Specialty Polymers & Chemicals Policy Page
Quality Policy Statement
Specialty Polymers and Chemicals was established in 2006 to provide performance additives and key raw ingredients to the PVC and Rubber industry.
Quality is important to our business because we value our customers as well as all other stakeholders. We strive to provide our customers with products and services which meet and exceed their expectations.
We are committed to continuous improvement and have established a internal Quality Management System which provides a framework for continuously measuring and improving quality performance.
We have the following policies and procedures in place to support us in our quality goals and align with our quality system:
Regular gathering and monitoring of customer feedback
A strict corrective and preventative action procedure
Selection and performance monitoring of the entire supply chain
Continuous training and development of employees
Regular quality audits of Supply chain
Measurable quality objectives which reflect our business aims
Management reviews of audit results, customer feedback and complaints
Our internal procedures are reviewed regularly and are made available to all employees.
Management has ultimate responsibility for Quality, but we ensure all employees understand their responsibilities within their own areas of work.
Modern Slavery
Specialty Polymers and Chemicals (Australian registered Company Number 22125561140) respects ethical labour practices and value and promotes diversity.
We are a fully owned Australian company with head office in Melbourne and warehousing across the nation. Our sales activities also extend to New Zealand , Fiji , Malayisa , Singapore and USA. No other entities are owned by SP&C.
SP&C is a small business with les than 10 people that actively trades Polymers and associated additives to the Australian market place from over 100 different organisations spanning 25 different country locations. Our customer base exceeds over 200 clients within and not limted to the PVC , Polyolefin , Rubber , PU and additive sectors. We also actively deal with over 25 local third party suppliers to provide services within the transport / warehousing / blending and repacking industry.
We actively seek to conduct business with suppliers that align with our core values, morals , ethics including and not limted to those related to Human Rights and Modern slavery. We understand that the conduct of our supply chain can influence our reputation within the communities and landscape we operate in.
Consistent with these principles,SP&C takes a zero-tolerance approach to any form of modern slavery in its operations or supply chains , this stance in embedded in all levels including Leadership , finance , Procurement , sales and HR. Our Zero-tolerance policy applies to any actions , interactions or suggestions that compromise our standards relating to Human Rights , Animal Rights , Child labour and Modern slavery.
SP&C has had no previous breaches relating to Modern slavery or labour standards, we have the necessary processes to investigate , identify and remedy any of this instances. We comply and support the Ethical Trade Initiative and the UN guiding principles on Business and Human rights.
Our “New supplier” questionnaire and initiation procedure in cooperation with ECOVADIS sustainability assessment and The Vinyl Council of Australia “Product Stewardship commitment” screens our supply chain in relation to ethics , labour practices , work place standards and diligence , sustainability , environmental policies and Human and animal welfare. This risk assesment is part of ouir Procurement Policy and Procedure that ensure all Suppliers and service providers adhere or exceed our requirements relating to this matter. In the year 2024 all Suppliers within our model met our requirements and adhered to the expectations. The assesment is carried out on ALL new suppliers and is randomly circulated to existing approved suppliers to ensure standards are maintained. The questionnaire is circulated with our “Modern slavery policy” and “Ethical sourcing policy” and the expectaion is for Management to anser the questions and sign off on the documentation.
As part of the Vinyl Council “Product Stewardship commitment” we also take this annual “Health check” to train and educate our staf on Modern Slavery and Human rights. We enourage a “speak up” culture for reporting any suspected breaches to the initiative which is to be conveyed to Managerial staff.
Measurability ": 100% of our staff are trained in Modern Slavery and HUman rights expectations . 72% of our current Supplier sourcing has reviewed , understood , completed and complied to our review system as tabled above. All those Suppliers thus farv reviewed have received 100% compliance level to our screening. Many also supplied their own Modern slavery / Human Rights commitments that are active within each orgainisation. We are currently working with some “new suppliers” and the remaining existing suppliers to understand their compliance level and seek to maintain our 100% compliance level.
We acknowledge the potential “Risks” upstream especially relating to some base raw materials that are sourced from areas that have “Geographical and Industry” based risk. SP&C actively works with its current Supplier base to help them identify their upstream risk and mitigate any potential issues or uncertainties relating to Human Rights , Modern slavery , Sustainabilty and environmental expectations.
Any investigations that identify a breach are treated with the upmost of concern and are reported to the contact person within the organisation and the local authority responsible for compliance. At this point all business is suspended and SP&C will engage with the supplier on a Corrective Action Plan with a “Written warning of the breach” escalated to senior staff members from the supplier in question. SP&C will utilise their leverage to inititiate change and improvement and those unwilling to cooperate will be removed from the “Approved Supplier Listing”.
This statement, which is intended to meet the requirements of section 54 of the Modern Slavery Act 2015 (UK), describes steps taken by SP&C during the fiscal year ending 31 December 2021 as part of its efforts to decrease the risk of modern slavery taking place in its operations or supply chains as part of our commitment to the Vinyl Council of Australia PSP guidelines https://www.vinyl.org.au/itemlist/search?searchword=modern+slavery&categories=1%2C4.
Continuous educating, auditing and verifying our supply Chain will continue to ensure we make a positive contribution in this area and SP&C has initiated a “supplier self assesment questionnaire” to capture and regulate the information and standards required.
Environmental Policy
Specialty polymers and chemicals is committed to managing environmental impact as an integral part of our operations. In particular, it is our policy to assure the environmental integrity of our processes and facilities at all times. We will do so by adhering to the following principles:
- We will employ management systems and procedures specifically designed to minimize the use of hazardous materials, energy and other natural resources, to minimize the generation of waste, and to enable recycling and reuse of materials.
As a non-manufacturing entity we encourage our suppliers and customers to incorporate these practices.
We will continually seek opportunities to improve our environmental performance by establishing objectives and targets, measuring progress, and reporting our results; including but not limited to energy, water, paper and fuel consumption and vehicle miles traveled.
We work continuously with third party service providers and suppliers to ensure these practices are in place.
We will promote participation and communicate our commitment to responsible environmental management by promoting environmental responsibility among our employees; by providing the necessary training and support to enable them to implement this policy; by informing suppliers of our environmental policy and encouraging them to adopt effective environmental management practices; and by soliciting input from our employees, suppliers, customers and board members in meeting our environmental goals.
As a member of the Vinyl council or Australia product stewardship program we stringently adhere to these practices and regular communication and auditing of our supply chain ensure our continuous improvement.
Procurement & Ethical Sourcing policy
SP&C is an Australian business that supplied a variety of Polymers and Additives to the local Australian Manufacturing , Mining and Building and construction industry. Over a 17 year period we have developed a strong and dedicated supply chain from around the globe. We understand our responsibilities to a vast spread of legal and cultural requirements within the global environment and as such need to continuously monitor and engage with our suppliers to ensure we adhere to strict responsible sourcing guidelines. As part of our “Supplier Approval” process, all suppliers must comply with this policy and we will continuously engage with them to ensure compliance.
Further to the above, the role of the “Procurement & Ethical sourcing policy” is to define standard methods and procedures for the Company to purchase products and services from different vendors and suppliers to ensure continuous uninterrupted supply whilst maintaining the highest level of business integrity. This policy covers all expenses for the company raw materials, logistics services, etc... and in most instances contractual arrangements are in place clearly identifying cost structures / terms and the length of the contract.
Compliance with this policy is mandatory for all employees. Noncompliance with this policy could lead to action including termination of employment. The purchasing department (in this case management) is responsible for maintaining and implementing the processes defined in this policy.
Procurement guideline:
Spend analysis
If new product / service then market research is investigated
Typically a site visit or verification program is initiated with new supplier via “Supplier Audit Checklist” SPC controlled doc or onsite visit at this point the New supplier is requested to complete a questionairre related to Ethical sourching / Adherence to Human Rights expectations and avoidance of Modern Slavery.
Determination of ability to compete is considered with quality and business programs considered that are aligned with our industry commitments
RFI and RFQ sent to approved business partners / supplier.
Negotiation on price, typically terms are fixed at early stages of engagement.
Negotiation requirements vary depending on business sensitivities however always fall within the guidelines of the trade practices act and local laws.
Contracting is finalised in the form of an official PO which is counteracted by a Pro-forma Invoice / PO acknowledgement by supplier.
All PO’s distributed by our office are distributed to all levels of management for review and transparency.
Performance monitoring, based on the terms of the PO - price , quantity , quality , incoterms, payment terms, eta requirements etc…….
We address any performance issues or policy breaches immediately as it’s crucial to keep track of supplier performance regularly and identify areas for improvement. This allows us to identify supplier risks and develop strategies to avoid any supply chain disruptions and non-conformances.
Consideration of the VCA Product stewardship program and ECOVADIS:
Procurement decisions and New Supplier considerations are decided upon in compliance to the Vinyl Council of Australia “Product Stewardship program” and the strict guidelines that determines “Worlds Best Practices” which can be found on https://www.vinyl.org.au/ .
In conjunction with this, SP&C has recently aligned its quality program with ECOVADIS recommendations and procurement guidelines.
As part of our continuous compliance process SP&C will randomly select existing suppliers to participate in specifically designed questionnaires targeting compliance to ethical sourcing policy / Human Rights standards and preventing Modern slavery , this is also addressed in the annual Vinyl Council “Product Stewardship / Upstream Supplier” questionnaire as reflected above.
Governance and Laws applied to Human Rights
· SP&C complies and endorses UN Guiding Principles on Business and Human rights which are reflected in various business policies including our “Modern Slavery” and “Diversity and Equity” policies.
· The UN Guiding Principles on Business and Human Rights are a set of guidelines for States and companies to prevent, address and remedy human rights abuses committed in business operations.
Further details on our commitment can be found on the below link and we encourage suppliers to familiarise themselves with the initiative and imbed the guidelines into their own working procedures and policies:
https://www.ohchr.org/sites/default/files/documents/publications/guidingprinciplesbusinesshr_en.pdf
· SP&C complies with all local and international laws through a defined code of conduct that ensures its supply chain complies or exceeds these legal and moral expectations.
Work Health & Safety
Obligations
Management is firmly committed to a policy enabling all work activities to be carried out safely, and with all possible measures taken to remove (or at least reduce) risks to the health, safety and welfare of workers, contractors, authorised visitors, and anyone else who may be affected by our operations.
We are committed to ensuring we comply with the Work Health and Safety Act 2012, the Work Health and Safety Regulations 2012 and applicable Codes of Practice and Australian Standards as far as possible.
Responsibilities
Management
Will provide and maintain as far as possible:
· a safe working environment
· safe systems of work
· plant and substances in safe condition
· facilities for the welfare of workers
· information, instruction, training and supervision that is reasonably necessary to ensure that each worker is safe from injury and risks to health
· a commitment to consult and co-operate with workers in all matters relating to health and safety in the workplace
· a commitment to continually improve our performance through effective safety management.
Workers
Each worker has an obligation to:
· comply with safe work practices, with the intent of avoiding injury to themselves and others and damage to plant and equipment
· take reasonable care of the health and safety of themselves and others
· wear personal protective equipment and clothing where necessary
· comply with any direction given by management for health and safety
· not misuse or interfere with anything provided for health and safety
· report all accidents and incidents on the job immediately, no matter how trivial
· report all known or observed hazards to their supervisor or manager.
Application of this policy
We seek the co-operation of all workers, customers and other persons. We encourage suggestions for realising our health and safety objectives to create a safe working environment with a zero accident rate.
This policy applies to all business operations and functions, including those situations where workers are required to work off-site.
Sustainability Policy
SP&C are committed to finding ways in which we can reduce the impact of our activities on others and the environment.
These conscious decisions include :
Complying with applicable laws
Commitment to protect human rights.
Promote Biobased products and/or additives produced with biobased renewable energies.
Fostering responsible environmental care within employees and their actions.
Recycling and Reusing where possible.
Avoiding the use of paper and relying on electronic paperless systems.
Reducing energy levels.
Purchasing recycled products ; paper / pallets / packaging etc…
To maintain and improve our commitment, we regularly engage with stakeholders, gather feedback and implement the necessary changes.
CoR POLICY for Transportation services
SP&C is committed to ensuring all relevant business activities are compliant to Federal and Sate Laws and regulations. SP&C is constantly reviewing supply chain processes to ensure they are conducted safely and within the prescribed state and federal requirements. We engage with our internal staff and external service providers to ensure workplaces are free from risks associated with Health and safety. We also periodically audit our service providers to ensure they comply with CoR obligations. In particular we engage with relevant personnel to ensure they have sound understanding of their obligatiosn relating to :
Vehicle Maintenance Speed Fatigue Management Mass and Dimension Loading Protocols
Service providers on request will issue SP&C with relevant CoR awareness training documentation on request as ensure personnel in all facets of the business adhere to the necessary obligations. SP&C will regularly engage with direct personnel to ensure a clear understanding of the process and our obligations. Any incidents will be recorded and communicated to the necessary party to ensure improvements and risks are managed / eliminated.
Diversity and Equity Policy
We embrace and encourage our employees’ differences in age, color, disability, ethnicity, family or marital status, gender identity or expression, language, national origin, physical and mental ability, political affiliation, race, religion, sexual orientation, socio-economic status, veteran status, and other characteristics that make our employees unique. We encourage our supply chain to also embrace diversity within their workplace environment.
SP&C’s diversity initiatives are applicable—but not limited—to our practices and policies on recruitment and selection; compensation and benefits; professional development and training; promotions; transfers; social and recreational programs; layoffs; terminations; and the ongoing development of a work environment built on the premise of gender and diversity equity that encourages and enforces:
Respectful communication and cooperation between all employees.
Teamwork and employee participation, permitting the representation of all groups and employee perspectives.
Work/life balance through flexible work schedules to accommodate employees’ varying needs.
Employer and employee contributions to the communities we serve to promote a greater understanding and respect for the diversity.
All employees of SP&C have a responsibility to treat others with dignity and respect at all times. All employees are expected to exhibit conduct that reflects inclusion during work, at work functions on or off the work site, and at all other company-sponsored and participative events. All employees are also required to attend and complete annual diversity awareness training to enhance their knowledge to fulfill this responsibility.
Working hours
We ensure our employees do not work excessive hours, in accordance with local and national laws, collective agreements and the expectations of the relevant local standards on working time.
Anti Corruption / Bribery policy
Bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for action which is illegal or a breach of trust. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage. It is our policy to conduct all of our business in an honest and ethical manner. Specilaty Polymers and Chemicals takes a zero- tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery. We will uphold all laws relevant (Vic Police act 2013 - sect 253) to countering bribery and corruption in all the jurisdictions in which we operate. However, we remain bound by the laws in Australia in respect of our conduct both at home and abroad. Bribery and corruption are punishable for individuals by up to ten years' imprisonment and a fine. If we are found to have taken part in corruption, we could face an unlimited fine, be excluded from tendering for public contracts and face damage to our reputation. We therefore take our legal responsibilities very seriously.
Gifts and Entertainment : In certain circumstances, the giving and receiving of modest gifts and entertainment is acceptable. Nonetheless, depending on their size, frequency and the direct situation in which they are given, they may constitute bribes and favourable influences and in these instances and with a Dollar value above AUD$100 will be politely declined. SP&C also adheres to external stakeholders policies with regards to this topic.
Conflict Materials , Materials of High concern & Persistent organic Pollutants
Sources of raw materials to our business do not contain any “conflict minerals” (including, but not limited to, tin, tantalum, gold and tungsten) which are sourced directly or indirectly from any country that is subject to restrictions pursuant to conflict mineral laws or equivalent.
No additives in the SPC range of proudcts contain Lead, Mercury, Cadmium, Chromium, Cobalt, PAF’s, Arsenic nor Bisphenol A and we adhere to the VCA Product Stewardship commitments in this area as policed by the Vinyl Council of Australia and Chemistry Australia.
Operation Cleansweep
SP&C is a signatory to “Operation Cleansweep” and the initiative that “All resin pellets should be contained , reclaimed and / or disposed of in accordance with regulatory measures. Information on this initiative can be found at : https://www.opcleansweep.org.au/
Performance evaluation & Training
Employee performance is monitored and continuoulsy evaluated. A yearly review is conducted in December and necessary engagement in undertaken throughout the year. As part of the performance evaluation a training matrix is established as deemed fit with the necessary targets and measureable improvements assigned to a suitable timeline. Job descriptions are controlled through the SP&C BMS and are updated accordingly with input from employees and internal stakeholders.
Cyber security
SP&C has had a long time partnership with TEAMWORK TECHOLOGY a leader in IT support , Software integration and Cloud based storage and security solutions and relies on their experience and services in this area.
Teamwork Technology are currently undergoing accreditation for ISO/IEC 27001 the international standard to manage information security.
Up until that time in conjunstion with TEAMWORK TECHNOLOGY we have implemented strict security measures to protect against cyber-attacks, including regular software updates and monitoring systems. Our employees and contractors receive regular advice on our cybersecurity situation, and we are committed to compliance with all applicable regulations relating to Cybersecurity.
Privacy Policy
SP&C is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information.
We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The NPPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.
A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at https://www.oaic.gov.au/.
What is Personal Information and why do we collect it?
Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect includes names, addresses, email addresses, phone and facsimile numbers.
This Personal Information is obtained in many ways including [interviews, correspondence, by telephone and facsimile, by email, via our website www.yourbusinessname.com.au, from your website, from media and publications, from other publicly available sources, from cookies- delete all that aren’t applicable] and from third parties. We don’t guarantee website links or policy of authorised third parties.
We collect your Personal Information for the primary purpose of providing our services to you, providing information to our clients and marketing. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing.
When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.
Sensitive Information
Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.
Sensitive information will be used by us only:
• For the primary purpose for which it was obtained
• For a secondary purpose that is directly related to the primary purpose
• With your consent; or where required or authorised by law.
Third Parties
Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.
Disclosure of Personal Information
Your Personal Information may be disclosed in a number of circumstances including the following:
• In rare circumstances, to Third parties where you consent to the use or disclosure; and
• Where required or authorised by law.
Security of Personal Information
Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorized access, modification or disclosure.
When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 7 years.
Access to your Personal Information
You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.
SP&C will not charge any fee for your access request, but may charge an administrative fee for providing a copy of your Personal Information.
In order to protect your Personal Information we may require identification from you before releasing the requested information.
Maintaining the Quality of your Personal Information
It is an important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.
Policy Updates
This Policy may change from time to time and is available on our website.
Privacy Policy Complaints and Enquiries
If you have any queries or complaints about our Privacy Policy please contact us on our “contact us” information page.
Signature
John Candela John Mallia
Director Director