The Queensland Government Supplier Code of Conduct: what to keep on file

When it applies and what you warrant

The code applies to all Queensland Government procurement activities regardless of value from the first of January this year. Rule 9 of the procurement policy requires every invitation to ask you to warrant that you adhere to it, and every contract to make a breach of the code a breach of the contract. Suppliers are expected to self-assess their adherence and fix shortcomings, and suppliers engaged on contracts executed since the code began must make and retain records demonstrating adherence. You must also cooperate with Queensland Government Procurement assessments and provide documents reasonably requested.

The expectations, grouped

The code has three groups. In the code's own terms, with the document it implies in brackets:

• Ethical: disclose actual, perceived and potential conflicts of interest at every stage, and submit a copy of your conflicts-of-interest policy where you have one (a conflicts-of-interest policy); no fraud, corruption, inducements or gifts to officers; practical cybersecurity and privacy practices (an information handling practice you can describe); no collusion or misuse of market power; subcontractor payment terms no less favourable than the government gives you, and trust account requirements under the Building Industry Fairness legislation where they apply; goods and services that meet the Australian Standard where one is specified.
• Social: manage and review workplace hazards and train staff (a safety system); act to stop domestic and family violence, for example a stated zero-tolerance approach or a workplace policy (a domestic and family violence workplace policy); pay entitlements and respect workplace rights; make reasonable efforts against human rights exploitation in the supply chain, with risk assessments in vulnerable industries (a modern slavery risk statement or assessment); workplace diversity and equal opportunity; quality, secure local jobs; child safe standards where you work with children.
• Environmental: look for improvements such as waste minimisation and recycling, emissions reduction, renewable energy, less water and energy, correct disposal of hazardous substances and less packaging (an environmental practice statement, however short).

What happens on a breach

Concerns go to Queensland Government Procurement, which triages them under the Procurement Assurance Model Framework. The model's accountability stream runs from capability building through an improvement notice to a sanction or suspended sanction; a supplier suspended on the Procurement Assurance Portal cannot be engaged by any agency under rule 10 of the policy. The framework also says accountability prioritises capability building and treats removing suppliers as a last resort. From the first of January next year the model adds a voluntary incentive scheme: a tiered rating a supplier can opt into with an ABN or ACN, based on performance under government contracts and regulator data, with new suppliers exempt from initial assessment for their first twelve months. Its specific incentives were still to be published when this guide was written; check the framework for the current position.

A small business's checklist

What to have in a folder before the next Queensland tender:

• A one-page conflicts-of-interest policy and a register of disclosures made.
• A domestic and family violence workplace policy or a stated zero-tolerance position.
• A modern slavery risk statement proportionate to your supply chain, with the higher-risk categories named.
• Your safety system summary, current insurances and any certifications, with review dates.
• A short environmental practice statement.
• A note of the payment terms you give subcontractors.

How Helm fits

Helm's evidence library names the code's artefacts and shows which ones you already hold, matched conservatively on the titles of the documents you have stored; a gap is shown as a suggestion, never as an accusation. Each document carries a review date and Helm reminds you before it lapses, so the warranty you sign on the next invitation is one your records support. On Queensland Government tenders the policy panel and the readiness checklist note that the code warranty applies.