakup@altusgroup.com.au 

4.0 Monitoring and Enforcement 

Altus Group reserves the right to assess supplier compliance with this Code. Any breach, particularly those involving modern slavery, safety violations, corruption, or discrimination, may result in corrective action, suspension, or termination of the business relationship. 

This Code aligns with applicable laws in Australia and New Zealand and reinforces Altus Group’s commitment to ethical, lawful, and transparent business conduct worldwide.