To our stakeholders:

I am pleased to confirm that Aspen Medical Pty Ltd reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to sharing this information with our stakeholders using our primary channels of communication.

Sincerely yours, Bruce Armstrong
Chief Executive Officer, Aspen Medical

• We have policies to define our approach to Human Rights in the Our Team. Vulnerable People and Child Protection Policy which is included in any Humanitarian Contract prior to deployment.
• We also have policies to protect our staff such as our Code of Conduct, Respectful Workplace Behaviour, which is included in annual training and a Prevention and Management of Aggression in the provision of Health Services.
• Aspen Medical has been accredited as an Emergency Management Team under the World Health Organisation (WHO) for international Humanitarian work and as such our policies and procedures relating to Human Rights and Labour has been rigorously audited by the WHO prior to accreditation being awarded.
• Aspen Medical is also a certified B Corporation. Certified B Corporations are businesses that meet the highest standards of verified social and environmental performance, public transparency, and legal accountability to balance profit and purpose.
• As part of our Health Safety and Environmental Sustainability Policy we will respect the traditional rights and culture of Indigenous people wherever we work.
• Aspen Medical’s business operations are conducted in accordance our with accreditation of the International Standards Organisation (ISO) Quality Management System 9001:2015, Occupational Health and Safety and Management System 45001:2018, and Environmental Management System 14001:2015. These include all the elements of an integrated Management System which is audited by a third part annually.

• Operational policies and procedures supporting Human Rights
• Auditing by third parties of our Human Rights systems and practices (ISO and WHO)
• Awareness training for all managers and employees on Human Rights
• Consultation with stakeholders and affected parties especially in overseas missions
• Addressing the requirements of the B Corps Impact Assessment on Human Rights
• Responsibility statements specifically aimed at managers for the protection of Human Rights within the company and the community in which we serve
• Reporting mechanisms, monitored, reported and investigated

• Auditing by third parties of our Human Rights systems and practices (International Standards Organisation (ISO), B Corps and World Health Organisation (WHO)).
• Reporting Auditing results to the Board
• Incident Performance reporting through the Senior Management Team

• Aspen Medical has a policy that outlines its approach to business integrity in two parts: a Code of Ethics and a Code of Conduct. This policy applies to Aspen Medical and all of its subsidiaries and affiliates. Our Code of Ethics outlines the ethical principles of Aspen Medical and its staff, representing the aspirations of the company at the business level. Our Code of Conduct translates these principles into practical guidance that empowers Aspen Medical, its staff, its business partners and their employees to realise these aspirations. Our Business Ethics Policy – the combination of these two codes – has been developed to reinforce our commitment to honest and truthfulness and for the practical purpose of protecting Aspen Medical, its staff and business partners from acts of corruption, modern slavery (slavery, servitude, forced or compulsory labour, bonded labour) or human trafficking and the potential criminal liabilities.
• Our Team, Vulnerable People and Child Protection Policy aims to ensure the prevention of exploitation and abuse of vulnerable people. Aspen Medical recognises vulnerable people are at particular risk of being subjected to exploitation and abuse.
• Aspen Medical is preparing a Statement on Modern Slavery this year under the Modern Slavery Act 2018
• Aspen Medical is also a certified B Corporation. Certified B Corporations are businesses that meet the highest standards of verified social and environmental performance, public transparency, and legal accountability to balance profit and purpose which is audited by a third party to ensure compliance.

• Aspen Medical is committed to safeguarding the health, safety and wellbeing of our people, our patients, our partners, our clients and the communities in which we operate. Health, safety and environmental sustainability (HSES) is fundamental to the way Aspen Medical operates. People are at the heart of our capacity to be the preferred provider of outsourced health services wherever we are needed.
• Aspen’s Health, Safety and Environmental Safety Management System (HSEMS) is accredited to ISO 45001:2007 – Occupational Health and Safety Management. Aspen Medical is also accredited to ISO 14001:2004 – Environmental Management System.
• The Aspen Medical HSE Management System is comprised of management plans and procedures that will be implemented to work within other client HSEMSs or define sub-contractor HSEMS, meet compliance with legal and other requirements, minimise HSE risk and impacts, and achieve continual improvement through a cycle of planning, implementation, checking and reviews.
• Aspen Medical has a Risk Manager and a Risk Management Policy (AMGMP05) which defines our risk management compulsory requirements, responsibilities and standard methodology. Each Project Manager develops a Risk Management Plan with a Project specific Risk Register with their team that encompasses all risks relating to the project.
• Participation in international framework agreements and other agreements with the World Health Organisation, UN Global Compact, B Corps and the preparation of an Anti-Slavery Statement
• Operational policies and procedures supporting the Labour principles
• Addressing the requirements of the B Corps Impact Assessment on Labour rights
• Auditing by third parties of our Human Rights systems and practices (ISO and WHO)
• Awareness training for all managers and employees on labour rights and policies
• Consultation with stakeholders and affected parties
• Responsibility statements specifically aimed at Human Resources managers to prevent discrimination of all kinds and ensures comparable pay for comparable work
•

• A rigorous Risk Assessment process is conducted by all project teams to specifically assess the various risks the project team may be exposed to or impacted by. This process is particularly relevant for International Missions and overseas work and includes; Human Rights, Labour, Environment and anti-corruption elements
• Auditing by third parties of our Labour systems and practices (International Standards Organisation (ISO), B Corps and World Health Organisation (WHO)).
• Reporting Auditing results to the Board
• Incident Performance reporting through the Senior Management Team
• Annual reporting is completed for the Workers Gender Equality Report by the Workplace Gender Equity Agency (WGEA) comprising:
o Worker Profile
o Gender composition of workforce
o Gender composition of governing bodies
o Equal remuneration for women and men
o Consultation with employees on gender equality issues
o Sex-based harassment and discrimination
• Aspen Medical has a very high level of Health, Safety and Environmental (HSE) Performance, which is reported monthly to our senior management team, quarterly and annually to all managers including the Senior Management Team, the Corporate HSE Committee and the Board.
o Fatalities
o Fines and Sanctions
o Lost time injuries
o Medical treatments
o Days lost
o Lost Time Injury Frequency Rate (LTIFR)
o New Workers Compensation Claims
o Environmental Incidents

• Aspen Medical has an accredited Environmental Management System (EMS) to ISO 14001: 2015 and has held this for several years.
• Aspen Medical demonstrates its commitment to Health, Safety and Environmental Sustainability (HSES) in our HSES Policy Statement
• We publish our environmental commitment and performance annually in our EMHSEPL03 Environmental Sustainability Development Plan 2019 – 20
• Our Risk Management Processes include Environmental Risks as part of our 10 areas of risk
• Climate Change is a risk reported in our Strategic and Board Risk Registers
• Our EMS undergoes monthly Site Hazard inspections and six-monthly audits as part of our accreditation.
• Environmental hazards and incidents are required to be reported and investigated as per our AMHSE01 HSE Incident Reporting and Investigation SOP. Tracking is conducted in our RiskMan Incident Reporting system.
• Aspen Medical does not emit any pollutants from our work processes other than procuring utility supply, use of vehicles and third-party commercial aircraft.
• Aspen Medical has Emergency Management Policy (AMHSEP10) to prevent and address incidents affecting the environment and human health impacts
• We strive to minimize the use and safe handling and storage of chemical and other dangerous substances as per our procedures AMHSE13 Hazardous Substances SOP and AMHSE12 Dangerous Goods SOP

• Ongoing commitment to our accredited Environmental Management System (EMS) to ISO 14001: 2015
• As part of our Health Safety and Environmental Sustainability Policy we will encourage staff to incorporate an attitude of environmental stewardship throughout the organisation.
• Awareness training of employees on environmental protection and practices
• Rigorous Risk Assessment of our Environmental Risks and provision of appropriate controls
• Raise awareness involving our suppliers in our Supply Chain Assurance Program
• Site Hazard inspections and six-monthly audits which include Environmental risk and their controls
• Reduce, Reuse, Recycle practices across a wide range of supplies
• Aspen Medical is a member of the ACTSmart Business Energy and Water Program

• Aspen Medical has a very high level of Health, Safety and Environmental (HSE) Performance, which is reported monthly to our senior management team, quarterly and annually to all managers including the Senior Management Team, the Corporate HSE Committee and the Board.
o Environmental Incidents (as per the HSE Incident Reporting and Investigation Procedure)
• Environmental Key Performance Indicators are reported annually in our EMHSEPL03 Environmental Sustainability Development Plan 2019 – 20 and reported to the Senior Management Team, the Corporate HSE Committee and the Board comprising:
o Water
o Paper
o Electricity
o Fuel
o Vehicles
o Domestic and International Air Travel
• We publish our environmental commitment and performance annually in our EMHSEPL03 Environmental Sustainability Development Plan 2019 – 20

• Aspen Medical has a policy that outlines its approach to business integrity in two parts: a Code of Ethics and a Code of Conduct. This policy applies to Aspen Medical and all of its subsidiaries and affiliates. Our Code of Ethics outlines the ethical principles of Aspen Medical and its staff, representing the aspirations of the company at the business level. Our Code of Conduct translates these principles into practical guidance that empowers Aspen Medical, its staff, its business partners and their employees to realise these aspirations. Our Business Ethics Policy – the combination of these two codes – has been developed to reinforce our commitment to honest and truthfulness and for the practical purpose of protecting Aspen Medical, its staff and business partners from acts of corruption, modern slavery (slavery, servitude, forced or compulsory labour, bonded labour) or human trafficking and the potential criminal liabilities.
• Australia is a signatory to the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions Countries (the Convention). In accordance with our Anti-Bribery Policy, despite the availability of a facilitation payment defence in Australia, it is the policy of Aspen Medical that facilitation payments will not be made to Foreign Public Officials. Aspen Medical states further, that Aspen Medical will not pay bribes in any circumstances.
• Aspen’s Risk Management Policy is aligned and is conducted in conformance with the ISO 31000: 2009 methodology. Accordingly, Aspen’s Risk Management Plans cover ten areas of business risks which includes Financial Risk that incorporates anti-bribery and corruption.

• Financial policies and procedures for anti-corruption within the company and especially for overseas missions and work
• Aspen Medical's Risk Management Policy is aligned and is conducted in conformance with the ISO 31000: 2009 methodology. Accordingly, Aspen’s Risk Management Plans cover ten areas of business risks which includes Financial Risk that incorporates anti-bribery and corruption.
• Each Aspen Medical Project Manager develops a project specific Risk Register with their team that encompasses all risks relating to the project including anti-corruption
• Position Descriptions for all Financial roles ensures responsibilities are clearly stated for anti-bribery and corruption.
• Annual Financial Auditing by third parties

• Auditing by third parties of our Financial systems and practices
• Reporting Financial Auditing results to the Board
• Anti-bribery and corruption Incident Performance reporting through the Senior Management Team