Occupational Health Saftey Management Plan (OHMSP) - NZ

Occupational Health &
Safety Management
Plan (OHSMP)
New Zealand
Table of contents
Table of contents ........................................................................................................... 1

1. Introduction............................................................................................................ 2
1.1. Objective ......................................................................................................... 2
1.2. Definitions ........................................................................................................ 2
2. Policies .................................................................................................................. 3
2.1. Health, safety & wellbeing policy ......................................................................... 3
Procedures ................................................................................................................... 6
1. Induction and training procedure ............................................................................ 6
2. Accident/incident reporting and investigation procedure ............................................ 6
3. Emergency response procedure............................................................................ 10
4. First aid procedure ............................................................................................... 9
5. Hazard identification and control procedure ........................................................... 10
6. Working at heights procedure .............................................................................. 12
2.2. Equal Employment Opportunity (EEO) policy ....................................................... 13
Procedures ................................................................................................................. 17
1. Equal Employment Opportunity (EEO) – Reporting and investigating a complaint
procedure ................................................................................................................ 17
2.3. Drugs and alcohol policy .................................................................................. 21
2.4. Social media policy .......................................................................................... 23
3. Breach of policy and procedure ............................................................................... 24
4. Communication and consultation ............................................................................. 25
5. OHSMP policy acceptance ....................................................................................... 27
© Entity Solutions Pty Ltd OHSMP – New Zealand Page 1 of 28

Updated 29.09.2016
1. Introduction
This Occupational Health & Safety Management Plan (OHSMP) outlines the policies, processes
and procedures used to manage Occupational Health and Safety (OHS) of Entity Solutions’
(ES) workforce, which includes Independent Professionals (IPros), contractors, and volunteers.
All workers are subject to the policies and procedures outlined in this OHSMP. To acknowledge
acceptance all workers must sign the OHSMP Policy Acceptance located at the end of this
document or acknowledge acceptance on Entity Online to show that they accept the policies
and procedures prior to commencing work.
All policies and procedures in this document are to be used in conjunction with the
Client sites policies and procedures.
1.1. Objective
To encourage workers to take responsibility for their own safety and that of their colleagues,
by positively reinforcing the basic fundamentals of safe work practices.
1.2. Definitions
Independent Professional Term used to describe white collar contractors.
(IPro)
Contractor A person or an incorporated entity that operates independently

and is sub contracted by ES to provide services to a client.
Visitor A visitor is not an employee, contractor or IPro but is visiting ES

offices. Visitors are generally not inducted, are required to wear
a Visitor’s badge, sign into a Vistor’s log and should be escorted
by an employee while they are onsite.
Client ES’ client or ES client’s client to whom the services are provided
by the IPro.
Worker Includes Independent Professionals (IPro) and contractors.

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2. Policies
2.1. Health, safety & wellbeing policy
2.1.1. Purpose
To outline Entity Solutions’ (ES) policy relating to Occupational Health and Safety (OHS) and
return to work.
2.1.2. Objective
To protect the health, safety and wellbeing of all workers and third parties.
2.1.3. Occupational Health and Safety (OHS)
a) ES Commitment Statement
ES will provide a framework to support and monitor the health, safety and wellbeing of all
workers, which includes:
 ensuring an OHS induction is part of the onboarding process for new workers; assess office
environments and/or well-maintained home office space
 the completion of the Workplace Safety and Induction form;
 taking all reasonable steps to identify, assess and control any known or potential risks to
health and safety;
 conducting an investigation at the Client site or at ES’ premises to remedy the problem
and prevent a recurrence;
 ensuring workers know how to report hazards or incidents (including awareness of the
Incident Report Form);
 ensuring all workers working from home, complete a Workplace Induction Safety
Inspection Form, where required; and
 ensuring compliance with health and safety legislative requirements and relevant
standards.
b) Workers Responsibilities
All workers, whatever their role, have a primary responsibility to ensure that the work they
undertake or supervise is carried out in a safe manner. This includes being proactive in
awareness, promotion and prevention. No task is so important that a person’s safety is put at
risk.
To ensure this occurs, all workers must:
i. report OHS issues immediately to their relevant Entity Solutions Representative

ii. comply with all workplace policies and procedures in relation to health and safety,
whilst on ES premises and on Client sites
iii. contribute to, and be involved in, ongoing management of health and safety.\

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2.1.4. Safety rules
All workers have a shared responsibility to ensure the health, safety and wellbeing of
themselves, colleagues and third parties. All workers must follow all relevant policies and
procedures of ES and the Client.
All workers must:
i. report to the relevant site representative before commencing work;

ii. carry out activities in a manner that does not compromise the health, safety and
wellbeing of every person affected or likely to be affected by such activities;
iii. not undertake manual handling tasks without first assessing the load. Can the load be
machine lifted? Is a team lift required?;
iv. obey all signs. If a meaning is not understood, ASK!;
v. wear appropriate clothing at all times; and
vi. always drive in a safe and courteous manner, obey road rules and maintain vehicles in
a safe and serviceable condition. Workers are personally responsible for any breaches
of traffic laws, parking restrictions and any fines or penalties that are incurred.
2.1.5. OHS forms
a) Workplace Induction Safety Inspection form (WISI form)
The WISI form is provided to all workers before commencing work. It is used to highlight,
reduce and/or eliminate workplace dangers, as far as reasonably practicable and for the
assessment of office environments and/or well-maintained home office space. It is not to be
used for other workplace environments.
b) Client Site Inspection form (CSI form)
The CSI Form is provided to a Client to ascertain an understanding of the sites occupational,
health, safety and induction policies and procedures. It is used to facilitate communication
between ES and the Client regarding any potential health and safety issues.
2.1.6. Workers’ compensation (WC) and Return to Work (RTW)
*Given the nature of the relationship between Entity Solutions, IPro or contractor, Entity
Solutions will not undertake sourcing alternative duties and/or assignment, should the current
contract expire. Entity Solutions will work with the Client site to determine if alternative duties
are available at the workplace however will not undertake sourcing alternative duties if they
are not available.
Workers need to determine if they are covered under the workers compensation scheme.
a) The role of the injured worker
The role of the injured worker is to:
 ask their doctor to complete a workplace capabilities check, or to specify capabilities for
suitable duties on a medical certificate
 maintain communication with their Entity Solutions’ representative and Client site about
relevant issues relating to their injury

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 provide all parties with all relevant forms, including medical certificate, which is to be filled
in correctly and submitted on the due date.
b) The role of the Return to Work (RTW) Coordinator
The Return to Work (RTW) Coordinator is a person who has satisfactorily completed a
workplace rehabilitation course approved by the respective state OHS Regulator (WorkCover
Authority). This person is the link between the injured worker, treating doctor, Entity
Solutions’ representative, client site management, state OHS Regulator (WorkCover Authority),
rehabilitation providers and any other relevant parties.
The role of the RTW Coordinator is to:
 ensure that an efficient system exists for immediate reporting of injured workers
 coordinate the return to work of injured workers and work with the Client site to take all
reasonable practicable steps to prevent a repeat of the injury or illness
 develop a RTW Plan (where possible and practical) in conjunction with the worker’s treating
practitioner/s, Occupation Rehabilitation Provider (if required) and the Client site
 work with the Client site (where possible and practical) to provide suitable meaningful
work, including modified or alternate duties at the earliest opportunity
 maintain communication with all parties involved in the process including Client site
managers and HR teams related to the injured workers RTW plan
 monitor the injured worker’s progress in relation to suitable duties and suggest
adjustments if/where applicable
 offer support (where appropriate) to the injured worker.
*A Return to Work (RTW) plan is specially selected duties at the worker’s Client site to provide
a means of a monitored and gradual return to normal duties.
The program would be:
 matched to the capabilities of the worker;

 time limited and regularly updated according to the worker’s level of recovery and treating
doctor’s advice; and
 as closely associated with the worker’s normal role as deemed possible.
If required, a copy of the plan will be provided to the ES insurer and Client site for worker’s
compensation and RTW purposes.
2.1.7. Support and Counselling
Workers are encouraged to seek assistance with work and/or personal issues from sources,
such as their direct manager, Client representative or Entity Solutions’ representative.
If work related help is not available or appropriate, workers should source external assistance
through family, friends, professional counselling or help lines.
2.1.8. Emergency Management
In the event of a natural disaster, epidemic, pandemic, flood, fire, or earthquake, the health
and safety of all workers will be ES’ first priority. ES will take appropriate steps to ensure
workers are managed appropriately during these times by working with the Client site’s

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processes, policies and plans. This may mean the partial or full closure of a floor or building,
temporary or permanent relocation, or working from home options. Workers are reminded to
adhere to the Client site’s emergency policies and procedures.
Each plan of action to an emergency event will be determined on a case by case basis.
Procedures
1. Induction and training procedure

1.1. Purpose
1.2. To ensure that workers are provided with an appropriate site induction.
Workers shall have a current ES specific induction if they are working in an ES office. Workers
must speak to their Client representative to insure that they receive a comprehensive
induction, which includes the checks listed on the Workplace Induction & Safety Inspection
(WISI) Form. Workers are required to fill out a WISI Form within 7 days of commencing work.
Some of the areas that should be discussed include:
 Duration and breaks

 Environment and factors
 Scope of work
 Emergency communications
 Equipment
 Access
 Emergency procedures
 Smoking arrangements
 Hazards present
 Site OHS policies and procedures
Workers are expected to be competent to perform the tasks for which they are engaged. ES
has an expectation that any given worker holds appropriate qualifications and nationally
accredited competencies.
ES reserves the right to request and review all workers training records and/or qualifications.
2. Accident/incident reporting and investigation procedure

2.1. Purpose
To provide guidance on to the process of reporting and investigating workplace incidents and
accidents.

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2.2. Definitions
Accident An unplanned event that results in personal illness or injury requiring

medical attention.
Incident An unplanned event, which has the potential to cause serious injury,
danger to health or damage to property, also known as a ‘near miss.’
Serious Accident A fatality or serious injury or illness such as:
 A person requiring medical treatment within 48 hours of exposure to

a substance
 A person requiring immediate treatment as an in-patient in a
hospital
 A person requiring immediate medical treatment for:
a. an amputation
b. serious head injury
c. serious eye injury
d. the separation of his or her skin from underlying tissue e.g.
de-gloving
e. electric shock
f. a spinal injury
g. the loss of a bodily function or
h. serious lacerations
i. serious burns
j. a loss of consciousness
Serious accidents are to be reported to the Ministry of Business, Innovation and Employment,
Health and Safety group after becoming aware of the incident.
2.3. Responsibilities
a) Return to Work Coordinator
 Ensure all legislative incident reporting requirements are met.

 Co-operate with Client site and other external bodies where incident investigation is
required.
 Document/process/report workplace accidents or incidents.
b) The Entity Solutions Representative
 Ensure accidents and incidents are reported to the Return to Work Coordinator by
emailing OHSandRTW@entitysolutions.com.au.
 Assist workers with the completion of an Incident Report form.
 Communicate incident reporting procedure requirements to Clients and workers.
 Implementations/controls required preventing re-occurrence of the event.
c) Workers
 Report accidents or incidents within 24 hours to the Client site manager and to the
Entity Solutions Representative.

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 Complete and sign an Incident Report form subsequent to a near miss or incident and
forward to the relevant Entity Solutions Representative.
2.4. Reporting of accidents and incidents
Accidents and incidents (including near misses) must be reported within 24 hours of the event
occurring to the Client site manager, the Entity Solutions Representative and RTW Coordinator,
which includes filling in an Incident Report Form.
Workplace accidents and incidents that need to be reported include:
1 An accident that results in a person suffering a work injury

2 An incident that has the potential to result in a person suffering a work injury
3 A work related illness
4 A dangerous event.
The following diagrams illustrate the reporting procedure for workers and the RTW coordinator:
a) Worker
INFORM COMPLETE
Incident or near Incident
Worker
miss Report form
INFORM
Seek medical Client Site ES RTW
assistance Manager Represenative Coordinator
b) RTW Coordinator
WHERE WHERE Incent Report

Controls to
REQUIRED Incident REQUIRED and
RTW Incident ensure they
Investigation Investigation
Coordinator Report form have been Form keep for
COMPLETE Form IMPLEMENT
ASSESS implemented 7 years
2.5. Reporting of dangerous events, serious injuries or fatalities
In the event that a serious injury, dangerous event or fatality occurs at a Client site or an ES
office, involving a worker or a member of the public, the following steps will be undertaken:

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Workplace accident, INFORM COMPLETE
unsafe situation and Client Site ES Incident
Worker incidence of serious Manager Represenative Report form
harm
RTW
Coordinator
Seek medical CONTACT

assistance
Client Site
INFORM
in 7 days
WorkSafe
New Zealand
3. Emergency response procedure

3.1. Purpose
To provide guidance for an emergency response within ES offices and Client sites.
This procedure is to be used in consultation with the Client sites emergency response
procedure.
3.2. Scope
The site emergency response procedure is to be explained to all workers during their site
induction. This includes emergency evacuation points and meeting point. The Workplace
Induction Safety Inspection (WISI) form consists of required fields where this requirement is to
be marked off. If this is not explained, the worker should contact their Entity Solutions
Representative to advise them.
The nominated emergency telephone number for Police, Fire and Ambulance throughout New
Zealand is 111. Some Client sites will have their own nominated emergency contact details and
workers should make themselves familiar with these.
3.3. Availability of medical expertise
There should be a qualified first aid person at every site. If a worker at a Client site is not able
to identify such a person, they should contact their Client representative and/or their Entity
Solutions Representative.
4. First aid procedure

4.1. Purpose
To provide guidance in regards to providing first aid to ES workers.

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Whilst ES is committed to proving a safe working environment, incidents can still occur. If a
person is sick or injured at a work site, all workers at that site are encouraged to assist within
their capabilities, by providing emergency first aid and informing emergency services.
4.2. First aid equipment
 All first aid items must be labelled accurately and clearly; the container must
accommodate all items comfortably and the first aid kit must be easily identifiable.
 Any items used must be replaced as soon as possible; the kit will contain a contents list
to ensure all items are present.
 First aid kits will be inspected every 6 months and a register of these inspections will be
maintained (maybe contracted out).
 If kits are stored in vehicles, they must be in a position that can be accessed easily and
secured when travelling.
4.3. First aiders
There should always be at least one qualified first aider per client site at all times. This person
must hold a current first aid certificate from a regulatory approved first aid course. . During
the induction process, the identification of the first aider/s must be undertaken.
4.4. Emergency medical access
All workers should know how to contact emergency services. The national emergency
telephone number is, 111 which may be used across New Zealand to contact emergency
services.
4.5. Record keeping
Any treatment provided to a sick and or injured worker must be recorded. All first aid kits
contain note books and record sheets to assist with this.
Information such as:
 person’s name
 date and time of treatment
 treatment provided
 patient condition at the time of assessment
 ongoing condition and observation of the patient’s condition
 date, time, name and details of a handover to a medical practitioner, emergency
respondent or another first aid provider
 any medications, drugs or items found on the injured worker.
5. Hazard identification and control procedure

5.1. Purpose
To provide guidance in regards to hazard identification and controls for workers.
5.2. Identifying hazards and risks
To ensure activities are conducted in a safe manner, the following is essential:

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 Hazard and risk identification.
 Control and mitigation processes (including processes to reassess hazards and risks
whenever changes occur to plant and equipment, personnel or the working
environment).
5.3. Workplace hazards (where practical) shall be identified by means of
 Audits and inspections

 Client Site Information (CSI) Form
 Review of the Incident Investigation Report
 Incident Investigation form
 Issues and concerns raised by workers identified
 Review of the Workplace Induction Safety Inspection (WISI) form.
5.4. Client Site and Information (CSI) form
As workers are working across a number of different sites, Clients are required to identify what
each site utilises to identify, assess and control hazards.
To ensure that all potential hazards or risks are identified and understood by workers, a Client
Site Inspection (CSI) form shall be completed prior to the worker commencing work in a new
area. The form may be used to list each step of the task, to assess and identify all hazards and
to apply an appropriate control for each hazard.
There is potential for different hazards to be present in a different work area or location. Due
to this reason, revisiting the CSI form will be actively encouraged.
Hazards and risks to be considered on a Client site include but are not limited to:
 High voltage power lines

 Live electricity
 Manual handling
 Plant and equipment
 Access & Egress
 Hazardous substances – Paints, Asbestos, lead, fuels etc.
 Cranes, hoists & rigging
 Driving
 Dust
 Falling Objects
 Fatigue
 Fire and explosion
 Smoking
 Tools and Plant
 Weather i.e. Heat, Cold, Wind, UV and rain
 Hoses and pressure equipment
 Painting
 Slip, trips and falls
 Vibration
 Gas Cylinders
 Noise
 Scaffolding
 Working at heights

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 Traffic
 Overhead hazards
 Underground services
 Lack of sufficient light (e.g. overcast days)
 Areas where mobility me be restrictive (under buildings, confined spaces)
 Ground Conditions
 Public
 Livestock and wildlife
ES will work with the Client site to ensure control measures (where possible) are implemented
to ensure the risk is eliminated or reduced to an acceptable level. To ensure activities are
conducted in a safe manner the following is essential:
 Hazard and risk identification.

 Control and mitigation processes (including processes to reassess hazards and risks
whenever changes occur to plant and equipment, personnel or the working environment).
 Engineering.
 Solutions such as barriers or guards.
 Limiting exposure, e.g. job rotation between noisy and quiet areas, rotation of tasks or
provision of specific training on the hazards.
 Personal Protective Equipment (PPE).
 Use of signage to warn personnel of hazards which have not been completely eliminated.
5.5. Workplace Safety Inspection (WISI) form
Workers are asked to complete a Workplace Safety Induction (WISI) form to determine if they
have undergone a Client specific OHS induction and have been provided with adequate
workplace facilities and equipment on the commencement of work. The form is also used to
ensure hazards have been identified and (if applicable) controls are implemented.
6. Working at heights procedure

6.1. Purpose
To provide guidance in regards to working at heights for workers.
6.2. Hazards associated with working at heights
Working at heights can represent the following hazards:
 Slips and trips

 Falls from heights
 Equipment falling from heights
 Microwaves
 Live electricity
 Tools and equipment used while working at heights
 Cuts and abrasions
 Suspension trauma

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 Weather
 Waste
 Poor ergonomics
 Poor hygiene
 Burns (Friction, radiation)
 Dust
6.3. Controls
Controls to reduce the risks associated with working at heights may include:
 Correct Personal Protective Equipment (PPE), including safety harness, ropes or clothing
 Signage
 Plans and procedures
 Securing of equipment
 Barricading
 Observer
 Qualified and trained personnel
 Equipment tested, inspected and appropriate for task
 Excellent housekeeping
 Excellent communication
 Documented rescue plan that has been rehearse
6.4. Assessment
Any work involving a risk of a fall or an injury will be risk assessed. Appropriate controls (with
consultation of the Client site) will be put in place to prevent a fall or to prevent an injury upon
a fall occurring.
An assessment should be conducted and documented by the worker undertaking the work and
the Client site. It should include all hazards identified and how each hazard will be controlled.
6.5. Forms and templates
If a hazard exists, workers should request a working at heights assessment and/or an Incident
Report Form from each Client site.
Some Client sites will require workers working at heights to work under a permit system.
2.2. Equal Employment Opportunity (EEO) policy

2.2.1. Purpose
To outline Entity Solutions’ (ES) policy relating to equal employment opportunity,

discrimination, harassment and bullying.
2.2.2. Objective
To ensure that there is a shared understanding amongst all workers of ES’ expectations in
regards to acceptable and appropriate behaviour in the workplace.

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2.2.3. EEO
ES values the contribution of all workers and is committed to ensuring the workplace is free
from discrimination and harassment. Discrimination, harassment, sexual harassment and
bullying is not only unacceptable, it is unlawful.
Outlined within this policy is an internal dispute resolution process to assist workers to raise
issues of concern. Appropriate disciplinary action may be taken against anyone found to have
breached this policy.
No worker will be penalised or disadvantaged as a result of raising legitimate concerns or

disputes relating to discrimination, harassment or bullying.
*Please note that the following definitions should be used as a guide only and the relevant
state legislation should be consulted.
2.2.4. Discrimination
The prohibited grounds of discrimination are set out at s 21 of the Human Rights Act 1993 and
at s105 of the Employment Relations Act 2000.
Unlawful discrimination can occur whether it is direct or indirect, intended or unintended.
a) Direct discrimination
Direct discrimination will occur if a person treats, or proposes to treat, another person
differently and unfavourably on the basis of a prohibited ground.
b) Indirect discrimination
Indirect discrimination will occur where any conduct, practice, requirement, or condition
that is not direct discrimination has the effect of treating a person or group of persons
differently on the basis of one of the protected grounds of discrimination.
What are the protected attributes of discrimination?
The particular grounds of prohibited discrimination under the Human Rights Act 1993 and
the Employment Relations Act 1993 can be summarised as follows:
 Race, colour, descent or national or ethnic origin

 Sex (including matters relating to pregnancy or potential pregnancy)
 Marital status
 Family status
 Disability
 Age
 Political opinion
 Religion
 Religious belief
 Sexual orientation or
 Employment status
The following are also unlawful in terms of the Human Rights Act 1993:

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 Inciting racial disharmony
 Sexual harassment and
 Racial harassment
2.2.5. Harassment
Harassment occurs when someone is made to feel intimidated, insulted or humiliated because
of their race, colour, national or ethnic origin, sex, disability, sexual preference, or some other
prohibited ground.
Harassment can include behaviour such as:
 Telling insulting jokes about particular racial groups.

 Sending explicit or sexually suggestive emails.
 Displaying offensive or pornographic posters or screen savers.
 Making derogatory comments or taunts about someone’s race or religion.
 Asking intrusive questions about someone’s personal life, including their sex life.
a) The nature of harassment
Harassing behaviour can range from serious to less serious levels. However one-off
incidents can still constitute harassment. Also, where continued, such behaviour can
undermine the standard of conduct within a work area, which may erode the wellbeing of
the individual or group being targeted and lead to lower overall worker performance.
b) Hostile working environment
A hostile working environment occurs when the workplace environment or culture is

sexually or racially ‘hostile’. Examples of a potentially hostile working environment are
where pornographic materials are displayed and where crude conversations, innuendo or
offensive jokes are part of the accepted culture. A person has the right to complain about
the effects of a sexually or racially hostile working environment, even if the conduct in
question was not specifically targeted at them.
c) What is not harassment?
Workplace harassment or discrimination must not be confused with legitimate comment

and advice (constructive feedback) from managers and supervisors on work performance
or work related behaviour of an individual or group.
Managers at ES or Client sites should manage these processes with sensitivity, but they
should not avoid their responsibility to provide full and frank feedback.
2.2.6. Sexual harassment
Sexual harassment may be defined as uninvited or unwelcome behaviour that may involve but
not be limited to verbal, written or physical insult against another worker. The effect of such
harassment may result in the individual being offended, humiliated or intimidated making the
workplace both uncomfortable and unpleasant.

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Sexual harassment may cover a range of unwelcome, unsolicited and non-reciprocal
behaviour, which constitutes deliberate or unintentional verbal or physical conduct of a sexual
nature. Such behaviour may include but not be limited to the following actions:
 Comments, jokes or gestures

 Telephone calls, text messages, letters, e-mail messages, social media.
 Sex-based insults, taunts teasing or name calling
 Displays of offensive material such as posters, books or pictures, including screen
savers on computer monitors
 Leering, patting, touching or unnecessary familiarity
 Unwelcome comments or questions of a personal nature
 Unwelcome sexual propositions
Everyone has a right to work in an environment that is free from sexual harassment. Sexual
harassment and other varieties of unlawful harassment may also constitute criminal behaviour
and may be forwarded on to the appropriate authorities. Workers may also wish to make
enquiries/formal complaints with the appropriate external authorities.
What is not sexual harassment?
Sexual harassment is not behaviour which is based on mutual attraction, friendship and
respect. If the interaction is consensual, welcome and reciprocated, it is not sexual
harassment.
2.2.7. Workplace bullying
Workplace bullying is the repeated less favourable treatment of a person by another or others
in the workplace, which may be considered unreasonable and inappropriate workplace practice.
It includes behaviour that intimidates, offends, degrades or humiliates a worker by another
worker.
Bullying behaviour can range from very obvious verbal or physical assault to very subtle
psychological abuse.
a) Obvious behaviour may include:
 Physical or verbal abuse

 Yelling, screaming or offensive language
 Excluding or isolating workers
 Psychological harassment
 Intimidation
 Assigning meaningless tasks unrelated to the job
 Giving workers jobs impossible to complete successfully
 Deliberately changing work rosters to inconvenience particular workers
 Undermining work performance by deliberately withholding information vital for
effective work performance
b) Subtle behaviour may include:
 Unjustified criticism or complaints

 Excessive scrutiny at work
 Excluding or isolating workers

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 Psychological harassment
 Intimidation
 Assigning meaningless tasks unrelated to the job
 Giving workers jobs impossible to complete successfully
 Deliberately changed work rosters to inconvenience workers
 Undermining work performance by deliberately withholding information vital for
effective work performance
 Spreading rumours or innuendo about someone
What is not bullying?
Reasonable management actions carried out in a reasonable manner is not bullying. Examples
may include:
 Setting performance goals, standards and deadlines

 Allocating work to a worker
 Rostering and allocating working hours
 Transferring a worker
 Deciding not to select a worker for promotion
 Informing a worker about unsatisfactory work performance
 Informing a worker about inappropriate behaviour
 Implementing organisational changes
 Performance management processes
 Constructive feedback
 Consultation concerning changes in the workplace
The key to the above is that these actions are carried out in a fair and equal way.
Procedures
1. Equal Employment Opportunity (EEO) – Reporting and
investigating a complaint procedure
1.1. Purpose
To provide a framework to report and investigate bullying, discrimination and harassment

complaints.
1.2. Guidelines
 All complaints will be taken seriously and will be taken on their merits and facts
 All complaints will be acknowledged within 24 hours in writing by an ES Representative
 Complaints will be dealt with quickly, courteously, fairly and within established timelines
 All relevant parties will be advised of the process and kept informed of progress or
delays
 Support will be available to all parties. ES will work with Client sites’ HR, managers,
policies and procedures during the complaints process
 Impartiality is critical
 The process will ensure confidentiality is maintained by all parties

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1.3. Informal procedure
Make a clear and polite request for the behaviour to stop. This request can be made by the
person affected or their manager. Anyone requested to act on behalf of the person affected
should adopt a confidential, non-confrontational approach with a view to resolve the issue.
It is during this stage that mediation may be suggested. Mediation is where a neutral and
independent person may assist resolution through a discussion of the issues. The person
will usually be either internal Client HR or if it is not appropriate for an internal person to
be involved, ES People & Culture may be utilised. The mediator should be approved by
both parties and independent of the complaint. The discussion should focus on agreeing to
actions that will resolve the problem.
1.4. Formal procedure
Commencement of the formal procedure should only take place if the issue could not be
resolved using the informal procedure.
Any person making a complaint should not be subject to victimisation because they raise or
are associated with a complaint.
Step 1: Lodge a formal compliant
Complete the Complaint form (available from People & Culture or your Entity Solutions
Representative) and forward it to the OHS Team – ohsandrtw@entitysolutions.com.au
All workers should consider the “who, when, what, where” when completing a Complaint
form:
 Who is the complaint about?

 When did it happen?
 What actually happened? (stick to the facts and try to avoid emotional content)
 Where did it happen?
All complaints are taken seriously and will be acknowledged within 24 hours in writing.
Step 2: Investigation
Following the receipt of a complaint, a nominated Investigator will investigate the matter
and make recommendations to those involved, to determine a resolution.
The investigation may involve some or all of the following:
 Providing a copy of the Complaint form or substance of the complaint to the person(s)
who is/are the subject of the complaint
 Requesting the person(s) to provide a formal written response. Formal interview(s) or
obtaining statements from people who can help to ascertain the facts
 Obtaining relevant and necessary documentation
 Identifying an option(s) for resolution of the complaint(s)
Step 3: Investigation outcomes

The investigation should be completed within ten (10) business days. This may be
extended should further details and processes be required (all parties involved will be
notified in writing). At the conclusion of the investigation, the investigator will write to all

Updated 29.09.2016
parties involved to identify the findings of the investigation and make recommendations to
resolve the matter. The recommendations will be in line with the seriousness of the
complaint/s raised.
Either party is able to appeal the decision and recommendation(s), conditional on new
evidence being presented. They cannot appeal simply because they are not happy or do not
agree with the outcome(s).
The investigator may make recommendations to resolve the issue(s), which may include:
 Gain commitment to cease the behaviour.

 Conduct training – individual, department, company.
 Provide coaching, counselling support and/or mentoring.
 Review the workplace policy.
 Mediation (where both parties agree to mediation and to the appointed mediator).
 If appropriate/practical, move the offender away from the affected person.
 Implement disciplinary action, which may include a warning letter, demotion and/or
dismissal.
 Seek an apology.
 Regular monitoring of behaviour.
 Involvement by an external body or party eg: Police.
Malicious or vexations complaints
Complaints that are found to be frivolous, vexatious or malicious will be dealt with accordingly
and may be subject to disciplinary action.
Step 4: Monitoring and evaluation
Following the outcome(s), all parties will continue to monitor the environment for an agreed
period of time to ensure that it has been properly addressed.
1.5. Further information
For further advice, you may contact the following:

1. People & Culture - humanresources@entitysolutions.com.au
2. OHS Team - OHSandRTW@entitysolutions.com.au
3. Entity Solutions Representative

Updated 29.09.2016
1.6. Steps in the complaint process

Updated 29.09.2016
2.3. Drugs and alcohol policy
2.3.1. Purpose
To outline Entity Solutions’ (ES) expectations on the use and consumption of drugs and
alcohol.
*When making recommendations on the use and distribution of drugs, this policy refers to
illicit drugs or prescription medication. It excludes the use and distribution of over-the-counter
medication such as paracetamol or ibuprofen for mild pain relief.
2.3.2. Objective
To reduce the likelihood of injury, damage and/or negative effects resulting from alcohol
and/or drug use and/or abuse in the work environment.
2.3.3. Responsibilities
All workers have a shared responsibility for maintaining a healthy and safe working
environment, which includes the health and safety of themselves, colleagues, Clients,
customers and visitors.
The inappropriate, irresponsible and unlawful use of drugs and/or alcohol can not only result
in a criminal offence but can adversely affect company performance, health, safety and
wellbeing of a person, damage to property, and/or affect the rights and enjoyment of others.
ES will contribute to a healthy and safe working environment by:
 Providing a responsible approach towards the serving and consumption of alcohol

 Promoting an inclusive environment for all who choose not to consume alcohol
 Promoting awareness of personal health, safety and wellbeing (where and when required)
via online communication, group information sessions and relevant leaflets, brochures and
posters
No worker is to possess, use, sell, or distribute drugs* whilst engaged in Client or ES

business.
a) Responsibilities of workers
 Must not be adversely affected by drugs and/or alcohol whilst engaged in ES or

Client business or work. This includes attendance at all internal and external ES,
Client and customer activities and events.
 Are required to always behave professionally whilst representing ES or the Client.
This includes being mindful of material (comments and pictures) posted on social
network sites such as Facebook and Twitter etc.
 Must immediately report any safety concerns about another worker or visitor being
possibly affected by drugs and/or alcohol.
 Must respect and adhere to Client site zero alcohol or random drug and alcohol
testing as part of their role or policy and procedures.
It is not a workers responsibility to counsel workers or visitors that appear to be misusing

drugs* and/or alcohol. If you are concerned about a person’s wellbeing, direct the person to

Updated 29.09.2016
their manager or supervisor.
b) Responsibilities of managers/event coordinators
If alcohol is to be served at a company event, a suitable person must be nominated as the

Event Coordinator to responsibly coordinate the serving of alcohol. Event Coordinators are
responsible for:
 ensuring the serving of alcohol is conducted safely and must do everything that is
reasonable and practicable to reduce or eliminate potential risks and;
 ensuring the activity caters for workers not consuming alcohol.
2.3.4. Suspension
Client site management has the authority to suspend workers they believe to be adversely
affected by drugs and/or alcohol. Suspension can occur with or without pay and for an
indefinite period of time. Reinstatement will only occur once the manager, Client site and ES is
convinced the offending worker is capable of working effectively and is no longer under the
influence of the offending substance.
2.3.5. Attending ES, Client, customer activities and events
The attendance at ES, Client, customer activities and events is an opportunity to network and
establish or maintain good working relationships. Christmas activities and events is an
opportunity to celebrate the year’s achievements (company, department and personal), and
therefore should be relaxed, jovial and respectful.
However, workers are asked to display a duty of care where colleagues are intoxicated and
may cause harm to themselves and/or others, by discouraging further consumption and if
possible assisting them in getting home safety e.g. calling a taxi.
2.3.6. Further information
Workers are encouraged to seek assistance should they require support in dealing with a drug
and/or alcohol problem. All workers are encouraged to speak to a counsellor, family, friends
or their managers or supervisor.

Updated 29.09.2016
2.4. Social media policy
2.4.1. Purpose
To outline Entity Solutions’ (ES) policy in relation to social media in and outside of the
workplace.
2.4.2. Objective
To provide clarity to workers on how to conduct themselves on social media both at work and
outside of work hours.
2.4.3. Social media
Online collaboration and social networking platforms are changing the way we fundamentally
work and engage with each other, customers and partners.
ES continues to explore how online discourse through social networking can:
 create and develop brand awareness – i.e.: who we are, what we do, how we work, and
why people should use ES services
 generate exposure and;
 promote customers as advocates of our brand.
The lines between public and private, personal and professional, can often be blurred in online
social networks. Therefore, it is in the best interests of all workers to be aware of ES’
expectations when engaging in online social networking.
By identifying yourself as an ES IPro or contractor within a social network, you are possibly
connecting with colleagues, customers, and ES’ partners and clients. Be thoughtful of how you
present yourself and ensure that content is consistent with the work and professional
standards expected at ES.
2.4.4. Guidelines
The following guidelines are in reference to online social network channels, such as Facebook,
Twitter, YouTube, Blogs, LinkedIn, Yammer, Pintrest, Instagram and so on:
1. You are personally responsible for the content you publish online, whether in a blog,
social networking site or any other form of user-generated media. Be mindful that what
you publish will be in the public domain quickly and indefinitely - protect your privacy
and take care to understand terms and conditions of the site.
2. Identify yourself – name and when relevant, your role within the company when
discussing company related matters.
3. Be mindful of what you publish on your own private networking sites. If you are unsure
whether content is suitable or could possibly tarnish ES or the Client’s brand, do not
circulate it.
4. Engagement in social media using ES or Clients’ facilities during office hours must be
for work related purposes only. Facebook catch up with friends should only be

Updated 29.09.2016
conducted during your lunch break or after office hours..
5. Respect privacy, copyright, fair use and financial disclosure laws.
6. Do not provide ES, Clients or another party’s confidential and/or proprietary information
and never publicly discuss ES’ business performance or other sensitive matters.
7. Do not cite or reference customers, partners or suppliers without their approval. When
you do make a reference, link back to the source. Do not publish anything that might
embarrass or disparage a customer, partner or ES, whether this is written content or
photographs.
8. Respect your audience. Do not use ethnic slurs, personal insults, obscenity or engage in
any conduct that would not be acceptable in the workplace. You should also show
proper consideration for the privacy of others and for topics that may be considered
objectionable or inflammatory - such as politics and religion.
9. Be aware of your association to the company in online social networks. If you identify
yourself as an IPro or contractor of ES, ensure your profile and related content is
consistent with how you wish to present yourself with colleagues, partners and
customers is in line with ES’ values.
10. Do not provoke fights, conflicts or retaliate should someone try and initiate a conflict
with you on social media.
11. Try to add value. Provide worthwhile information and perspective. ES’ brand is best
represented by workers and what you publish should always be of a positive nature.
12. Do not use ES’ logos or trademarks unless you have obtained written
approval/permission to do so.
13. Do not bully, harass or offend anyone which includes ES’ employees, IPros, contractors,
representatives, customers and partners.
14. Be mindful that all comments made, regardless of whether they are made on an ES or
Client’s account (Twitter, Yammer etc…) or on workers personal account, are in the
public domain, accessible to anyone and therefore may be subject to disciplinary action,
even when those comments may appear to be unrelated to a worker’s work and/or
position.
3. Breach of policy and procedure

Breach of Entity Solutions (ES) Health, Safety and Wellbeing, Equal Employment Opportunity
(EEO), Drugs & Alcohol & Social Media policy or procedures or Client site policy or procedures
may result in disciplinary action.
In the event of any breach ES will consult with Client site management or HR to investigate the
breach and to determine an appropriate outcome. Breach of policy or procedure outcomes may
take the form of a formal warning letter, demotion or termination depending on the severity of
the misdemeanour.

Updated 29.09.2016
4. Communication and consultation
3.1.1. Purpose
To provide guidance with regards to effective communication and consultation between Entity
Solutions (ES), Client sites and workers.
3.1.2. Procedure
ES is committed to providing relevant health and safety information to all workers. ES

understands that effective communication and consultation between workers, Client sites and
ES is a two way system and we remain committed to maintaining open and effective
communication.
ES will maintain communication and consultation with Client sites and in particular areas where
workers are conducting activities or providing services.
To enable ES to instigate effective communication and consultation we have developed a

vertical communication process.
3.1.3. Vertical communication process
The requirement to consult with workers who carry out work for ES or Client site who could be
directly affected by a matter relating to work, health and/or safety. The process ensures that
workers, Client sites and ES (where appropriate) are able to:
 Report hazards, near misses and incidents

 Add controls to where hazards or incidents have taken place
 Investigate hazards and incidents
 Suggest changes to health and safety policy and procedure
a) Client site
Entity Solutions (ES)
Client Site
Worker

Updated 29.09.2016
ES understands that consultation, communication, coordination and cooperation are important
parts of managing health and safety. ES believes that the greatest danger in a consultation
process is to ignore a risk on the basis that a risk is someone else’s problem.
Effective communication and consultation requires identifying that the risks in a workplace are
the problem of everyone in that workplace. Eliminating or managing the risks helps to protect
everyone in the workplace.
3.1.4. Meetings
Meetings are an effective way of maintaining a vertical communication system. Reasons for
conducting meetings and discussions within ES may include:
 Health and Safety Committee meetings

 A meeting specifically related to a workplace incident
 Departmental meetings
3.1.5. Consultation
To ensure that all workers are aware of health and safety issues that relate to their work, the
RTW Coordinator or Entity Solutions Representative, will work with Clients (within reason) to:
 ensure that workers are aware of who is responsible for occupational, health and safety
processes in the work place
 communicate and update all parties in the event of an incident or hazard, which
involves the health and safety of workers
 complete the Client Site Information form by consulting with the Client and worker
where there are any changes that affect workplace health and safety.

Updated 29.09.2016
5. OHSMP policy acceptance
IPro/contractor agrees to adhere to the policies and procedures that are listed in the
OHSMP.
Policies
 Health Safety & Wellbeing Policy

 Equal Employment Opportunity Policy
 Drugs & Alcohol Policy
 Social Media Policy
 Breach of Policy and Procedure
Procedures
 Induction & Training Procedure

 Accident/Incident Reporting & Investigation Procedure
 Emergency Response Procedure
 First Aid Procedure
 Hazard Identification and Control Procedure
 Working at Heights Procedure
 Equal Employment Opportunity (EEO) – Reporting, Investigation &
Complaints Procedure
Please provide at least one emergency contact.
IPro/contractor name
1. Emergency contact name

Relationship
(E.g. mother, husband, brother)
Home ph:
Business ph:
Mobile ph:
2. Emergency contact name

Relationship
(E.g. mother, husband, brother)
Home ph:
Business ph:
Mobile ph:

Updated 29.09.2016
Do you have any medical conditions or allergies you would like to advise of?
Details
If there is a procedure in place for your particular condition that would help assist in
case of an emergency, please also provide a copy of it along with this form.
This information will only be forwarded to Entity Solutions Representative on an as

required and needs to know basis.
Please sign below as acceptance of the above conditions:
________________________ _____________________________ ___________________
Signature Name Date

Updated 29.09.2016

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Occupational Health &

Table of contents ........................................................................................................... 1

© Entity Solutions Pty Ltd OHSMP – New Zealand Page 1 of 28

Contractor A person or an incorporated entity that operates independently

Visitor A visitor is not an employee, contractor or IPro but is visiting ES

Worker Includes Independent Professionals (IPro) and contractors.

© Entity Solutions Pty Ltd OHSMP – New Zealand Page 2 of 28

2.1.3. Occupational Health and Safety (OHS)

To ensure this occurs, all workers must:

i. report OHS issues immediately to their relevant Entity Solutions Representative

© Entity Solutions Pty Ltd OHSMP – New Zealand Page 3 of 28

All workers must:

i. report to the relevant site representative before commencing work;

2.1.5. OHS forms

a) Workplace Induction Safety Inspection form (WISI form)

b) Client Site Inspection form (CSI form)

2.1.6. Workers’ compensation (WC) and Return to Work (RTW)

a) The role of the injured worker

The role of the injured worker is to:

© Entity Solutions Pty Ltd OHSMP – New Zealand Page 4 of 28

b) The role of the Return to Work (RTW) Coordinator

The role of the RTW Coordinator is to:

The program would be:

 matched to the capabilities of the worker;

2.1.7. Support and Counselling

2.1.8. Emergency Management

© Entity Solutions Pty Ltd OHSMP – New Zealand Page 5 of 28

1. Induction and training procedure

 Duration and breaks

2. Accident/incident reporting and investigation procedure

© Entity Solutions Pty Ltd OHSMP – New Zealand Page 6 of 28

Accident An unplanned event that results in personal illness or injury requiring

Serious Accident A fatality or serious injury or illness such as:

 A person requiring medical treatment within 48 hours of exposure to

a) Return to Work Coordinator

 Ensure all legislative incident reporting requirements are met.

b) The Entity Solutions Representative

© Entity Solutions Pty Ltd OHSMP – New Zealand Page 7 of 28

2.4. Reporting of accidents and incidents

Workplace accidents and incidents that need to be reported include:

1 An accident that results in a person suffering a work injury

WHERE WHERE Incent Report

2.5. Reporting of dangerous events, serious injuries or fatalities

© Entity Solutions Pty Ltd OHSMP – New Zealand Page 8 of 28

Seek medical CONTACT

3. Emergency response procedure

3.3. Availability of medical expertise

4. First aid procedure

To provide guidance in regards to providing first aid to ES workers.

© Entity Solutions Pty Ltd OHSMP – New Zealand Page 9 of 28

4.2. First aid equipment

4.3. First aiders

4.4. Emergency medical access

4.5. Record keeping

Information such as:

5. Hazard identification and control procedure

To provide guidance in regards to hazard identification and controls for workers.

5.2. Identifying hazards and risks

To ensure activities are conducted in a safe manner, the following is essential:

© Entity Solutions Pty Ltd OHSMP – New Zealand Page 10 of 28

5.3. Workplace hazards (where practical) shall be identified by means of

 Audits and inspections

5.4. Client Site and Information (CSI) form