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Bega Cheese Employee Handbook The Great Australian Cheese Company Bega Cheese Site - NSW Tatura Milk Industries - VIC Bega Cheese Coburg Site - VIC Bega Cheese Coburg Site - VIC Bega Cheese Strathmerton Site - VIC

Bega Cheese – Work Dates

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Page 1: Bega Cheese – Work Dates

Bega Cheese

Employee Handbook

The Great Australian Cheese Company

Bega Cheese Site - NSW

Tatura Milk Industries - VIC

Bega Cheese Coburg Site - VIC

Bega Cheese Coburg Site - VIC

Bega Cheese Strathmerton Site - VIC

Page 2: Bega Cheese – Work Dates

Bega Cheese Limited

Employee Handbook

Head Office Bega Cheese Limited Ridge Street Production Plant 23-45 Ridge Street Natural Cuts 02 6491 7756 NORTH BEGA NSW 2550 Processing 02 6491 7754 Postal Address PO Box 123 Bega NSW 2550 Telephone 02 6491 7777 Lagoon Street Production Plant Facsimile 02 6491 7700 Cheese Control Room 02 6491 7604 Web www.begacheese.com.au Heritage Centre 02 6491 7762 Email [email protected]

Bega Cheese – Coburg VIC Port Melbourne – VIC 10-16 Allenby Street 274 Salmon Street NORTH COBURG VIC 3058 PORT MELBOURNE VIC 3207 Telephone 03 9350 5766 Telephone 03 9251 2777 Facsimile 03 9005 2973

Bega Cheese – Strathmerton VIC Murray Valley Highway STRATHMERTON VIC 3641 Postal Address PO BOX 100 STRATHMERTON VIC 3641 Telephone 03 5875 8111 Facsimile 03 5875 8100 BEGA CHEESE EMPLOYEE HANDBOOK V1 Revised November 2012

HR-EMP-1001 BEGA 30/10/2012

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1. INTRODUCTION ............................................................................................................................................. 9

2. OUR HISTORY ................................................................................................................................................ 9

Mission ........................................................................................................................................................ 10

Vision ........................................................................................................................................................... 10

Our Organisation.......................................................................................................................................... 10

Structure of the Organisation for Bega, Coburg & Strathmerton ................................................................... 11

3. FUNCTIONAL AREAS .................................................................................................................................... 12

Sales and Marketing ..................................................................................................................................... 12

Supply Chain ................................................................................................................................................ 12

Operations ................................................................................................................................................... 12

Quality ......................................................................................................................................................... 12

Technology and Innovation .......................................................................................................................... 12

Engineering and Maintenance ...................................................................................................................... 12

Milk Supply and Farm Services ..................................................................................................................... 13

Administration ............................................................................................................................................. 13

Finance ........................................................................................................................................................ 13

Human Resources ........................................................................................................................................ 13

4. COMPANY LOCATIONS ................................................................................................................................ 14

Cheese and Whey Manufacturing – Lagoon Street, Bega .............................................................................. 14

Cheese and Whey Manufacturing – Allenby Street, North Coburg ................................................................ 14

Processing and Packaging – Ridge Street, Bega ............................................................................................. 14

Processing and Packaging - Murray Valley Highway, Strathmerton ............................................................... 15

Tatura Milk Industries .................................................................................................................................. 15

Port Melbourne ............................................................................................................................................ 15

5. KEY POLICY STATEMENTS ............................................................................................................................ 16

Company Code of Conduct ........................................................................................................................... 16

TABLE OF CONTENTS

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Workplace Diversity ..................................................................................................................................... 19

• Quality ................................................................................................................................................. 22

• Environment ........................................................................................................................................ 22

Customer Service ......................................................................................................................................... 23

Employment of Friends and Relatives........................................................................................................... 23

6. HEALTH & SAFETY ........................................................................................................................................ 24

Occupational Health and Safety Consultation ............................................................................................... 24

Safety Training ............................................................................................................................................. 24

Personal Protective Equipment .................................................................................................................... 24

Manual Handling .......................................................................................................................................... 25

Move4Life .................................................................................................................................................... 25

Repetitive Work and Job Rotation ................................................................................................................ 26

Employee Health and Wellbeing .................................................................................................................. 26

Employee Assistance Program (EAP) ............................................................................................................ 26

Machinery (including forklifts)...................................................................................................................... 26

Hazardous Substances ................................................................................................................................. 27

Workers Compensation and Rehabilitation .................................................................................................. 29

Visitors and Contractors ............................................................................................................................... 30

First Aid and Emergency Personnel .............................................................................................................. 30

7. FOOD SAFETY – GOOD MANUFACTURING PRACTICES (GMP) / HOUSEKEEPING STANDARDS – ALL SITES... 31

Purpose ....................................................................................................................................................... 31

Scope ........................................................................................................................................................... 31

Regulatory Requirements ............................................................................................................................. 31

Site Requirements ........................................................................................................................................ 31

Records, Documentation and Recording Practices ........................................................................................ 31

8. CLOTHING AND PERSONAL EQUIPMENT...................................................................................................... 33

Approved Clothing ....................................................................................................................................... 33

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Pockets ........................................................................................................................................................ 33

Fasteners ..................................................................................................................................................... 33

Disposable Clothing...................................................................................................................................... 33

Shoe Types ................................................................................................................................................... 34

Helmets, Bump Caps, Hard Hats ................................................................................................................... 34

Ear plugs ...................................................................................................................................................... 34

Hands .......................................................................................................................................................... 34

Hand Sanitising Frequency ........................................................................................................................... 34

Hand Washing and Sanitising Methods ........................................................................................................ 35

Control of Hand/Glove Uses ......................................................................................................................... 35

Hand Lotions ................................................................................................................................................ 35

9. SECURITY, INCLUDING COMPANY AND PERSONAL EQUIPMENT ................................................................. 36

Car Parking................................................................................................................................................... 36

Lockers ........................................................................................................................................................ 36

Personnel Records ....................................................................................................................................... 36

Confidentiality and Media ............................................................................................................................ 36

Employee Identification ............................................................................................................................... 37

Motor Vehicles............................................................................................................................................. 37

Use of Private Motor Vehicle on Company Business ..................................................................................... 38

Traffic Fines and Motor Vehicle Insurance .................................................................................................... 38

Site Access ................................................................................................................................................... 38

Company Computer Use .............................................................................................................................. 39

Email/Internet Use ....................................................................................................................................... 39

Telephone /Mobile Usage ............................................................................................................................ 40

Personal items in Operational Areas............................................................................................................. 40

Personal Property ........................................................................................................................................ 40

Illegal drugs and Alcohol .............................................................................................................................. 41

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Prescribed drugs .......................................................................................................................................... 42

10. SITE SPECIFIC OBILIGATIONS ........................................................................................................................ 43

Product Tampering ...................................................................................................................................... 43

Badges and ID Cards..................................................................................................................................... 43

Traffic Patterns ............................................................................................................................................ 43

Housekeeping .............................................................................................................................................. 43

Lunch Storage .............................................................................................................................................. 43

Lockers ........................................................................................................................................................ 43

11. EMPLOYMENT CONDITIONS ........................................................................................................................ 44

Employee Relations...................................................................................................................................... 44

Continuous Improvement ............................................................................................................................ 45

Workplace Consultation ............................................................................................................................... 45

Industrial Agreements .................................................................................................................................. 45

Contract of Employment .............................................................................................................................. 45

Position Descriptions ................................................................................................................................... 46

Induction ..................................................................................................................................................... 46

Company Orientation ................................................................................................................................... 46

Site, Department.......................................................................................................................................... 46

Leave and other Absences from Work .......................................................................................................... 46

Permanent Employees ................................................................................................................................. 47

Annual Leave ............................................................................................................................................... 47

Personal, Sick and Carer’s Leave ................................................................................................................... 47

Long Service Leave ....................................................................................................................................... 48

Parental Leave ............................................................................................................................................. 48

Breastfeeding............................................................................................................................................... 48

Bereavement /Compassionate Leave ........................................................................................................... 48

Jury Service .................................................................................................................................................. 49

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Military and Community Service Leave ......................................................................................................... 49

Study Leave.................................................................................................................................................. 49

Leave Without Pay (LWOP) .......................................................................................................................... 49

Discretionary Leave ...................................................................................................................................... 49

Public Holidays ............................................................................................................................................. 50

Casual Employees ........................................................................................................................................ 50

12. FAIRNESS @ WORK ...................................................................................................................................... 51

Whistleblower Policy ................................................................................................................................... 51

Equal Employment Opportunity (EEO).......................................................................................................... 51

What is Discrimination? ............................................................................................................................... 51

Systems and Education ................................................................................................................................ 52

EEO Communication & Training ................................................................................................................... 53

Harassment, Sexual Harassment and Bullying ............................................................................................... 53

Grievances and Dispute Management .......................................................................................................... 59

Counselling and Disciplinary Procedures ...................................................................................................... 62

13. REMUNERATION AND BENEFITS .................................................................................................................. 63

Superannuation ........................................................................................................................................... 63

Staff Discounts ............................................................................................................................................. 64

Access to Specialist Services ......................................................................................................................... 64

Bega Cheese Benefit Fund ............................................................................................................................ 64

Amenities..................................................................................................................................................... 64

14. TRAINING AND DEVELOPMENT ................................................................................................................... 65

Career Paths and Internal Job Applications................................................................................................... 65

Performance Reviews .................................................................................................................................. 66

Requests for Training ................................................................................................................................... 66

15. CLEANING AND SANITATION ....................................................................................................................... 67

Water Handling ............................................................................................................................................ 67

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Sanitary Handling of Sanitation Tools and Equipment................................................................................... 67

Cleaning and Handling of Product Equipment .............................................................................................. 67

Sanitary Mats ............................................................................................................................................... 67

Good Housekeeping Practices in Production Areas ....................................................................................... 67

Personal accessories in work areas ............................................................................................................... 68

Preventing Aerosols on Finished Product and Product Contact Surfaces ....................................................... 68

16. RECEIVING, HANDLING, STORAGE AND SHIPPING ....................................................................................... 69

Receiving ..................................................................................................................................................... 69

Storage and Handling ................................................................................................................................... 69

17. PROPER STORAGE ........................................................................................................................................ 70

Designated Storage Practices ....................................................................................................................... 70

Ingredient Storage Practices......................................................................................................................... 70

Rework Handling and Storage ...................................................................................................................... 70

18. LEAVING YOUR EMPLOYMENT .................................................................................................................... 71

Termination Payments ................................................................................................................................. 72

References ................................................................................................................................................... 72

Acronyms, Key Words and Names ................................................................................................................ 73

19. VISITORS ...................................................................................................................................................... 74

Supervisors .................................................................................................................................................. 74

Restricted/Sensitive Areas ........................................................................................................................... 74

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1. INTRODUCTION

This employee handbook is intended to provide information about Bega Cheese: what we do, how we operate, and the terms, conditions and benefits of working here. We have produced the handbook so that all employees can understand more about Bega Cheese as an organisation and about the part they play in its development and success. The information in this handbook is necessarily general, applying to Bega Cheese as a whole. In all cases there is more detail to be found elsewhere, in other documents that set out specific policies, procedures and instructions that apply to particular positions, processes and sites, including the company’s intranet, web page & various industrial agreements.

This handbook will be updated and revised from time to time. Bega Cheese has the right to change, at any time, the policies, procedures and details set out here. Where deemed necessary, employees will be notified of all and any changes as soon as possible.

The handbook is an important document, and reading, understanding and acknowledging its contents is a requirement of your employment.

2. OUR HISTORY

Dairying started in the Bega Valley in the 1850's. In those days each farmer produced and sold cheese from their dairy. After a period of time local farmers decided to improve their individual production and marketing activities, and banded together to establish The Bega Co-operative Creamery Company in 1899.

Bega Cheese's original factory was opened in Bega in 1900 and with the new processing plant built in 1997, has grown to be the largest employer in the region.

There are now approximately 470 farmers supplying the Bega group with around 640 million litres of milk from the regions of the Bega Valley and Gerringong/Berry in NSW, as well as Gippsland and the Northern and Western Districts in Victoria. Much of this milk is directed to the manufacture of bulk cheese and/or powder at sites in Bega, Coburg and northern Victoria; however, as appropriate and in order to meet contractual commitments, some milk is re-directed to markets in Canberra and Sydney where it is used for the production of consumer milk products.

In 2001 Bega entered into a major long term partnership with the Fonterra company, which sees Bega as the preferred contract packer for all of Fonterra’s Australian product requirements. As part of this deal, Fonterra also assumed the long term sales and marketing rights over the Bega brand just for the Australian market. In return Bega Cheese receives a royalty on all sales and is of course the exclusive manufacturer of all Bega brand products.

In April 2007 Bega Cheese Co-operative Limited acquired a 70% controlling interest in Tatura Milk Industries (TMI), and in 2011 assumed 100% ownership. Tatura Milk was established in 1907 and is located at Tatura in regional Northern Victoria. Tatura Milk has grown into a full automated modern complex which produces a wide range of dairy products to exacting specifications and employs more than 300 local people. 60% of the total Tatura Milk production is exported primarily to North and South East Asia. The acquisition was a good fit for Bega Cheese as it broadens the product range with the addition of cream cheese, milk powders, infant formula and nutraceuticals which compliments Bega's existing range of natural and processed cheddar cheese.

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In January 2008 the business changed from a co-operative structure to an unlisted company structure. The restructure of the company means that existing and new shareholders have input into the strategic decisions and directions of the business based on their investment in the business, and the company is now able to attract the capital investors it needs to fulfill the growth ambitions that is has.

In October 2008 Bega Cheese purchased the assets and operations of De Cicco Industries in the Melbourne suburb of Coburg. This site now forms an important element of Bega Cheese's access to milk supply and adds significantly to our bulk cheese manufacturing capability.

In March 2009, Bega Cheese acquired the cheese assets of Kraft Foods at Strathmerton, in Victoria. At the time of publication, the Strathmerton facility was producing 35,000 tonnes of processed and natural cheddar cheese products annually, primarily for the domestic market. Production is carried out in a continuous operation mode across eight production lines. As per its commercial agreement with Kraft, Bega will continue to contract manufacture Kraft's domestic product. In addition to this, Bega's focus moving forward is to increase volume through the introduction of new domestic and export product volumes at the site.

Bega Cheese’s most significant milestone occurred in August 2011 when the business listed on the Australia Stock Exchange (ASX). Following the successful listing, the Bega Cheese then acquired the final 30% of Tatura Milk Industries (TMI). With TMI now a wholly owned subsidiary of Bega Cheese, both businesses will work closely to achieve maximum operational efficiencies.

Today, with sites spread from Bega to Melbourne to Northern Victoria, Bega Cheese employs around 1,500 people and the company has evolved from its modest and localised co-operative heritage in Bega into a significant and innovative player in the Australian and international dairy industry. Group sales turnover is approaching $1 billion, from around 200,000 tonnes of product.

Bega's rich co-operative history stands in pride of place across the business and the factors which have driven its success for over a century remain enmeshed in its culture, thereby ensuring that it remains an Australian icon, leading the Australian dairy manufacturing industry.

Mission Bega Cheese – working together to deliver dairy products to the world.

Vision Bega Cheese’s vision is to be an Australian dairy industry icon, valuing our heritage, people, customers and community. Embracing challenge. Driving change. Building for the future.

Our Values Our core Values are:

Safety always

Supporting each other

Think Customer

Right first time

Take Ownership

Our Organisation Our organisation is made up of business departments and sections that have specific roles and responsibilities. The Organisation Chart and departmental descriptions show how the departments and sections work together in the overall operation of Bega Cheese.

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Structure of the Organisation for Bega, Coburg & Strathmerton

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3. FUNCTIONAL AREAS

Sales and Marketing As the front line representation for Bega Cheese, this department manages the day-to-day relationships with all domestic and international customers. Our Customers include Fonterra, Coles, Woolworths, Aldi, Kraft, McDonalds, National Foods and many other local and overseas organisations. Sales and Marketing also have responsibility for sales of all Bulk Industrial products, including Whey and Blended Powders.

Supply Chain The Supply Chain function is responsible for the co-ordination of group sales and operations planning process, group procurement requirements across all product categories and activities and all group logistics activities, including the physical storage and distribution of raw materials and products to our internal and external customers.

Operations The Bega Operations Group is responsible for the development and manufacture of an extensive range of dairy products at five manufacturing and processing sites across Southern NSW and Victoria.

The three Product Manufacturing sites at Lagoon Street – Bega, Coburg in Melbourne and Tatura in Northern Victoria produce approximately 80,000 tonnes of product including Milk Powders, Natural Cheeses & Processed Cheeses, Butter and Milk Protein Derivatives.

There are also two “process and packaging” plants that convert bulk cheese and other inputs into a range of retail consumer products including Natural and Processed Cheese Slices, Block cheese and Shredded cheese at Bega Ridge Street and Strathmerton.

Together Bega Operations employs around 1400 people to produce over 200,000 tonnes of product for local and overseas sales.

Quality Is responsible for developing, deploying and maintaining the company’s Quality Management System, ensuring compliance to regulatory and customer standards, the development of SOPs (standard operating procedures), standards of hygiene and cleanliness in our food production facilities & the effective & efficient operation of our on-site laboratories. These standards enable us to eliminate all possible sources of bacterial and microbiological contamination and secure the quality of our products.

Technology and Innovation This department supports the Operations Management and Sales & Marketing team across all technical areas. The team coordinates all Packaging and New Product Development and R & D projects and investigates technical challenges across the business.

This Environment and Sustainability team is also responsible for the delivery of the corporate environment management strategy and ensures that our business activities are environmentally sustainable and compliant with all relevant regulatory requirements.

Engineering and Maintenance Ensures that all machinery and equipment across the business operates effectively and efficiently. This is done with the assistance of a computerised maintenance management system and includes preventative and breakdown plant maintenance and new plant installation and commissioning.

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Milk Supply and Farm Services Milk Supply and Farm Services is responsible for maintaining milk supply to our manufacturing units, so they can meet product demand. Milk is sourced from direct farm suppliers and also external purchases with opportunity milk sold including sales into the liquid milk market. Maintaining milk quality, enhancing milk security and supporting milk sustainability are all aspects of milk supply management which is supported by a number of programs and services delivered by the Farm Services team. Milk transport logistics is also a key function of the department.

Administration Administration staff provide a range of support services across the Group. They have duties which include clerical support, general correspondence, preparation and distribution of reports, travel arrangements, and supporting visits from guests, including suppliers, customers and representatives of external organisations.

Finance Manages all the financial aspects of the business, including finance systems and IT, statutory and management reporting, treasury management, accounts payable, accounts receivable, budgets, capital expenditure, product costings, financial analysis, asset management, risk management and shareholder/investor relations.

Human Resources Is accountable for ensuring that the organisation possesses the necessary human talent required to achieve its objectives. The function is also accountable for managing and coordinating the relationship between the company and its employees, providing support services in areas such as occupational health and safety, recruitment and induction, remuneration and benefits management, training and development, talent development, succession planning, employee relations, industrial relations and payroll management.

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4. COMPANY LOCATIONS

Cheese and Whey Manufacturing – Lagoon Street, Bega

Milk and Butter Factory This is where the tankers unload the milk collected from suppliers’ farms. This milk is received at the factory and treated and distributed to other areas of the site, where it will be further processed. One such process involves separating cream from the milk and churning it into butter in the butter room. Some milk is also dispatched to other milk processors and ends up as cartoned milk. This milk is known as ‘market milk’.

Cheese Factory After arrival, milk is pasteurized to kill any bacteria, and starter cultures and rennet are added to turn milk into curds and whey. The curds are used to produce cheddar cheese in the Alfomatic, which produces 20kg blocks that are wrapped, boxed and palletized and transported to maturation rooms. Other cheese processes in the factory include string cheese production and waxed cheese.

Whey Plant As a byproduct of cheese making, liquid whey is dried into different types of powder and packaged in the whey plant, to be sold and used in the making of confectionery and other products.

Cheese and Whey Manufacturing – Allenby Street, North Coburg

Bega Cheese’s facility concentrates on the manufacture of Cheddar, Gouda and other specific cheese inclusive of Mozzeralla. The Coburg facility includes the newest Cheese Plant in Australia and has a total capacity in excess of 10,000 metric tonnes of product a year. Milk is supplied from the Gippsland, North Eastern and Western Victoria regions, representing a significant sized milk pool in Australia.

Processing and Packaging – Ridge Street, Bega

This department comprises several quite distinct and unique functions. Preparation covers grinding (where cheese blocks are ground in preparation for blending and cooking, as well as formulating/blending and cooking of various cheese products and additional ingredients, such as cream, powders, colorings’, flavour enhancers and the like. Once prepared, the product is piped to the two main processing areas, which are:

Castings (also known as Naked Slice or Slice-on-Slice) is where hot cheese is extruded onto large stainless steel belts which revolve around two drums. The cheese is then cooled and cut, before being packed, typically into large packs which are used for bulk catering, such as restaurants, fast-food outlets

Individually Wrapped Slices (IWS) is where hot processed cheese is extruded, wrapped and packaged, cooled and then cut prior to being boxed and palletized for distribution to customers.

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Involves the cutting of cheddar and other cheese blocks, such as parmesan, into different sizes and weights prior to wrapping, boxing and palletising for the consumer market. Apart from blocks and slices, which are the most typical retail forms of natural cheese products, other processes and packaging involving natural cuts include shredded cheese, string cheese and portions.

Processing and Packaging - Murray Valley Highway, Strathmerton In 2007 Bega acquired the Strathmerton site from Kraft. The site employs approximately 300 employees. Strathmerton produces both natural cheese and processes cheese products. Processed cheeses are spread across multiple processing lines in various packaging formats including Individually Wrapped Slices (IWS), Slice on Slice, Sticks, Wedges, Cheesy Pops, Jars, Cans and Processed Block cheese. The Naturals production lines produce block, sliced and shredded varieties of cheese. These products are sold to the domestic and international markets. Similar to the Ridge St plant, Strathmerton’s processing lines have a common preparation area that blends the required cheeses and additives and then delivers the product to various industrial cookers that are specific to the line the product is being filled on. Once the product is filled into the various packaging formats it is then palletised for distribution to the relevant markets. Natural cheese is packaged on site by utilising a larger block of cheese and cutting it down to the correct size in blocks or slices and then repacking it into the desired packaging format. Shredded cheese is made by taking larger blocks of cheese and grating them in an industrial size grating machine. There is provision during the shredding process to blend other types of chesses such as mozzarella to make different shred products as per the customer requirements.

Tatura Milk Industries

TATURA Milk Industries is located in the picturesque township of Tatura in regional northern Victoria and is a wholly owned subsidiary of Bega Cheese Ltd, an ASX listed company. TATURA has grown from humble beginnings in 1907, when in their first year of operation they produced a very modest 100 tonnes of butter. Tatura now process 80,000 tonnes of dairy products annually from milk supplied by best practice dairy farms in the immediate area.

TATURA manufactures a wide range of dairy products to the most exacting standards and specifications using state of the art technologies and systems. They manufacture the finest quality Australian dairy products for the global market with more than 60% of the total production exported to Japan, Korea, Malaysia, Singapore, Indonesia, China, Philippines, Thailand, Taiwan, Hong Kong and Europe.

Port Melbourne

The Company maintains an office in Port Melbourne to facilitate its business activities, including meeting with customers and suppliers.

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5. KEY POLICY STATEMENTS

Company Code of Conduct

Introduction

The board of directors and management of Bega Cheese Limited recognise the need for Bega Cheese to observe the highest standards of corporate practice and business conduct in Bega Cheese’s interaction with its customers, shareholders, employees, suppliers, business partners, the community and environment in which Bega Cheese operates. The Board has endorsed this code of conduct as part of Bega Cheese’s corporate governance framework. The Bega Cheese code of conduct provides a framework of principles that Bega Cheese as a company will abide by in business and dealing with stakeholders. Broadly speaking the Bega Cheese code of conduct requires Bega Cheese to:

a. act with honesty, integrity and fairness; b. respect, and act in accordance with, all applicable laws, regulations, policies and procedures; c. engage in the proper use of Bega Cheese’s information, funds, equipment, property and facilities; d. avoid real or apparent conflict of interests.

All Bega Cheese employees play an important role in establishing, maintaining and enhancing the reputation of Bega Cheese and ensuring that the high standards of ethics and behaviour that Bega Cheese is committed to are observed. It is required that employees display the highest levels of professionalism in all aspects of their work and comply with this code of conduct, other applicable Bega Cheese corporate policies and all applicable laws. Employees have a responsibility to report any potential breaches of this code of conduct to management or an appropriate Board member. Any employee who breaches this code of conduct may face disciplinary action, including potential termination of employment.

Acting with Honesty and Integrity

Bega Cheese wants to be known as an organisation that does what it says it will do. Bega Cheese cares both about results and equally how these results were obtained. Bega Cheese aims to compete effectively and fairly in the markets in which it operates. It will be honest, ethical and responsible in the ways it presents products and services to its customers, uses its market power and its pricing practices. Bega Cheese will be fair and honest in its relationship with suppliers and contractors, from selection through to payment and termination of the relationship. Employees are to act honestly and with integrity in dealings on behalf of Bega Cheese, and should always act in good faith and in the best interests of Bega Cheese. Employees of Bega Cheese must not use coercive or misleading practices or falsify or wrongly withhold information to obtain an outcome for Bega Cheese.

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Compliance with Law Bega Cheese aims to conduct its business activities in accordance with both the spirit and the letter of the law, and all regulations and policies within the industries in which Bega Cheese operates. Employees must familiarise themselves with the laws, regulations and policies relevant to their employment activities at Bega Cheese, including in relation to occupational health and safety, fair trading and dealing and privacy and employment practices. If in doubt, employees should seek assistance from their supervisor, manager or a Board member (as appropriate). Employees must notify their supervisor, manager or a Board member (as appropriate) if they become aware of any breach of a law or regulation, or instances of unethical behaviour within Bega Cheese. Bega Cheese aims to provide a safe environment in which to work and for customers and suppliers to visit. Employees must work safely and apply appropriate industry practices and laws to protect the health, safety and wellbeing of employees, customers and suppliers.

Confidentiality and Protection of Company Assets Bega Cheese will maintain the privacy of confidential information relating to its employees and customers. Employees must keep confidential all Bega Cheese related information that would reasonably be considered to be confidential, including but not limited to staff personal details, performance and financial details and Bega Cheese’s policies and procedures. Confidential information must not be misused by employees. Where an employee obtains confidential information in the course of their employment at Bega Cheese, that confidential information must only be used by the employee in the proper course of their duties. Employees must not use Bega Cheese resources for personal gain or for any other reason that is not in the best interests of Bega Cheese. All employees of Bega Cheese are under an obligation to use Bega Cheese’s funds, information, facilities and any other company property in the pursuit of the Bega Cheese business and not for any private or other purpose, unless specifically authorised to do so by a director of Bega Cheese. Misappropriation of Bega Cheese property will not be tolerated. Any misappropriation should be immediately reported and will be investigated. Appropriate disciplinary and or legal action will be taken for the misuse of Bega Cheese assets.

Conflicts of Interest

Employees are to act in the best interests of Bega Cheese at all times.

Employees must avoid any personal, financial or other interest which may be in conflict with their duties and responsibilities to Bega Cheese. Areas where conflicts might arise include: share ownership (other than shares in Bega Cheese), direct or indirect personal interest in contracts, dual employment with outside organisations or seeking gifts from competitors, customers or suppliers.

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Any actual or potential conflicts of interest are to be fully disclosed by an employee to an appropriate senior manager or supervisor.

Bega Cheese and its Employees

Bega Cheese is an equal opportunity employer. Bega Cheese aims to:

a. make human resource decisions on the basis of merit with the information available to it; that is, employment decisions will be made on the basis of the possession of skills, experience, qualifications and characteristics relevant to the performance of work;

b. ensure unlawful discrimination does not occur in the workplace or in circumstances arising out of the employment relationship;

c. maintain a workplace free from sexual harassment, unfair discrimination or other offensive conduct; and

d. promote a work environment in which individuals have the opportunity to develop to their full potential.

Bega Cheese aims to provide its business activities in a safe manner and prevent injury to its employees, customers, suppliers and contractors as a result of its operations. Bega Cheese endeavours to reduce the environmental impacts of its business activities and will seek to do this through continual improvement of environmental performance, protection and safety. Bega Cheese is committed to providing support and training for its employees to assist them in their responsibilities of ensuring a safe workplace and reducing the environmental impacts of their activities.

Other Matters

Monitoring of this code

The Bega Cheese Board will continue to monitor the appropriateness and effectiveness of this code of conduct and may amend the code from time to time as required to ensure that it remains effective and relevant to the Bega Cheese business and operation. Employees will be required to comply with the code as updated by the Bega Cheese Board.

Questions about the code and reporting non-compliance

Employees should direct questions about this code and its application to their manager or supervisor or a Board member, as appropriate. Employees are to report genuine suspicions of non-compliance with this code to their supervisor, a senior manager or Board member.

Breaches of the code

An employee who is found to be in breach of this code may be subject to disciplinary action by Bega Cheese.

This document was approved by the Bega Cheese Board on 30 May 2011, with effect from the date of approval.

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Workplace Diversity

Introduction

Bega Cheese Limited has a strong commitment to workplace diversity. Bega Cheese recognises that the wide array of perspectives resulting from a workplace that is diverse in gender, age, ethnicity and cultural background promotes innovation and benefits for Bega Cheese shareholders, customers, suppliers and other stakeholders. The appointment of a diverse group of well qualified employees, senior management and board of directors maximises the potential achievement of corporate goals. This diversity policy is designed to supplement Bega Cheese’s code of conduct and other internal Bega Cheese employment policies.

Objectives This policy provides a framework for Bega Cheese to achieve:

a. a diverse and skilled workforce, leading to continuous improvement in service delivery and achievement of corporate goals;

b. a workplace culture that is characterised by inclusive practices and behaviours for the benefit of all staff;

c. improved employment and career development opportunities for women; d. a work environment that values and utilises the contributions of employees with diverse

backgrounds, experiences and perspectives through improved awareness of the benefits of workforce diversity and successful management of diversity; and

e. awareness in all staff of their rights and responsibilities with regards to fairness, equity and respect for all aspects of diversity.

(collectively, the Objectives).

The Board’s Commitment The Bega Cheese Board is committed to workplace diversity, with a particular focus on supporting the representation of women at the senior levels of Bega Cheese.

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Diversity Strategies Bega Cheese’s diversity strategies include:

a. recruiting from a diverse pool of candidates in a manner that promotes diversity for all positions, including senior management and the Board;

b. reviewing succession plans to ensure an appropriate focus on diversity; c. identifying specific factors to take account of in recruitment and selection processes to encourage

diversity; d. developing programs to develop a broader pool of skilled and experienced senior management

and board candidates, including, workplace development programs, mentoring programs and targeted training and development;

e. developing a culture which takes account of domestic responsibilities of employees; and f. any other strategies the Board or the Nomination and Remuneration Committee develops from

time to time.

Monitoring and Evaluation The General Manager – Human Resources will monitor this policy and develop measurable objectives and strategies to implement the Objectives.

Reporting The General Manager – Human Resources will report to the Board on the achievement of the Objectives.

Bega Cheese will also continue to report annually to the Equal Opportunity for Women in the Workplace Agency regarding strategies for achieving equal opportunity for women in the Bega Cheese workplace, in accordance with its requirements under the Equal Opportunity for Women in the Workplace Act 1999 (Cth). This document was approved by the Bega Cheese Board on 30 May 2011, with effect from the date of approval.

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Occupational Health and Safety

Commitment

Bega Cheese Limited (Bega Cheese) embraces its legal and moral responsibilities to provide a safe and healthy workplace for employees, contractors and visitors. To deliver this commitment, Bega Cheese will maintain a work environment where the health and wellbeing of people is protected. Bega Cheese will comply with all relevant legal and regulatory requirements and will do everything practicable to prevent injury and illness to people and damage to property. The goals of this policy will be delivered primarily through consultation, training and a culture of continuous improvement through hazard identification and control.

Responsibilities

Board of Directors

Will ensure that Company’s OHS policies and programs meet statutory obligations and achieve continuous improvement.

Will remain acquainted with OHS issues and concerns at Bega Cheese and will regularly liaise with senior management on OHS issues.

Will ensure that senior management and other staff show commitment and due diligence to OHS requirements.

Managers / Supervisors Are responsible and accountable for maintaining a safe workplace.

Must consult with employees about OHS matters so they can contribute to decisions that affect them.

Must be actively involved in and support health and safety policies, procedures and programs.

Shall ensure adequate resources are allocated to achieve the health and safety commitment.

Must demonstrate all due diligence necessary for the prevention of accidents, injuries and illnesses’ in the workplace.

Are required to provide effective instructions, training, supervision and advice to all employees, contractors, or visitors under their control.

Employees Must co-operate with management efforts to ensure a safe and healthy workplace.

Shall actively participate in safety programs and initiatives.

Must comply with their obligations under the relevant OHS Legislation and company OHS rules and policies.

Must take reasonable care to ensure that neither by act, nor omission, they endanger the health and safety of themselves and other, including those who are under their supervision at work.

Must use all provided Personal Protective Equipment (PPE) and manual handling equipment in accordance with directions and report when equipment including PPE requires repair, replacement or when risk assessment indicates the need for PPE to be provided by the employer.

Participate fully in training and consultation arranged to support implementation of this policy.

Must assist the employer by reporting and/or recording all incidents and hazards that may cause injury or illness.

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Consultation

To ensure continuous improvements in safety performance and OHS systems, consultation that considers the views of all relevant stakeholders, especially employees will occur when required. This includes but is not limited to changes to or new work areas, plant and equipment and work processes. Consultation may take place through risk assessment, team meetings, OHS employee representatives or other suitable means.

Review

This policy will be reviewed at least annually, in consultation with employees; however it may also be reviewed in response to receipt of significant new information, legislative or organizational change that warrants modification to this document.

• Quality

The focus of our quality system is on the identification and control of assessed hazards; thereby utilizing preventative measure of Quality Assurance rather than relying on finished goods testing alone. This has been achieved through the implementation of a Hazard Analysis and Critical Control Point (HACCP) system based on the HACCP Plan. The Plan has been developed to identify both Food Safety and Quality issues. Bega Cheese has a legal obligation to our customers to maintain the quality systems to assure the safe and continued quality of manufactured products at Bega Cheese sites. The quality and reliability of the Company’s products are the concern of every person in the organisation and are not just the sole responsibility of the Quality Department. All employees have quality related responsibilities. Quality is the results of team effort and diligence. The “Make If Right First Time’ approach is the key to quality production, cost control, and customer satisfaction. To help achieve this objective, quality problems arising in various areas are to be identified and managed with speed, technical efficiency and given the highest of priorities. The methods employed are to be continually under review and techniques improved whenever and wherever possible. ‘Quality Assurance’ means exactly what it implies: assurance that quality is satisfactory when compared with the reference standard or specification by using sampling and testing based accredited methods. The Company requires such assurance before goods can be supplied to the customer. The Foregoing board principles are basic to the Company for the assurance of product quality and all levels of management actively support the Quality Assurance Department in the implementation of this policy and compliance to the control documentation and system of inspection.

• Environment

Responsible environmental management is an essential part of Bega Cheese’s business objectives. The Chairman of the Board of Directors is ultimately accountable for compliance and heads the team that ensures that operating procedures which are part of our Environmental Management System (EMS)

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monitor and improve environmental performance. The EMS implements projects to reduce energy, water, and resource consumption and also waste generation.

Bega Cheese is committed to: Protecting our immediate pristine environs from impact from our activities;

Implementing the best resource management practices to minimize waste and losses;

Optimizing its operation to minimize the environmental footprint of all products manufactured;

Continuously improving our management system and comparing our performance with others nationally and globally: &

Complying with all relevant laws and regulations.

Community Bega Cheese recognises the importance of corporate support in our local community and the difference it can make to not-for-profit organisation’s and charities. In an endeavor to support a broad range of groups within the local area, Bega Cheese is committed to organisations and activities that assist in areas that have as wide and lasting a community benefit as possible. These might typically include areas such as education, sport, community services, the arts and health. Bega Cheese employs a Public Relations Officer who is responsible for not only the receipt, review and response to requests for assistance from Bega Cheese, but also to promote the many positive areas of support provided by the company and the overall good name of Bega Cheese throughout the community.

Customer Service

Customer service is the focus of all our activities. Bega Cheese aims to continuously improve our products and processes to meet and exceed our customers needs and expectations. We pride ourselves in our ability to respond to specific customer requests in the shortest possible time frame, thereby building excellent customer relations.

Employment of Friends and Relatives

It is the highest compliment to Bega Cheese that you may recommend your friends and relatives to the Company for employment. We welcome the opportunity to assess their suitability for positions, however they will need to progress via the normal external and internal recruitment channels, and there will be no preferential treatment given. Whilst the company welcomes the opportunity to employ suitably qualified relatives & friends of existing employees, it reserves the right to manage the deployment of all employees within the business, so as to avoid any perception of favoritism & or to avoid the company’s risk management arrangements potentially being compromised.

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6. HEALTH & SAFETY

Many of our operations have potential dangers: heavy machinery, vehicles, chemicals, heat sources, high voltage electricity and activities requiring manual handling. Bega Cheese provides safety equipment, procedures and training; but ultimately, safety depends on the safety-consciousness of all employees. You must always have a positive and active approach to safety. This means:

knowing how to do your job safely, and following the correct work procedures;

wearing and using the correct safety equipment;

being aware of the hazards of your work environment;

knowing the layout of your site, the location of fire alarms, extinguishers, and exits;

knowing the site emergency procedures;

Being fully alert: please do not attend work under the influence of medications, alcohol or other drugs, or when you are fatigued;

Never playing practical jokes;

Behaving safely so as not to put yourself or work colleagues at risk.

Occupational Health and Safety Consultation Consultation on OHS matters at the work group level is enhanced through regular work group safety team meetings, toolbox meetings or line meetings where safety matters are discussed and recorded. This enables all employees an opportunity to participate in occupational health and safety issues affecting them.

All safety issues should, in the first instance be reported to your Supervisor as soon as possible. Such reports may be made via your Team Leader or Area Health and Safety Representative (HSR). If there is no action or insufficient action taken, then the matter can be elevated to the OHS Committee for final resolution.

Safety Training Bega Cheese has a continuing commitment to train all staff in occupational health and safety which is seen as an integral part of all workplace training. This reflects the fact you don’t know how to do the job unless you know how to do it safely.

The safety committee helps to identify training needs and communicates these to the appropriate Managers. You should request training if you believe that training will assist you to do your job in a safer way.

Personal Protective Equipment As far as possible, we try to design work procedures and environments to remove workplace hazards. Where this is not possible we provide personal protective equipment (PPE) to prevent injury to employees. PPE includes: earmuffs, ear plugs, face shields, goggles, safety boots, rubber gloves, bump hats and aprons.

It is a condition of your employment that you wear or use all personal protective equipment issued to you, at all times as directed. Breaches of this condition are treated in the same way as other workplace issues, and are subject to counselling and disciplinary procedures.

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Your Supervisor will advise you of the PPE requirements for your work area, on commencement of employment.

Manual Handling Manual handling is any activity that requires the use of force exerted by a person to lift, lower, push, pull, carry or otherwise move, hold or restrain an object.

Every job in the factory requires some degree of physical effort. Cheese blocks weigh around 20kg and pallets around 50kg. It is possible to hurt yourself lifting any weight incorrectly, so follow these simple rules:

Do use the safe lifting technique which is taught in the Move4Life program: Always carry loads close

to your body. When lifting, your spine should maintain its natural curved shape, and you should use the strong muscles in your upper legs to take the weight not your spine. This is best achieved by allowing your bottom to drift backwards as you bend your knees, keeping your weight in your heels, positioning yourself close to the load and getting a secure hold and breathing out as you lift

use any mechanical aids available

step instead of twisting the lower back

ensure the area is free from clutter so you have enough room to move

get assistance - team lifting reduces the weight

have regular breaks & rotate between jobs/tasks.

plan the lift

Don’t lift Heavy Weights

lift awkward loads by yourself

bend and twist whilst lifting or carrying heavy loads

lift above shoulder height

carry a load away from your body e.g carrying at arms length

rush when carrying loads

Move4Life Move4Life is an informative and refreshing education program that provides different movement options to help you move with less strain, discomfort and pain. Move4Life is a whole body program that looks at natural movement patterns of the back, spine, knees, abdominal muscles, shoulder and hands. It is very applicable to your work, but also to your leisure time.

The way we use our body to perform certain tasks or actions can impact on our health and wellbeing. Poor movement patterns or techniques can result in some people sustaining sprain or strain injuries.

The Move4Life program is an interactive, action learning program that will equip you with the skills, knowledge and tools to make your movement patterns safer and to take better care of not only your back, but other body parts like shoulders, wrists, elbows and knees.

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Repetitive Work and Job Rotation The nature of work on our production lines involves repetitive task and movements. We have implemented job rotation practices whereby production line employees change work tasks and lines regularly to help reduce repetitive work injuries. Job rotation also provides variety of work, an increase in skill and greater job satisfaction.

Employees are encouraged to maintain a degree of physical fitness to reduce risk of injury and use the gentle stretches taught during Move4Life training. If you suffer from any back, shoulder, wrist or hand irritation, discomfort or pain stop what you are doing and report this to your Supervisor.

Employee Health and Wellbeing Bega Cheese employees have access to comprehensive employee health and wellbeing services, inclusive of soft tissue injury therapists, registered nurses, preferred or company medical officers and rehabilitation consultants, to enable early intervention measures to be initiated to assist employees.

In addition, other employee wellbeing activities include the provision of free, confidential counseling, voluntary influenza immunization, as well as regular hearing testing. Health promotional programs are also run from time to time, such as smoking cessation and health checks.

Employee Assistance Program (EAP) D’Accord Pty Ltd is a national Australia company that provides Employee Assistance Programs. Bega Cheese has engaged in the services of D’Accord to provide professional and confidential counselling for employees and immediate family who may have personal and work related issues such as;

Work performance

Emotional difficulties

Career issues

Anxiety & Depression

Personal Trauma

Grief & Bereavement

Family/relationship concerns

Alcohol, drug or family issues

For further information or to contact D’Accord please phone 1300 130 130.

Machinery (including forklifts) Never operate machinery unless you have been trained on site to do so. Never reach under, through or over any guard and under no circumstances operate any machinery with safety guards removed. Always ensure you know exactly how to stop any machine you are working with. Do not try to fix any problems with machinery yourself, except for minor repairs/adjustments as specifically covered by your job role and competencies and approved by your Supervisor. Any breakdowns or defects should be immediately reported to your leading hand or Supervisor.

Before starting any shift a full operational check has to be performed of the safe working condition of the machinery.

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If a machine or item of equipment has been tagged: “don’t operate” or “do not remove”, check with your Supervisor as to when the machine may be used. Activating a tagged machine or equipment could cause serious injury or death to you or other employees.

Only trained, appropriately licensed and authorised employees or contractors are permitted to drive or operate forklift trucks, cranes, cherry pickers, front-end loaders (including tractors fitted with load shifting equipment), trucks or other heavy vehicles on site.

Any employee selected for training as a driver of forklift trucks or front-end loaders must complete an introductory training session, be issued with a log-book and appropriate training documentation & be allocated a qualified trainer, who will be responsible for closely supervising the completion of their training, including supervising the use of the equipment whilst they are in training.

It is the responsibility of all employees operating company equipment to ensure that they carry with them at all times in the workplace the appropriate licenses authorizing them to do so & that such licenses are kept current. No employee is to operate equipment or machinery in the event that their license is cancelled or lapses & it is the employee’s responsibility to advise the company if such a situation arises.

The company will meet the cost of training & licensing employees to operate its equipment, where its operation is a requirement of the employee’s role. The Human Resources Department will maintain a record of employees who are licensed & required to operate such equipment, along with details of any employee being trained to operate such equipment.

Employees are responsible for ensuring that company machinery is not used in a way that will jeopardise the safety of others or themselves, or that would reflect badly on the company, or for inappropriate or unauthorised purposes. “Employees found to have used company machinery, including forklifts, in a manner that jeopardised the safety of others or themselves, or for an inappropriate or unathorised purpose, may face disciplinary action, which could result in the termination of their employment.”

Hazardous Substances During the course of your work you may come into contact with a wide variety of substances. These include, chemicals used in cleaning and sanitation, gases such as ammonia and fuels like propane. Dust, vapors and fumes can also be hazardous substances. All of these substances have been assessed as being safe to work with in our production process, provided the correct handling procedures are followed.

If you at any time experience any sensitive or allergic condition you must report it immediately to your Supervisor.

The following points must be observed when dealing with hazardous substances:

before you use the product, read the product label and Safety Data Sheet (SDS) information. Seek training in the product use, in the event it has not already been provided to you;

avoid eye and skin contact. Wear PPE provided;

never eat, drink or smoke when handling any chemical and wash hands after chemical use.

avoid inhaling chemical fumes and dust;

never mix chemicals unless instructed and trained to do so;

only transfer into clean and properly labeled containers;

always return chemicals to the proper storage area. Never store chemicals in direct sunlight or near to sources of heat;

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clean up spillages immediately, following the correct procedure. Always report major spillages immediately;

always dispose of empty containers as instructed;

know the action to take in the event of an accident.

Smoking Policy Bega Cheese has a policy that restricts smoking to designated smoking areas and is working toward removing smoking areas from all sites. We strictly enforce our restricted smoking policy and employees who fail to adhere to the policy may be subject to disciplinary procedures.

Smoking Cessation Bega Cheese recognises the significant mutual benefits of assisting employees to quit smoking and has Quit Smoking initiatives available to support employees. Nicotine replacement or appropriate drug therapy is subsided for employees wishing to quit and referral to pharmacy, GP, and or counselling is facilitated to support employees to quit. These programs have proved very successful to date.

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Accident and Incident Reporting

If you are injured at work, no matter how minor the injury, you must:

Get first aid (if required);

Immediately report the incident to your Supervisor; &

Record the details by completing an Incident report form. When you have observed a dangerous incident, even when no injury has occurred, you must complete a Near Miss form eg: a carton fell from racking’ steam escaped; unsafe conditions such as a machine guard missing; risk of falling etc.

Every Near Miss notification is an opportunity to reduce future injuries, so please play your part in looking after yourself and others.

Supervisors and Managers will investigate all incidents, accidents, injuries and near misses. Solutions to hazards will be sought in the first instance via work group safety team meetings. Unresolved OHS issues can be elevated to the OHS Committee for action.

If, having finished work and left the site, you later believe that you may have suffered a work-related injury, then you should, at the earliest possible opportunity, contact your Supervisor or Manager or, if you cannot contact them, a member of the Human Resources Department. If your injury is suspected to be work related, then Bega Cheese will need to be involved in the assessment or your injury, liaison with your medical practitioner and, if necessary, your return to work capabilities and designation of suitable duties.

Workers Compensation and Rehabilitation Workers Compensation ensures that you do not experience a significant loss of income or incur expenses for an injury or illness you suffered in the work place (including journey claims where applicable).

A Workers Compensation Claim Form should be completed for any accident or injury that needs ongoing medical assistance or requires you to take time off work.

In the case of medical treatment being required, employees may visit the Doctor of their choice or, if convenient, the company’s medical consultant. If time off work is required, a Work Cover Medical Certificate (NSW) or Certificate of Capacity (VIC) must be obtained. Where an employee is subject to a Work Cover claim, they may also be required to consult with medical providers nominated by the company or it’s Workers Compensation Insurer.

Consent is obtained to enable Bega Cheese to discuss your medical treatment and return to work conditions with your treating Doctor or other health service providers engaged in your rehabilitation (this consent also covers discussions with your Supervisor/Manager, the company’s Workers Compensation Insurer and any other relevant party, including legal representative’s). This will facilitate a return to work as soon as possible. A return to work plan, possibly involving alternative duties, may be implemented to assist your injury rehabilitation.

In the event that you suffer a significant injury at work, your own situation will be discussed with you, so that you are quite clear about the Workers Compensation process.

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Visitors and Contractors All visitors and contractors to the Bega Cheese sites must comply with the safety policies and requirements. Visitors include employees from other sites, members of the public, VIPs, customers and office staff. It also includes an employee’s family members – to assist employees with their child-minding arrangements, the company does allow access of employee’s children to certain non-operational areas of the business, primarily for the purposes of drop-off/collection by another family member. In such cases it is the responsibility of the parent to ensure their child’s security and appropriate behavior.

Visitors and contractors must be made aware of the health and safety requirements of the site, by their host. Regular Visitors and Contractors may be required to complete the company’s site Induction Program.

The Heritage Centre attracts a large number of visitors to the Lagoon Street site, and employees are required to be mindful of public safety, production presentation and Company image in dealing with our visitors.

First Aid and Emergency Personnel Bega Cheese maintains a First Aid and Emergency Response capability at all of its sites.

First Aid During their Induction, new employees will be introduced to the designated First Aider in their area, as well as being shown the site First Aid facilities. All First Aiders have completed an accredited First Aid Program and are required to satisfactorily complete regular refresher training in First Aid. First Aid Kits are available in all work areas; checked regularly and restocked as required. Any employee who becomes injured or requires medical assistance whilst at work should immediately contact the closest First Aider for assistance. To ensure that the company continues to meet its health and safety obligations, open wounds are not permitted in food production areas. Any employee suffering from such a wound, including cuts and abrasions, must immediately contact their closest First Aider, who will cover the wound with a blue bandaid. (It is important for our employees to understand that only blue bandaids from the company’s First Aid Kits should be used to cover such wounds, as they contain a metallic strip to ensure detection, in the event that they accidently come off and find their way into food products.)

Emergency Response Emergency response arrangements are in place at all Bega Cheese sites, with specific employees designated as members of the company’s emergency response team, including employees designated as Area Wardens. During their Induction, new employees will be introduced to the Area Warden for their area. In an emergency, employees are required to follow the directions of their designated Area Warden.

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7. FOOD SAFETY – GOOD MANUFACTURING PRACTICES (GMP) / HOUSEKEEPING STANDARDS – ALL SITES

Good Manufacturing Practices/Housekeeping Standards are part of Bega’s heritage. The best employee practices, raw materials, equipment, processes, and technologies mean nothing if they are not used in a way that protects our products and ensures food safety and quality. This section outlines Bega’s GMP requirements.

Purpose GMP/Housekeeping Standards help us make safe, wholesome food products for all our customers and consumers. The rules in this manual are necessary to make sure our products are produced, stored, and handled under sanitary conditions.

Scope GMP’s apply to all people within the entire supply chain who are involved with:

Producing, handling, and distributing food products.

Design, constructing, and maintaining food facilities, processes, and equipment.

Regulatory Requirements Several government regulations address requirements for GMP’s. While these regulations may be broad, this manual provides more detail and additional company defined GMP requirements.

Where necessary for a given facility and /or production line, other applicable regulations may need to override a certain GMP rule, for example, where there are specific government regulations. Usually, these regulations are focused on particular products, processes, or locations.

Site Requirements Bega Cheese applies a minimum set of GMP/Housekeeping Standards across all sites. Where differences exist, often as a result of operating circumstances or the addition of new sites into Bega Cheese, the business is progressively moving towards adopting a uniform approach to GMP/Housekeeping Standards, which will in time see the most appropriate standards being harmonized across the business.

Records, Documentation and Recording Practices Where employees are required to log, record or document activities, these records and/or other company documentation must be completed in a timely and accurate manner.

To ensure the integrity of document records;

Pencils must not be used on permanent records

If a mistake is made, a single line should be drawn through the mistake and the person’s initials and date of change placed near it – correction fluids (‘white-out’) or tape must not be used

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Good Manufacturing Practices/Housekeeping

Standards – All Sites THE FOLLOWING RULES APPLY UNLESS OTHERWISE PRESCRIBED ACROSS SITE POLICES OR PROCEDURES

1. HANDS MUST BE WASHED AND SANITISED - BEFORE ENTERING THE MANUFACTURING AND PACKING AREA, AFTER USING THE TOILET, AFTER SMOKING, BLOWING NOSE, SNEEZING OR WHENEVER HANDS HAVE BECOME SOILED OR CONTAMINATED.

2. FINGERNAILS MUST BE KEPT CLEAN. FALSE FINGERNAILS AND NAIL POLISH ARE NOT PERMITTED.

3. NO JEWELLERY IS PERMITTED. THIS INCLUDES WATCHES, RINGS, EAR RINGS AND EAR STUDS, CHAINS, BROOCHES, RELIGIOUS JEWELLERY AND TONGUE AND NOSE RINGS. THE ONLY EXCEPTIONS ARE APPROVED MEDICAL ALERT NECKLETS.

4. A HAIRNET MUST BE WORN TO COVER ALL HAIR. HAIR EXTENDING OVER THE EARS OR BEYOND THE TOP OF A SHIRT COLLAR

MUST BE PROTECTED BY THE APPROPRIATE HAIR NET COVERING. A HAIR BALACLAVA MUST BE WORN OVER THE HAIRNET FOR RED LINE AREAS. EYE WEAR PROTECTION MUST BE WORN IN ALL AREAS OF MANUFACTURING/PRODUCTION

5. CLEAN UNIFORMS MUST BE WORN AT ALL TIMES AND MUST NOT BE WORN OFF THE SITE. THIS INCLUDES WORK BOOTS.

6. SPITTING, USING TOBACCO, CHEWING GUM, EATING FOOD OR LOLLIES IS NOT PERMITTED IN THE MANUFACTURE OR

PACKING AREAS.

7. SMOKING ON SITE IS ONLY PERMITTED IN THE DESIGNATED AREA.

8. NO GLASS IS PERMITTED IN THE MANUFACTURING AREA.

9. PINS, STAPLES, RUBBER BANDS OR ELASTRATOR RINGS ARE NOT PERMITTED IN THE MANUFACTURING AREA.

10. UNNECESSARY CONTACTS WITH PRODUCT CONTACT SURFACES IS TO BE AVOIDED. NO SITTING OR STANDING ON FOOD CONTACT SURFACES.

11. ANY OPEN SORES OR WOUNDS ARE TO BE IMMEDIATELY ATTENDED TO BY A REGISTERED FIRST AIDER.

12. ANY CUTS ON HANDS ARE TO BE COVERED WITH A BLUE METALISED ADHESIVE STRIP. (SUPPLIED BY THE FIRST AIDER ON DUTY)

13. EMPLOYEES WITH INFECTIOUS DISEASES, OPEN SORES OR WOUNDS MUST NOT START WORK AND MUST NOTIFY THEIR SUPERVISOR.

14. THE USE OR POSSESSION OF PERSCRIPTION MEDICATION MUST BE ADVISED TO YOUR SUPERVISOR OR OH&S CO-ORDINATOR PRIOR TO COMMENCEMENT OF SHIFT.

15. THE USE OF HEAVILY SCENTED PERFUMES IS NOT PERMITTED IN AREAS OF EXPOSED PRODUCT.

16. FACIAL HAIR - RIDGE STREET SITE EMPLOYEES MUST BE CLEAN SHAVEN. NO BEARDS ARE PERMITTED AT RIDGE STREET OR LAGOON ST RETAIL PACKAGING. MOUSTACHES MUST BE CLEAN AND NEATLY TRIMMED (LEVEL WITH THE LIP LINE). LAGOON STREET/COBURG SITE EMPLOYEES MAY HAVE BEARDS, BUT MUST COVER THEM WITH A BEARD NET WHEN ENTERING DESIGNATED PRODUCTION AREAS. SIDE BURNS ARE TO BE KEPT NEAT AND NOT REACH BELOW THE EARLOBE – FOR RED LINE AREAS, ABLE TO BE COVERED BY PPE HEADWEAR.

17. SANITISED BLUE FOOD GRADE GLOVES MUST BE WORN ANYTIME A RAW MATERIAL (UNWRAPPED PRODUCT) IS HANDLED IN THE REDLINE AREA. THESE DISPOSABLE GLOVES MUST BE SPRAYED WITH SANITISING SOLUTION PRIOR TO COMMENCING WORK, REGULARLY DURING WORK WITH THE PRODUCT AND REPLACED ANY TIME THE GLOVE INTEGRITY IS COMPROMISED.

18. SHIRTS OR T-SHIRTS ARE TO BE WORN UNDER RED LINE GARMENTS TO ENSURE ALL BODY HAIR IS COVERED. 19. CLOTHING INCLUDING HEADGEAR THAT IS FOR RELIGIOUS OR CULTURAL REASONS MAY ONLY BE WORN PROVIDED IT DOES

NOT BREACH THE COMPANY’S EMPLOYEE CLOTHING POLICY, GMP’S, OH&S & SECURITY POLICIES AND PROCEDURES.

20. CLOTHING INCLUDING HEADGEAR THAT IS FOR RELIGIOUS OR CULTURAL REASON MAY ONLY BE WORN PROVIDED IT DOES NOT BREACH THE COMPANY’S EMPLOYEE CLOTHING POLICY, GMP’S, OH&S & SECURITY POLICIES AND PROCEDURES.

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8. CLOTHING AND PERSONAL EQUIPMENT

Approved Clothing Employees who work in operational areas will wear only company-approved clothing. Stricter site regulations must be followed where applicable. Clothing shall provide adequate coverage to ensure that hair, perspiration or other foreign materials do not contaminate the product. (Unacceptable clothing would include, but is not limited to; shorts, tank tops, sleeveless shirts, etc.)

Whenever entering a operational area, all non-production Bega employees, contractors and visitors must wear a lab coat or other approved covering and appropriate footwear consistent with individual site policy.

All clothing and headgear must be free of potentially offensive markings.

Pockets Pockets above the waist must be removed or sewn shut.

Fasteners Only zippers, grippers or snaps may be used as the fasteners on shirts, coats, laboratory jackets, or smocks.

Disposable Clothing In operations where clothing is rapidly soiled, and there is exposure to open product, disposable clothing (plastic aprons, arm guards, lab coats, etc.) must be worn over clothing and changed at a frequency to prevent product contamination.

Clothing for Specific Process Areas/Changing Facilities

All clothing must be kept in good repair

Clothing must be clean at the beginning of the shift and kept reasonably clean during operations.

Work-wear dedicated to specific product areas must be restricted to those areas. Such areas must be defined in individual site procedures. (Typically high care areas where clothing change is required when entering and exiting.) This restricted work-wear is not permitted in other plant or non-plant areas where clothing may be subject to allergen or microbiological contamination (e.g. Lunch rooms, external rest areas, and/or any areas not subject to GMP controls).

If a captive clothing and/or footwear policy exists, employees who work in microbiologically sensitive areas must not wear captive clothing and/or footwear outside the plant.

When not in use, work-wear and/or captive clothing should be stored in a sanitary many (e.g., on hangers or hooks).

Employee clothing should not be source of contamination.

Designated changing facilities shall be provided for all personnel, whether staff, visitor or contractor. These shall be sited to allow direct access to the production, packing or storage areas without recourse to any external area. Where this is not possible, a risk assessment shall be carried out and procedures implemented accordingly. Eg: the provision of cleaning facilities for footwear.

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Shoe Types To help avoid product contamination (and for personal safety) shoes worn in GMP areas should be designed and constructed as follows:

Fully enclosed – NO open toes, open weave, or sandals.

Made with leather or vinyl outer materials – NO canvas or nylon mesh.

Low heeled.

Sole grooves depth must not be a source of contamination.

Overall construction should be sturdy enough to provide impact protection (Note: Personal safety gear guidelines must also be followed where required).

Shoes worn in wet, microbiologically sensitive areas must not allow passage of water from the base of the shoe. (Shoe should not trap or absorb water when walking through footbaths at room entrances.)

Helmets, Bump Caps, Hard Hats Safety helmets must be maintained in a sanitary condition. Labels or stickers are prohibited.

Helmets used in microbiologically sensitive areas must be cleaned and sanitized at a frequency determined by plant quality. Helmets must be stored in a sanitary manner.

Helmets must not be used for storing or carrying objects such as cigarettes, notepads, food, pens etc.

Ear plugs Hearing protection devices must be secured to prevent product contamination.

These include:

ear plugs attached by a string worn around neck.

earplugs with a rigid attachment worn around neck.

earmuffs attached by a headband.

Hands Hand Washing/Glove Changing Frequency

Personnel working in operational areas must wash hands at the following times:

Before entering an operational area.

Upon re-entering any operational area.

After each visit to the toilet facility, rest room, and/or lunch and break room facilities.

Prior to touching product or product contact surfaces.

Any time when hands have become soiled or contaminated.

When gloves are soiled

Hand Sanitising Frequency Personnel in direct contact with the product must sanitize hands:

If working in a microbiologically sensitive area (after proper hand washing.

After touching non-product contact surfaces.

If soil is observed on hands, hands must be washed prior to re sanitizing.

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Hand Washing and Sanitising Methods The steps listed below are required when washing and sanitizing hands.

Wet hands with warm water.

Apply soap. Lather the soap by thoroughly rubbing the hands together taking care to apply both rubbing action and soap to the entire surface area of the hands.

Rinse hands completely.

Dry hands.

Sanitize hands with a sanitizer after the hands have been washed and dried.

Put on gloves and sanitize if required.

Control of Hand/Glove Uses When working in operational areas, the use of hands for unsanitary practices must be avoided. Specifically, hands should not be used to:

Head or body.

Touch face or wipe forehead.

Place fingers on, or in, mouth, nose, or ears.

Hand Lotions Hand lotions must not be used if hands are in direct contact with product or product-contact surfaces. However, appropriate gloves may be worn over hands having non-perfumed lotion, if it is compatible with work conditions and regulatory rules.

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9. SECURITY, INCLUDING COMPANY AND PERSONAL EQUIPMENT

Car Parking Bega Cheese provides various locations where employees may choose to park their vehicles. In the unfortunate event of damage being occasioned to an employee’s vehicle, Bega Cheese shall not be liable, unless the damage arose directly from an authorized activity being undertaken by a Bega Cheese employee. Please note that no private cars are to enter the site without permission.

Lockers All operations-based employees who are required to wear company uniforms are provided with lockers in which to keep personal belongings. You will be issued your locker on commencement. It is recommended that you do not keep valuable items in your locker, as the Company will not be held responsible for any loss that may occur from them. Lockers are to be kept clean and clear of clutter. No items of food should be kept in your locker as it encourages cockroaches and other pests. Locker keys must be returned at the completion of your employment. In the event of an emergency, potential risk of site security or in instances where an employee leaves the company not having returned their locker key, the company reserves the right to access that employee’s locker & retrieve the contents. A list will be made of any items of personal property as retrieved and these will be held by the Human Resources Department for a period of three months, after which they will be disposed of at the company’s discretion.

Personnel Records You should let the Payroll Office know if there is any change to the basic personal information you provided on your original employment application. In particular, the Payroll Office should always know your home address and phone number, next of kin, and whom to contact in an emergency. Bega Cheese recognises that it may acquire sensitive personal information about you, such as about your health in relation to a workers compensation claim. There are very strict confidentiality rules about the handling of personal information and therefore access to personnel files is closely controlled.

Confidentiality and Media In the course of your employment you may become aware of sensitive commercial or technical information. This information is confidential and valuable and as an employee you have a duty to maintain the confidentiality of this information. You may be asked to sign a confidentiality agreement when you start with Bega Cheese, but even without such an agreement Bega Cheese has the right to take legal action if you deliberately reveal confidential information without permission. All records, documentation, notes and other information, in full or in part, obtained during the course of employment will be treated as confidential and remain the exclusive property of Bega Cheese and are not to be used for personal gain or to cause harm to the Company. No records, documentation, notes or other information shall be duplicated, copied or removed in any way whatsoever from the Company’s premises, unless expressly approved by your Department Manager.

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You should develop an attitude of discretion towards Company information, even if it does not seem, to you, to be sensitive or important. Make it a rule not to discuss Company matters with outsiders or in a public manner. Parts of our business can be newsworthy at times, attracting interest from all areas of the media, especially in the local region. Public statements can only be made by the legally authorized spokespersons. If you are approached for a comment by any representative of the media, politely decline and refer the enquiry to your Manager.

Employee Identification To enhance employee security & protection of confidential information, Bega Cheese maintains individual photographic images of all of its employees within a database managed & accessed only by the HR Department. These images are primarily used by the Human Resources Department as a necessary aid in identifying individual employees, thereby ensuring that confidential information is not released or conveyed inappropriately. The provision of your photograph to support payroll & related security information is a condition of employment & Bega Cheese will arrange for the taking of your photograph, at no cost to you. In addition, the Company may, from time to time, wish to publicly display or publish such photographic images within its business, including on screens, noticeboards & in newsletters or other publications (both internal & external), acknowledging or promoting its business activities & or the achievements of its employees. If you do not accept this possible use of your photo for other than payroll identification purposes, then you will need to formally advise the Human Resources Department in writing of this.

Motor Vehicles

If you are allocated a Company vehicle, you will receive a copy of the policy covering its use with your letter of appointment. When using company vehicles, employees must hold an appropriate Licence. Employees allocated a Company Motor Vehicle are responsible for its general care and welfare and in particular for :

• ensuring that company vehicles are not used in a way that will jeopardize the safety of others or themselves, or that would reflect badly on the company;

• maintaining the Vehicle in a clean and tidy condition at all times, at their own expense; • ensuring that the vehicle is not used for hire or reward, racing, or participation in any rally,

reliability trial or competition, carrying of commercial loads (except where specifically acquired for that purpose) or other inappropriate or unauthorized purpose; and

• ensuring the vehicle is not pledged, pawned or used as security or misused in any other way.

• Employees allocated a Company Motor Vehicle are responsible for ensuring that:

• oil, water and battery levels are checked and tyre pressures adjusted on a regular basis and that necessary steps are taken to correct problems identified; and

• that all Scheduled Maintenance is carried out and that all faults are reported and rectified.

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If a company motor vehicle is involved in a traffic accident, it is the responsibility of the employee in charge of the vehicle at the time of the accident to abide by the traffic regulations of the applicable State or Territory. The Employee should co-operate with the authorities involved (if any) but should not admit liability for the Accident.

Use of Private Motor Vehicle on Company Business

Company vehicles, rather than private vehicles, should be used for Company business whenever possible. If a Company vehicle is not available, and consequently a private vehicle is used for approved Company business, then subject to your Manager’s approval, the Company will pay an allowance based on kilometers travelled.

Traffic Fines and Motor Vehicle Insurance Employees driving a Company Motor Vehicle must at all times drive carefully and observe local State Traffic Regulations. Employees are personally responsible for fines resulting from any Infringement of the law committed while operating company motor vehicles , including parking offenses. In addition, employees driving company motor vehicles will be liable to pay the excess relating to any insurance claim, where damage to the vehicle (or property of a third party) was due to their negligence or the incident results in an infringement notice being issued by the Police or subsequent conviction of an offence by a Court. The Human Resources Manager shall be the final arbiter in such matters. Bega Cheese maintains comprehensive Motor Vehicle Insurance but employees must be aware of and drive within the limitations set out in the Company's Motor Vehicle Insurance Policy. In particular, an employee driving a Company Motor Vehicle must understand that the Motor Vehicle Insurance Policy specifically excludes cover for damage incurred in an accident where:

the vehicle was being driven by a person under the influence of liquor or drugs

the vehicle was mechanically unsafe or overloaded and/or

the vehicle was being driven by an unlicensed or disqualified driver Where an insurance claim is denied on any of the above grounds, the employee may be subject to dismissal for misconduct and the appropriate action necessary for Bega Cheese to recover all costs and damages associated with the incident shall be taken.

Site Access In most areas of the business you will need a personal swipe card to enter through an employee entrance.

you should take very good care of this important card and if you lose it, report this immediately to your Supervisor so your old one can be cancelled and a new one issued to you;

never lend your card to anyone else, even another employee;

for some areas, you will be issued with a PIN to gain out-of-hours access. Always keep this confidential and never give this PIN to anyone else, even another employee.

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Company Computer Use The company provides computers to various employees for their use in undertaking their required duties. It is the responsibility of mangers to ensure that where an employee requires access to company computer equipment that such access is coordinated through the IT Department, thereby allowing the IT Department to ensure that employees have appropriate access & published from time to time. Key policy requirements pertaining to the use of the company computer equipment include: Employees may only access those system areas for which they have authority;

employees using company computer systems must use their approved access passwords & such passwords should not be divulged to other employees for any reason;

employees must not provide access to the company’s computer systems to other employees without the prior approval of their manager & the IT Department;

employees must not remove computer equipment from the company’s premises without the prior approval of their manager & IT Department, the exception being for laptop computers specifically issued on the understanding that they may be transported away from company premises for express business purposes;

where an employee is authorized to take computer equipment away from company premises for business reasons, that employee shall be responsible for the safe-keeping of such equipment whilst it is in their care, custody & control. In the event that such equipment is lost or damaged, the responsible employee must immediately report the details of the matter to their manager & the IT Department;

the IT Department is responsible for the deployment, configuration & maintenance of all company computer equipment & software & under no circumstances should any non IT Department employee interfere in any way with any such hardware or software, including adding, removing/deleting or copying any hardware or software;

any operational difficulties relating to the use of computer hardware of software should be immediately reported to the designated IT support personnel for attention;

employees area responsible for ensuring that the computer equipment allocated to them is kept clean & dust free & that the equipment is shut down when not in use.

The company reserves the right to monitor employee usage of company computer equipment & software, & where abuse is detected, the employee concerned will be subject to disciplinary action.

Email/Internet Use Where the company provides employees with access to email or the internet, such access is provided for business purposes & the company expects that such employees will not abuse such access by engaging in non-business related activities. More particularly, employees with such access must not access, download, forward or install material:

that could reasonably be perceived to be offensive or demeaning;

that could reasonably be perceived as sexually explicit;

such as games or software;

such as graphics, pictures, logos, documents etc that may be covered by copyright or trademark laws, without permission of the owners.

should you leave or enter the site premises, you must swipe on and off as this will assist in situations of where an emergency evacuation takes place

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In addition, employees with such access must not:

access non Bega Cheese email accounts;

access chat programs or instant messaging programs;

attempt to test probe or illegally access another organisation’s computer system or internet site. The company reserves the right to monitor employee usage of email & the internet, including content, & where abuse is detected, the employee concerned will be subject to disciplinary action.

Telephone /Mobile Usage Where the company provides employees with access to a telephone or mobile telephone, such access is provided for business purposes & the company expects that such employees will not abuse such access by the unreasonable use of such equipment for non-business related activities. The company accepts that there may be occasions where it is necessary & desirable for an employee to use a company telephone for personal reasons, including in emergencies or when an employee is away from home on company business. Employees are also expected to use their common sense in such matters. It is the responsibility of employees:

to take good care of all company property, including tools, uniforms, machinery, keys, passes, mobile phones and computers;

not to remove company property from company premises without prior authorization;

to immediately report all property damage, losses and evidence of theft to their Supervisor/Manager.

Bega Cheese expects that its property, including tools, telephones and computers, shall only be used for business purposes, although the company accepts the occasional personal use of telephones and computers, in particular where an employee may be traveling on behalf of the company or in an emergency.

Personal items in Operational Areas With the exception of electronic devices specifically issued by the company for use in operational areas, no mobile phones, iPods, cameras or other electronic devices which may be used to listen to music, play games, send and receive text and email messages, voice and video calls, record pictures, access Facebook or other internet sites, upload information and/or undertake other activities may be taken into operational areas, including Production, Laboratory, Maintenance & Supply Chain. No magazines or books, live plants, flowers or animals should be taken into operational areas, including Production, Production Offices, Corridors opening directly into Production areas or areas that share a common air supply with Production areas, Laboratory, Maintenance & Supply Chain.

Personal Property In cases of loss of or damage to an employee’s personal property whilst engaged at Bega Cheese, it is the policy of Bega Cheese that it will not usually compensate employees for any loss or/damage. However,

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Bega Cheese reserves the right to consider special circumstances which may influence the application of this policy. Personal property includes, but is not limited to, clothing, electrical/communication devices, motor vehicles and spectacles.

Illegal drugs and Alcohol Bega Cheese has a ‘zero tolerance’ policy in respect of illegal drugs in the company property. The consumption, sale of, or being under the influence of illegal drugs whilst on duty or on company property is prohibited at all times. The consumption or sale of alcohol in the workplace is prohibited, without the express prior permission of a member of the executive management team. Being over the prescribed legal limit of alcohol whilst on duty or on company property is prohibited at all times and employees must also comply with any other regulatory requirements. Where a problem with drugs or alcohol is suspected then the suspicion should be reported to the appropriate Supervisor. It is the company’s policy not to condone a “code of silence” on these issues, but to acknowledge such problems and provide an appropriate course of action before the problem results in the necessity for disciplinary action. The company’s principle concern is always the safety & well-being of its employees. Introduction of random drug and alcohol testing in the workplace to augment and reinforce this process is currently under review. Where a Supervisor or Manager reasonably forms the view that an employee is adversely affected by either drugs or alcohol whilst at work, the Supervisor will (with the involvement of at least one other company Supervisor or Manager) raise the issue with the employee and (subject to the nature and outcome of that discussion) may immediately require the employee to stand down from their duties pending further instruction. If there is a threat of violence or damage to property the Police should be called immediately. Where an employee has been required to stand down from their work station, the responsible Supervisor or Manager will, as soon as possible, liaise with the company’s OH Coordinator (and /or company doctor if available) & HR Manager to agree further action, which may result in a decision to suspend the employee, pending further investigation of the matter. In the event that the company’s OH Coordinator & HR Manager are not available, the responsible Supervisor or Manager may suspend the employee, pending further investigation of the matter. Where an employee is suspended, the responsible Supervisor or Manager will make every reasonable effort to arrange for the employee to be taken home. Where an employee is instructed to stand down from their work station or is suspended, they will be paid for the remainder of their normal shift, pending a full investigation of the incident & any subsequent disciplinary action, which may result in a loss of pay for hours not worked. Serious breaches of the company’s drugs & alcohol policy may result in an employee being dismissed & where warranted, the incident being referred to the Police.

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Prescribed drugs Prescribed drugs and medication can cause drowsiness and other symptoms, and therefore reduce the person’s ability to function safely. Where an employee is directed to take prescription drugs by a medical practitioner, it is the responsibility of the employee to ascertain whether such drugs may impair their ability to carry-out their normal duties, without jeopardising their safety & well-being or that of their colleagues. If they are taking such medication it is mandatory that the employee notifies their Supervisor before commencing work so the Supervisor has the opportunity to liaise with the OH Coordinator or company doctor for advice on their fitness to carry out their normal duties safely. In the absence of this advice (i.e.: after hours) if there is any concern about the safety of that employee or his/her work colleagues, then the Supervisor must:

Call the police if there is a threat of violence or damage to property

Send the employee home (if necessary driven/accompanied by another staff member) or

Provide alternative duties to the affected employee; and

Discuss the matter with their Manager and/or Human Resources staff at the earliest opportunity.

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10. SITE SPECIFIC OBLIGATIONS

Product Tampering It is the responsibility of all employees to assure that our food products are safe for our consumers. Any intentional act by an employee which could render a Bega Cheese Limited ingredient, product, or package unsafe for consumers will result in termination of the employee. The Company will pursue all legal remedies, but not limited to, criminal prosecution.

Employees who observe any intentional act which might compromise the safety of any ingredient, product or package are required to immediately report this activity to their supervisor or manager.

Badges and ID Cards Use of badges and clip-on identification (ID) cards are permitted according to local Site security policy and must be worn below the waist. Visitor identification badges are permitted but must not be a source of contamination at the plant.

Buttons, service pins or similar articles are not permitted on uniforms, smocks, bump caps, or hard hats.

Traffic Patterns Employees must follow the established traffic patterns and controls to prevent microbial cross contamination within the manufacturing site.

Housekeeping Littering and other poor housekeeping practices are not allowed. All refuse must be placed in properly identified containers.

Lunch Storage Lunches must be stored in designated areas. Lunches must be completely enclosed in cleanable and /or reusable containers, or in single-use packaging (e.g., cling wrap and/or lunch paper bag.

Lockers Personal lockers must be maintained free of trash and soiled clothing. Inspection and cleaning of lockers must be scheduled routinely. Foods and direct product contact tools must not be stored in employee lockers.

Storage facilities of sufficient size to accommodate all reasonable personal items shall be provided for all personal who work in raw material handling, processing, preparation, packing and storage areas.

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11. EMPLOYMENT CONDITIONS

The Human Resources department is responsible for managing and coordinating the employment relationship between Bega Cheese and its employees, helping to provide a positive environment in which Bega Cheese staff can work effectively to achieve their goals.

The main activities of the department are:

Recruitment and selection

Employee induction

Training and development

Employee relations

Equal employment opportunity (EEO), and affirmative action (AA)

Employment contracts

Conditions of employment

Occupational health and safety

Workers Compensation and Rehabilitation

Performance management and counseling

Wage, salary and benefits management

Superannuation fund matters If you want to discuss any aspect of your employment, talk over any thoughts you have about your career path with Bega Cheese, or raise any other issues or concerns, please initially contact your Supervisor or Manager. The Human Resources Department can provide additional support and advice when required.

Employee Relations Our productivity, efficiency, and competitiveness depend very much on the quality of the relationship between the Company and its employees. It is vitally important that we all have a commitment to achieving the Company’s objectives and that we all work to a shared purpose and to common standards. To this end, we want all employees to be informed about new developments, to have the opportunity to participate in decision-making processes, and to provide comments, suggestions, and opinions. Employees, for their part, must be prepared to contribute positively to the Company’s purpose. We have established a number of formal and informal systems to keep employees informed about Bega Cheese’s goals, plans, financial achievements, staff changes and relationships with customers and suppliers.

These include: • Publications- (newsletters, supplier circulars, annual reports, etc.) • Department and line/shift meetings • Work section meetings • Consultative Committees • Notice Boards / Communications Screens & Communication Folders • Staff Briefings

To keep yourself informed please ensure you read the publications and notice boards regularly and participate in meetings whenever you have the opportunity.

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Continuous Improvement It is essential to Bega Cheese’s continuous improvement of products and processes that all workplaces and employees operate flexibly, without restrictive work practices, work barriers and limitations on gaining new skills.

To this end:

• You may be directed to carry out any duties that are within your skill, competence and training. • You may be directed to use any tools or equipment, provided you have been trained in their use. • You may be directed to work in other areas, provided you have the appropriate skills.

Workplace Consultation We want to further develop and maintain an atmosphere of mutual trust, respect and co-operation in the workplace. We seek to consult with all employees, to enable them to express their views, to contribute to problem solving, and to influence planning and decision making on matters that will affect their work. Joint Consultative Committee, with representatives from both employees and management, have been established at all company work sites, with the exception of Coburg. The committee aims generally to improve workplace relations and create a culture conducive to achieving the Company’s objectives and meeting the aspirations of its employees. One of the main tasks of the committee is to monitor the Industrial Agreement relevant to the particular site and to promote ideas and avenues for improved workplace relations. You may wish to become a member of a Trade Union, which can be arranged through your Union representative. Bega Cheese respects the right of employees to join a Trade Union.

Industrial Agreements If relevant to your position, you will be provided with a copy of the relevant Industrial Agreement on joining Bega Cheese and you can access it via our web-site. An Agreement is a legally binding document that details the employment relationship and conditions for all non-salaried employees of Bega Cheese. Your employment is subject to your contract of employment which, in turn, reflects the requirements of any relevant Industrial Agreement to which Bega Cheese is a registered party, in addition to any Federal and State Legislations and common law.

Contract of Employment

The Human Resources Department issue letters of appointment to every employee before they start work with the Company. This letter sets out your terms and conditions of employment, such as:

Employment relationship (full-time, part-time, casual, or contract)

Commencement date,

Wages or Salary, including payment method

Benefits,

Rules and policy adherence,

Location

Probation period

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This letter of appointment is your contract of employment. You will be given a new letter if you change positions within the Company or if your employment arrangements are varied. Your employment is subject to your contract of employment which, in turn, reflects the requirements of any relevant Industrial Agreement to which Bega Cheese is a registered party, in addition to any Federal and State Legislation and common law.

Position Descriptions A position description is a document setting out why a position exists and what is expected of the person who fills it. The Human Resources Department uses position descriptions when recruiting new employees. It is the objective of Bega Cheese that all employees are issued with a position description upon commencement. Employees will use the position description as their primary statement of duties, responsibilities, reporting relationship and authority. Due to the ever-changing nature of the business and its operations, your position description may be revised at any time during your employment. However, where this is required it will usually involve only certain aspects of your role and will usually occur in consultation with you.

Induction Induction is the process of settling a new employee in their position with Bega Cheese. Its purpose is to provide you with general information about the Company and about the work site and department where you will be working; and to provide training in the job you will be doing in your specified work area. The process of Induction may vary site to site, but will include:

Company Orientation

• Contract of employment • Employee Handbook

Site, Department

• Site facilities • Policies and rules • Safety and Emergency Procedures • Work area familiarisation including risks /hazards • Equipment and machinery • Arrangements for on-the-job training, including details of the “buddy” system & involvement of

Employee Support Officer (ESOs) • Review and evaluation of performance to conclude probationary period

Leave and other Absences from Work You have a responsibility to the Company and to your fellow employees to minimise, if you can, any disruption or inconvenience that your absence from work might cause. In particular, if you will be away for an extended period, such as annual, long service or parental leave, the Company needs time to plan for your absence.

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The following leave provisions apply to all Bega Cheese employees however, in the case of employees covered by Industrial Agreements, any leave provisions in such Agreements will apply to the extent of any inconsistency.

Permanent Employees If you are going to be away from work, for any reason, you are expected to contact your Supervisor or department Manager. In general, you apply for leave by filling in an “Application for Leave” form, and giving it to your Supervisor or Manager for approval. In some cases you must attach supporting documents to your application.

Annual Leave Permanent, full-time employees are entitled to four weeks leave each year. This entitlement commences after 12 months continuous service. If you are specifically covered by an Industrial Agreement you will be paid a leave loading of 17.5 percent, which is calculated as a percentage of your normal pay. Your entitlement accumulates if you don’t take the leave when it falls due. However, you are required to take your leave each year, unless you have made other acceptable arrangements due to unusual personal circumstances. Your request for leave will be accommodated whenever possible, however due to the size of the workforce and departmental operational needs and the practice of annual plant shutdown, this may not always be possible. In most departments you will need to complete an “Annual Leave Form”, which must be authorised by your Supervisor. Your leave application form should be approved and signed off by your Supervisor/Manager and then sent to the Pay Office at least 2 weeks before you commence your leave. Leave loading pay is deposited into your bank account with your normal pay. If you have any accumulated leave entitlement on termination of employment you will be paid for it.

Personal, Sick and Carer’s Leave Bega Cheese employees have an excellent record of attendance over the Company’s history and their loyalty has at times been recognised and rewarded by providing generous support to employees with prolonged illness. Sick leave is provided for times when you are too ill to work. You are entitled to 10 days sick leave each year and your unused entitlement accumulates. Letting your sick leave accumulate has the advantage of providing a supply of paid leave in case you have a long period of unexpected illness. You must advise your Supervisor of absences due to illness at the earliest opportunity and a medical certificate or statutory declaration may be requested. Employees with certain diseases and conditions will not be permitted in the plant because of their infectious characteristics. They include Glandular Fever, Ringworm, Impetigo, Scabies, Head lice and other communicable diseases. Employees suffering from any of the above must have a clearance from their Doctor before returning to work. If you are in doubt about this situation at any time during your employment then please speak to your Supervisor before returning to work.

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Long Service Leave With the exception of pro-rata payment upon termination, long service leave is in accordance with the NSW Long Service Leave Act and the Victorian Long Service Leave Act (1992). You may request pro-rata long service leave after ten years’ service. An eligible employee may request the taking of long service leave on a half pay, thereby extending the period of leave to twice that which would be available on full pay.

If you are employed in NSW and you leave the company after five or more years of service, then you are entitled to be paid your long service leave on a pro-rata basis. If you are employed in Victoria and you leave the company after 7 or more years of service, then you are entitled to be paid your long service leave on a pro-rata basis, except where you are employed under an Industrial Agreement, in which case your long service entitlements will vest on the attainment of 10 years’ service.

Parental Leave You are entitled to leave in relation to the birth or adoption of a child if:

You have 12 months continuous service with the Company, and

You will be the child’s primary caregiver.

Parental leave is for a maximum of 52 weeks. This period may include annual and long service leave, as well as up to 8 weeks paid maternity leave in the case of a woman and 1 weeks paid paternity leave in the case of a partner. The balance of the parental leave period is unpaid. The provision of paid maternity and paternity leave is subject to additional conditions, with full details available from the Human Resources Department.

Absence on parental leave is not considered an interruption to your continuity of service, but the leave is not included in calculating your length of service, nor do you accrue any leave entitlements during the leave period. When you return from parental leave, the Company will make your former position available if possible; if not, we will find another position for you as close as possible in status and pay to your former position. Further details outlining conditions and entitlements are available from the Human Resources Department.

Breastfeeding Bega Cheese has designed a breastfeeding policy to ensure consistent and effective support is provided to employees returning to work form maternity leave. This policy provides employment conditions and information in relation to lactation breaks, breastfeeding facilities and the provision of other resources.

Bereavement /Compassionate Leave You are entitled to paid leave following the death of a member of your family.

Near/Close relative – up to three days leave

Other relatives – up to one days leave

For the purposes of Bereavement/Compassionate Leave, a ‘near/close relative’ shall include a parent or step-parent, spouse (including de facto), child (including step child), brother, sister, mother-in-law or father-in-law, son-in-law, daughter-in-law, brother-in-law, sister-in-law, grandfather, grandmother or grandchild.

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Should an employee be on Annual Leave at the time Bereavement Leave is sought, upon presentation of proof of death, the company shall reinstate the equivalent amount of such Annual Leave to the employee concerned.

Jury Service An employee require to attend for jury service during his/her normal working hours shall be paid their normal wage, including all entitlements and allowances, as if they had worked their normal hours, however, in return they are required to reimburse the company by cheque or in cash the full amount of any payment they receive from the Crown for performing such jury service.

Military and Community Service Leave You are entitled to leave if you are taking part in voluntary military training with the armed forces. You must provide documentary evidence of the training, and of any payment you receive for it. Requests for leave for community service in emergency situations, such as rural fire service call out will be considered on an individual basis and will take into consideration the length of absence, the geographic location/area and the urgency of the situation

Study Leave Bega Cheese regularly supports employees who participate in external studies for their professional development. Requests for study leave to assist with your preparation for examinations will be considered on an individual basis, taking into account the relevance of the proposed studies to your current role and your intended career path within the business.

Leave Without Pay (LWOP) Should an employee require additional leave beyond their paid entitlements, applications will be considered on an individual basis and approved at the discretion of the responsible Supervisor/Manager and the Human Resources Department.

Circumstances where such additional unpaid leave may be approved include illness, family obligations, study and extended travel. As a general guideline, requests for LWOP will not be approved where the employee has existing leave entitlements available to be used.

Whilst Bega Cheese will provide employment for employees returning from LWOP, employees must understand that the company, for operational reasons, may not be able to offer ongoing employment in the same or similar position/level held by the employee prior to their commencing such leave, or in the same area of the company or the same hours of work.

Discretionary Leave In circumstances where genuine need or hardship arises, an employee shall be entitled to request leave at the discretion of the CEO. Such leave may be with or without pay, depending on the surrounding circumstances. Applications for Discretionary Leave should be submitted to the Human Resources Department.

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Public Holidays Bega Cheese employees are entitled to paid leave on the following statutory Public Holidays:

New Year’s Day

Australia Day

Good Friday

Easter Saturday & Easter Monday

Anzac Day

Queen’s Birthday

Labor Day

Melbourne Cup Day – Victoria only

Christmas Day

Boxing Day

Casual Employees Whilst Bega Casual employees are not entitled to paid annual leave or sick leave, they are required to advise their Shift Coordinator or Supervisor in advance of their non-attendance for rostered work or if they are not available to be rostered or called-in for work.

If a Bega Casual employee does not attend work when rostered and fails to notify their Shift Coordinator/Supervisor in advance of their non-attendance, or is unable to offer an acceptable reason for not having done so, the company reserves the right to review the employee’s ongoing employment and may elect to terminate the services of that employee.

Except in circumstances of illness, injury, family emergency or pre-agreed study commitments, where a Bega Casual employee is unavailable for work for more than one (1) week, whether having notified the company in advance of their unavailability or otherwise, the company reserves the right to review the employee’s ongoing employment and may elect to terminate the services of that employee. Where a Bega Casual employee is unavailable for work for more than two (2) weeks for any reason whatsoever, whether having notified the company in advance of their unavailability or otherwise, the company reserves the right to review the employee’s ongoing employment and may terminate the services of that employee.

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12. FAIRNESS @ WORK

Whistleblower Policy The Whistleblower service is an independent, confidential telephone, email and mail service that provides an effective channel for employees to blow the whistle on workplace misconduct. This service allows you to report misconduct like:

Theft

Fraud

Breaches of policy/procedures

Discrimination

Harassment/bullying

Workplace safety and environmental hazards

Misconduct or other unethical behaviour You can call the whistleblower service on 1800 173 918 24 hours, 7 days a week. In addition, an email service [email protected] is available 24 hours a day. Alternatively, send your complaint or concern to: Bega Cheese – Deloitte Whistleblower Service, Reply Paid 12628, A’Beckett Street, Melbourne, Victoria 8006 or Fax: 9691 8182. For further information on this service please go to www.whistleblower.deloitte.com.au

Equal Employment Opportunity (EEO) The purpose of this Policy and Procedure is to inform Bega Cheese employees about the company’s support of the following principles regarding Equal Employment Opportunity:

employment for all employees should be dealt with on the basis of merit;

workplace consultation between the company and its employees to promote an awareness and understanding of issues concerning Equal Employment Opportunity; and

provision of workplaces where employees are treated with fairness and respect. Bega Cheese recognises that all employees have the right to work in an environment free of discrimination. In order to meet its obligations under this policy, the company will promote equal opportunity in all aspects of its activities.

What is Discrimination? Discrimination occurs where a person is treated unfavourably in their employment because of an attribute they possess that is covered by equal employment opportunity laws. There are two types of discrimination. ‘Direct discrimination’ occurs where a person, or a group of people, is treated unfavourably on the basis of a characteristic listed as a ground of discrimination. ‘Indirect discrimination’ occurs when there is a requirement that is the same for everyone, but has a disproportionate effect or result on one particular group of people that can be linked to a discriminatory

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ground (as outlined below). Indirect discrimination will not occur if the requirement is reasonable in the circumstances. The attributes that are covered by equal employment opportunity laws are set out below. It is unlawful to discriminate against a person in any area of their employment. This includes recruitment, terms and conditions of employment, promotion, transfer, training, leave and termination of employment. Discrimination is also unlawful in the provision of goods and services, which means that workplace participants must not discriminate against or harass customers or clients of Bega Cheese. Intention to discriminate is not a requirement for unlawful discrimination. Accordingly, a person can discriminate against another person even if they did not intend to do so. It is not discrimination where such an attribute is relevant to the genuine requirements of a position. It is unlawful to discriminate against a person on the basis of any of the following grounds of discrimination:

race, colour, descent, ethnicity, national or social origin

sex

pregnancy or potential pregnancy

breastfeeding

parental or carer’s status

employment activity

industrial activity

marital status

sexual orientation, gender identity, lawful sexual activity

medical records, disability or impairment

HIV/AIDS

age

political belief or activity

criminal record, spent conviction

physical features

religious belief or activity

association with or relation to anyone with one of the above attributes The company’s policy should be interpreted to include all attributes protected by commonwealth and state anti-discrimination legislation.

Systems and Education Systems will be developed, implemented and monitored as outlined in this policy to support a workplace environment that provides equal employment opportunities for all employees. The company will develop and implement a Grievance and Dispute Management Policy and Procedure to ensure that all complaints and issues regarding Equal Employment Opportunity are investigated promptly, fairly, impartially and confidentially.

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EEO Communication & Training An Equal Opportunity communications and training strategy will be developed and implemented to ensure all employees, team leaders, shift coordinators, shift supervisors and managers are aware of this policy and their rights and responsibilities. Compliance audits will be carried out from time to time, as determined by the company, to ensure that this occurs. Equal Opportunity principles will be built into the systems used by the company in considering recruitment or opportunities for promotion, transfer or training, or any other benefits associated with employment, for employees; All company Employee Support Officers (ESOs) will be designated Contact Officers for the purposes of this policy and shall be available for any employee to approach regarding any Equal Opportunity concerns or issues. The names and contact details of Contact Officers will be publicised and displayed throughout the

organisation.

Harassment, Sexual Harassment and Bullying The purpose of this Policy and Procedure is to inform Bega Cheese employees about specific behaviours that are not acceptable in the workplace and their rights and responsibilities in relation to these. Bega Cheese recognises that all employees have the right to work in an environment free from harassment, sexual harassment, bullying, victimisation and vilification. Harassment, sexual harassment, bullying, victimisation and vilification are behaviours that are not consistent with the values of Bega Cheese and are therefore unacceptable and will not be tolerated under any circumstances. Bega Cheese will take action against any employee who is found to have breached this policy. This policy applies to all employees, agents, consultants and contractors (including temporary contractors) (“workplace participants”) of Bega Cheese. This policy is not limited to the workplace or work hours. The policy extends to all functions and places that are work related. A work related function is any function that is connected to work, for example, work lunches, conferences, Christmas parties and client functions. Workplace participants must comply with this policy at all related functions. This policy also applies when workplace participants go to other workplaces in connection with work, for example, when visiting a customer or client. This policy reflects Commonwealth and State equal employment opportunity laws that make it unlawful for any workplace participant to engage in conduct that discriminates against or harasses another person in the workplace. In some circumstances, workplace participants can be held legally responsible for their own behaviour. In circumstances where a workplace participant’s behaviour or conduct may involve a breach of law, Bega Cheese may notify the police or other relevant authority.

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Consequences of Breach All workplace participants are required to comply with this policy at all times and Bega Cheese is committed to assisting its workplace participants to comply with the terms of this policy. If an employee breaches this policy, they will be subject to disciplinary action. In serious cases and situations where employees continue to breach this policy and/or the law, consequences may include termination of employment. Agents and contractors who are found to have breached this policy may have their contracts with Bega Cheese terminated or not renewed. If Bega Cheese considers it appropriate, workplace participants may be stood-down or suspended, with or without pay, during an investigation. Immediate disciplinary action will be taken against any workplace participant who victimises or retaliates against a person who has complained of harassment, discrimination or bullying. This includes conduct such as glaring at a person with the deliberate intention of making them feel uncomfortable, spreading rumours, yelling at that person, etc.

Harassment Harassment is unwelcome conduct based on one of the following attributes that causes a person to be offended, humiliated or intimidated.

race, colour, descent, ethnicity, national or social origin

sex

pregnancy or potential pregnancy

breastfeeding

parental or carer’s status

employment activity

industrial activity

marital status

sexual orientation, gender identity, lawful sexual activity

medical records, disability or impairment

HIV/AIDS

age

political or religious belief or activity

criminal record, spent convictions

physical features

association with or relation to anyone with one of the above attributes Intention to harass is not a requirement for unlawful harassment. Accordingly a person can harass another person even if they did not intend to do so. Harassment can be a single or repeated act of offensive behaviour. It can be physical, verbal, non-verbal, written or visual. There is no requirement for a person to advise the alleged harasser that their behaviour is unwelcome and/or is causing the person to feel offended, humiliated or intimidated by that behaviour before making a complaint. Harassment does not have to be directed at a particular individual to be unlawful. Behaviour which creates a hostile working environment for other workplace participants can also be unlawful. Inciting

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hatred towards or vilifying another person ie: because such a person is of a particular race or religion is a serious breach of anti-discrimination laws and will be dealt with accordingly by Bega Cheese. The effects of harassment may include:

creating an intimidating, hostile or offensive working environment;

adversely affecting a person’s work performance;

adversely affecting a person’s employment; and

reflecting negatively on the reputation of Bega Cheese.

Sexual Harassment Sexual harassment is the most common form of harassment that occurs in the workplace. Sexual harassment is unwelcome conduct of a sexual nature that is likely to result in a person feeling offended, humiliated or intimidated. Conduct can amount to sexual harassment even if the person did not intend to offend, humiliate or intimidate the other person. However, conduct will not be sexual harassment if a reasonable person, having regard to all the circumstances, would not have anticipated that the conduct would cause offence, humiliation, or cause the person to feel intimidated. Sexual harassment is not behaviour which is based on mutual attraction, friendship and respect. If the behaviour is consensual, welcome and reciprocated, it is not sexual harassment. Sexual harassment can involve a series of incidents or it can be an on-off occurrence.

Sexual harassment may include conduct that occurs in the workplace or in connection with work, for example, at a Christmas party or at a work-related function outside work hours. A person can be sexually harassed by a supervisor or manager, co-worker, contractor, service provider, client or customer. Sexual harassment laws cover harassment against both men and women, and between people of opposite sex or the same sex. Generally sexual harassment involves a pattern of unwelcome behaviour. However, one act is sufficient to constitute sexual harassment. Bega Cheese recognises that workplace participants may have different standards of acceptable behaviour ie: what is acceptable to one person may not be acceptable to another. Bega Cheese therefore expects that all workplace participants will adhere to a standard of behaviour that would be considered to be acceptable to all reasonable workplace participants. It is a criminal offence to sexually assault or threaten to sexually assault another person and there are serious repercussions for doing so in the workplace.

Bullying

Workplace participants have a right to work in an environment where they are not subjected to bullying behaviour. Such behaviour impacts upon the productivity and wellbeing of the person being bullied and others who witness it. Bullying is a form of harassment that can be a criminal offence, and will not be tolerated by Bega Cheese. Any workplace participant who engages in bullying behaviour will be subject to disciplinary action, which may include termination of employment.

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“Bullying” is repeated, unreasonable behaviour directed towards a person or group of persons that creates a risk to health and safety. It includes behaviour that could be expected to intimidate, offend, degrade, humiliate, undermine or threaten. Unreasonable behaviour means that a reasonable person, having regard to all the circumstances, would expect to feel victimised, humiliated, undermined or threatened as a result of the behaviour. “Repeated unreasonable behaviour” refers to the nature of the behaviour, not the specific form of that behaviour. “Repeated unreasonable behaviour” may thus be a pattern of diverse incidents. Bullying behaviour is not confined to the workplace and can occur by publishing information or statements about the person on the internet, by email or text message. Bullying in a workplace can occur at any level of the organisation between:

two or more employees;

manager(s) and employee(s); or

employee(s) and other person(s) at the workplace (apprentices, trainees, contractors, managers).

Formerly agreed behaviour may be found to be bullying when it continues after a request from the recipient for the behaviour to stop, or at the point it becomes intimidating, offensive or humiliating. Bullying can also constitute criminal offences. For example, the Crimes Amendment (Bullying) Act 2011 considers bullying behaviours to be the following:

making threats to a person;

using abusive or offensive words to, or in front of, the person;

performing abusive or offensive acts in front of the person; and

directing abusive or offensive acts towards the person; acting in any other way that could reasonably be expected to cause physical or mental harm to the victim, including self-harm; or to arouse apprehension or fear in the victim for his or her own safety or that of any other person;

Further, a definition of mental harm is inserted and includes psychological harm and suicidal thoughts. A person may apply for an intervention order against the person alleged to have engaged in bullying conduct. If a workplace participant is subject to an Intervention Order, Bega Cheese is obliged to comply with the conditions of the Intervention Order. If the workplace participant is subject to an Intervention Order, there may be instances where it will not be possible and/or reasonable for Bega Cheese to continue its relationship with the workplace participant against whom the Intervention Order has been made. Bega Cheese will act immediately on reports of possible criminal offences.

Conduct that is NOT Harassment, Sexual Harassment or Bullying It is a normal workplace requirement for team leaders, co-ordinators, supervisors and managers to counsel an employee about their work performance or workplace behaviour. Performance counselling (even repeated counselling on the same issue or behaviour when required) is a necessary part of ensuring that staff members meet standards and expectations of work and behaviour. Performance counselling

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undertaken in accordance with the company’s established standards is NOT, harassment, sexual harassment or bullying. Reasonable supervisory and management actions such as disciplinary action, work instructions, and allocation of work in compliance with Bega Cheese’ business needs and systems do not constitute harassment, sexual harassment or bullying.

Vilification

Vilification occurs when a person, by public act, incites hatred towards, serious contempt for, or severe ridicule of, a person or a group of persons on the ground of that person’s or group’s beliefs or because the person or group of persons is a member of a certain group of people ie: because of that person’s race or religious beliefs.

Victimisation

Victimisation occurs when a person singles out another person and subjects or threatens to subject to detriment because that other person has or is believed to have:

made a complaint about them;

given information or documents to any relevant person or body about them;

asserted the rights of any person under equal opportunity legislation; or

alleged a breach of equal opportunity legislation.

Victimisation can also occur when a person subjects or threatens to subject another person to detriment because that other person proposes to do any of the above.

It is unlawful to retaliate against a person just because that person wishes to make a complaint of discrimination or other unlawful conduct under equal opportunity legislation.

Examples of a detriment in employment may include:

demotion;

dismissal;

transfer;

suspension; or

loss of a benefit.

Alcohol and Functions All employees of Bega Cheese have a responsibility to behave in a professional and appropriate manner at company and client functions or social events. Alcohol consumption is no excuse for behaving inappropriately and employees have an obligation to ensure that they practice responsible consumption of alcohol at all times. A breach of this requirement may result in disciplinary action. Full details on the company’s policies on alcohol, illegal and prescribed drugs may be found on Page 42 of this handbook.

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Systems and Education Systems and education that will be put in place to ensure a workplace environment free from harassment, sexual harassment and bullying will include the following:

training and awareness-raising strategies from time to time, as determined by the company, to ensure that all employees are aware of both this policy and the company’s Grievance and Disputes Management Policy and Procedure;

grievance and dispute management procedures which are based on the principles of natural justice and procedural fairness;

treating all grievances in a sensitive, fair, timely and confidential manner;

acting against victimisation; and

encouraging the reporting of behaviour which breaches this policy. The company will develop, implement and monitor a Grievance and Dispute Policy and Procedure, so as to ensure that all complaints and issues regarding harassment, sexual harassment, bullying and intimidation, including physical violence, are investigated promptly, fairly, impartially and confidentially.

Harassment, Sexual Harassment and Bullying Education and Training The company will develop a communications strategy to inform, instruct and train employees, contractors and site visitors, so that they are aware of company policies and work standards, and understand their responsibilities. This may include Training, Induction Programs, Posters, Pamphlets and Newsletters. The company will promote a corporate culture that is supportive of the above systems, policies and procedures. This may include:

encouraging open and timely communication in the organisation, where people are encouraged to raise concerns and promote discussion of issues;

leadership training and support for team leaders, shift coordinators, supervisors and managers to ensure their management styles are consistent with the principles enunciated in this policy;

As an Occupational Health and Safety (OHS) (Work Health and Safety Act WHS 2011) requirement, a risk management approach will be taken to prevent bullying and harassment, and risk assessments will be made from time to time;

Consultation with Occupational Health and Safety (OHS) (Work Health and Safety Act WHS 2011) Committee.

The company will consult with, so far as is reasonably practicable, the OHS (WHS) Committee regarding:

the risk management approach to workplace harassment, sexual harassment, bullying and intimidation, including physical violence;

the company’s policy and procedure regarding harassment, sexual harassment, bullying and intimidation, including physical violence, and policies and procedures for resolving grievances in these areas;

the company’s communications strategy to inform, instruct and train employees, contractors and site visitors regarding the company’s policies regarding harassment, sexual harassment, bullying and intimidation, including physical violence.

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The company will regularly provide information to the OHS (WHS) Committee regarding the number of complaints made regarding harassment, sexual harassment, bullying and intimidation, including physical violence; how they were resolved and what control measures were put in place to address underlying risk factors. A Harassment, Sexual Harassment, Bullying and Intimidation communications and training strategy will be developed and implemented to ensure all employees, team leaders, coordinators, supervisors, managers and contact officers are aware of this policy and their rights and responsibilities. Compliance audits will be carried out to ensure that this occurs. All company Employee Support Officers (ESOs) will be designated Contact Officers for the purposes of this policy and shall be available for any employee to approach regarding any harassment, sexual harassment, bullying or intimidation concerns or issues. The names and contact details of Contact Officers will be publicised and displayed throughout the organisation.

Grievances and Dispute Management Bega Cheese is committed to dealing fairly and reasonably with its employees, and aims to foster and maintain positive and effective relations with its employees at all times. The company shall take all necessary steps to promote the resolution of employment-related grievances or disputes as quickly as possible through consultation, co-operation and discussion, so as to minimise the level of industrial disputation and confrontation within its business, avoid interruption to the performance of work and the consequential loss of production and wages, and in order to attempt to resolve any grievances or disputes co-operatively to the satisfaction of all concerned. Bega Cheese shall make every reasonable effort to maintain positive and constructive employee relationships with and between its employees, and to facilitate a safe and harmonious work environment whereby acts of inappropriate behaviour, including unlawful discrimination, harassment, sexual harassment, bullying, intimidation, including physical violence, or any other offensive conduct is not tolerated and where it occurs, is dealt with appropriately. Employee grievances and disputes shall be resolved in accordance with this Policy and Procedure and the company’s Disciplinary Policy and Procedure. The parties involved in grievances and disputes are expected to participate in good faith, have regard to facts and the particulars of the circumstances. Grievances and disputes will be reviewed in the spirit of achieving resolution, procedural fairness, and sensitivity to the parties and confidentiality to the extent possible. Any party to a grievance or dispute has the right to have a support person, including an observer or interpreter, attend with them if being interviewed etc however, any such observer or interpreter is not to participate in the discussions about the grievance itself but rather is only permitted to attend the meeting as a source of support.

Procedures Any employee or group of employees with any work-related problem, complaint, query, misunderstanding or grievance shall notify the Supervisor of the work area as to the substance of the issue, request a meeting with the Supervisor for bilateral discussions and state the remedy sought. The

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Supervisor will make every effort to respond to the notification by establishing a suitable meeting time as soon as possible. If the matter remains unresolved, the employee or employees shall then refer the matter to the manager of the work area. The manager will make every effort to respond by the end of the following business day. If the matter remains unresolved, discussions will take place between the employee/s and a senior manager on the site, together with any support person/s the employee/s choose to have present. The senior manager will make every reasonable effort to respond within two business days. A “senior manager” may include a site Human Resources Manager. If the matter is still unresolved, the employee/s and their support person/s may confer with the CEO or their nominee. At the conclusion of the discussion, the CEO or their nominee must provide a response to the employee's grievance, if the matter has not been resolved, including reasons for not implementing any proposed remedy. If resolution is still not reached, by agreement the dispute shall be referred to FWA or the state Industrial Relations Commission/Tribunal ("the Commission"), for resolution. Any Employees reasonably required to attend a meeting or a hearing at the Commission related to a dispute will not lose any pay for such attendance. During any of the above steps, the employee or employees may have a support person present with them, which may include relevant employee representatives such as a Union. During discussions under this Policy and Procedure the "status quo" will remain and work shall proceed normally and without stoppage or the imposition of any ban, limitation or restriction. "Status quo" shall mean the situation existing immediately prior to the dispute or the matter giving rise to the dispute. It is noted that Bega Cheese and its employees expect genuine safety issues to be resolved as a matter of urgency and that an unsafe work environment obviously would not be accepted.

Grievance arising from Inappropriate Behaviour Whilst Bega Cheese is committed to providing a safe and harmonious work environment, free of inappropriate behaviour, it is only able to do so with the support and commitment of its employees. Any employee who believes they are the victim of inappropriate behaviour, including unlawful discrimination, harassment, sexual harassment, bullying or intimidation, including physical violence, is encouraged to respond to that behaviour immediately in accordance with this Policy and Procedure. Where an employee believes that they have been the victim of inappropriate behaviour, they are encouraged to engage with the person giving offence and request that they cease such behaviour and, if they believe it is appropriate, to also advise the protagonist that a complaint will be made about their behaviour to the appropriate team leader/co-ordinator/supervisor/manger or other authority, if the behaviour continues or is repeated. Such action can prompt an immediate resolution of the issue, in particular where the employee giving offence may not realise that their behaviour was inappropriate.

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In situations where the inappropriate behaviour continues or where an employee is not comfortable raising the matter directly with the person concerned, the employee should bring the matter to the immediate attention of their team leader/co-ordinator/supervisor or manager for action. Where an employee brings an incident of alleged inappropriate behaviour to the attention of their team leader/co-ordinator/supervisor or manager, the responsible shift co-ordinator /supervisor or manager shall promptly investigate the matter, taking necessary steps, including, where appropriate, enacting disciplinary action in accordance with the company’s Disciplinary Procedure, to correct any inappropriate behaviour. Shift co-ordinators, supervisors & managers are advised to seek advice from Human Resources Manager where there are allegations of unlawful discrimination, harassment, sexual harassment bullying and intimidation, including physical violence, as these issues may have technical components under particular employment equity, OH&S, WHS and/or industrial legislation. Whilst it is anticipated that prompt action at a local level, focussed around conciliation, will often prevent the need for more formal processes to resolve a grievance, it is acknowledged that, in some cases, the grievance will not be satisfactorily resolved. Where this local approach does not resolve the grievance, then the incident should be referred to the site Human Resources Manager for formal investigation/resolution on behalf of the company. Irrespective of the company’s preferred approach to addressing issues of inappropriate behaviour, as set-out above, it is open to every employee to lodge a complaint directly with the site Human Resources Manager or to pursue the matter with appropriate external agencies, such as the Equal Opportunity Commission, Worksafe, Fair Work Australia or any other appropriate agency. In some circumstances, where a complaint is made against a team leader, supervisor or manager, the grievance should be managed outside the reporting line by involving the responsible site Human Resources Manager or the General Manager - Human Resources. The general responsibilities of all team leaders/co-ordinators/supervisors and managers include identifying, preventing and responding to instances of inappropriate behaviour in the workplace, so as to create a positive and productive work environment. It is important to note that grievances will not be reviewed where the grounds for the grievance appear to be vexatious, frivolous, or malicious or where it is considered that they are lodged to avoid performance management, misconduct or other serious workplace matters.

Records Notes should be taken at all stages of the grievance resolution process by those involved, including details of any information gleaned through interviews with the parties or any witnesses. Specific requirements for record keeping during the grievance process include but are not limited to:

The details of all employees involved.

Specific details relating to alleged incidents, including the names of those present who may have witnessed the events.

Specific details as to what witnesses directly saw or heard during the incident.

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Details of any risk management issues identified, including the need to redeploy any employees whilst the matter is investigated. And

Details of the resolution of the grievance, including any action required by the company’s Disciplinary policy and Procedure.

Details of the resolution must be set out to the satisfaction of all parties involved. These details must be communicated to all employees directly involved. In instances where a grievance is upheld and action is taken in accordance with the requirements of the company’s Disciplinary Policy and Procedure, then copies of all related notes must be inserted in the personnel file of the employee subject to such action, attached to the Disciplinary Report.

Training for effective grievance resolution

It is expected that team leaders/coordinators/supervisors/managers/contact officers and Human Resources Managers will undertake appropriate training provided by the company to acquire a good working knowledge of the issues in relation to workplace discrimination, harassment, sexual harassment, bullying, intimidation and related matters.

Counselling and Disciplinary Procedures You are expected to maintain a fair and reasonable level of productivity in your work, and to follow all reasonable instructions. If your performance in any area, such as attendance, punctuality, performance, safety or compliance with Company policies and standards is unsatisfactory, the counselling and disciplinary procedure will be used to try to resolve the situation. There are minimum standards of performance set down in the classification levels detailed in the Industrial Agreement. These are very important standards and you should ensure you understand and practice them. The counselling and disciplinary procedures are also detailed in the Industrial Agreement to which Bega Cheese is a registered party.

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13. REMUNERATION AND BENEFITS

Salaries and Wages Bega Cheese aims to maintain a salary and wage structure that is fair and equitable and that compares favorably with other companies, so as to assist Bega Cheese to reward, retain, and where necessary attract employees. Salaries for monthly paid employees are reviewed annually and are monitored to ensure they remain competitive both within the industry and within professional areas. If you are paid a salary you will usually receive your pay no later than the 15th of each month. Wage structures are determined in accordance with the Industrial Agreement that defines job classifications and the associated wage rates. The wage rates of the Industrial Agreement to which Bega Cheese is a registered party, along with other conditions, are negotiated on a regular basis. Where the Industrial Agreement to which Bega Cheese are a registered party is not applicable, the relevant State or Federal Award or Agreement shall determine the wage structure. Wages are paid weekly on Wednesday, and, for the vast majority of employees, the pay week commences on Monday and finishes on Sunday. Your wages are calculated on the basis of your attendance records and approved leave forms. It is your responsibility to swipe on and off each day. Failure to do this may result in incorrect payment. Any employee found swiping on or off for another employee may be subject to instant dismissal or other disciplinary measures. Certain deductions may be taken from your pay. These include superannuation, Union membership dues, health insurance and some other work related fees (please note that the company is only able to make deductions where it is able to satisfy provider requirements ie: in the case of health funds, deductions are only able to be made where at least 15 of our employees are members of the designated fund). You will be required to confirm in writing the account details for your pay to be deposited to, prior to receiving your first pay. You can change your banking details simply by notifying the Payroll Office in writing. Certain deductions may be taken from your pay. These include superannuation, Union membership dues, health insurance and some other work related fees. To have deductions made from your pay, first check with the Pay Office that the particular deductions can be made and then you will need to request the deductions in writing.

Superannuation Bega Cheese contributes the required level of superannuation for employees, in accordance with legislation. Bega Cheese has an approved Company Superannuation Fund operating with MLC (The universal Super Scheme). Your superannuation contributions shall be directed to the Company Superannuation Fund unless otherwise directed in writing by the employee. The fund caters for all types of employee, whether full-time, part-time or casual. Membership of the fund provides you with benefits on retirement, death, disablement, and resignation. Full details of contributions and fund benefits are too detailed to summarise in this handbook The obligation of Bega Cheese to contribute to your superannuation fund shall cease on the last day of your employment with Bega Cheese.

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Staff Discounts “Discounts on product purchases may be available for products produced at individual sites”.

Access to Specialist Services Bega Cheese has in place excellent relationships with a number of organisations who provide specific services, usually without charge to Bega Cheese employees. These services currently include:

counselling, to assist employees with significant personal issues

financial, to assist with advice in guidance in relation to superannuation and management of personal finances

on-site soft tissue therapy services, to provide relief for injuries which have usually been sustained at work, or which are effecting your ability to carry out your normal role

Bega Cheese Benefit Fund The Fund exists to provide support to employees and their immediate families who are experiencing tragic, extraordinary or compassionate situations. Generally such situations will be outside the control of the individual/s and other forms of support will have been exhausted. The Fund is managed by a Committee which reflects a broad cross-section of Bega Cheese, and derives its funds from employee contributions via payroll, company donations, raffles, bequests and other forms. Regular information on the Fund and its activities is provided to employees.

Amenities A variety of staff amenities are provided at all company sites however, all facilities feature company provided tea and coffee, microwave ovens or food warmers, fridges, and snack and drink vending machines are available for all employees.

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14. TRAINING AND DEVELOPMENT

Bega Cheese recognizes that the skills and capabilities of our employees are central to the company’s ongoing success. This is clearly reflected in our Five Pillars and our Strategic and Business Plans. Accordingly, there is considerable emphasis placed on skills development, through the provision of in-house and specialist external training. Our training activities can be broadly broken into the following key areas:

Technical/skills development this training involves improving an employee’s ability to tackle the technical components of their role. Examples might include bringing equipment suppliers on-site to provide Operator or Maintenance training, or small groups of employees being trained up in a new process or computer software. We are committed to having a skilled workforce and encourage all employees to take advantage of our learning and development initiatives. To reflect this commitment, we provide traineeships in a number of areas for employees involved in production, laboratory, packaging, sanitation and drawdown. All new production and sanitation employees will be enrolled in Certificate II Food Processing. This is a 12 month program which includes learning material from the Induction week, annual refresher training and on-the-job training conducted by Bega Cheese. At the completion of Certificate II the trainee will then be expected to enroll in Certificate III Food Processing. For existing employees prior to the induction of the Certificate II program, Bega Cheese will continue to provide the two year Certificate III Food Processing traineeship, as this provides a foundation of important knowledge around topics such as OH&S, food safety, communications and environment. The program is delivered on-the-job and is focused on confirming your existing skills and knowledge. From an employee viewpoint, Food Processing Certificates are nationally recognized and help you to develop your career options with Bega Cheese, at no cost to yourself.

Compliance Training is training that is required by law to be undertaken. This includes, for example, confined space training, chemical handling training, forklift training and licensing, or training for First Aiders or members of OH&S Committees.

Developmental training revolves around developing individuals or groups, often outside the scope of their present role/s. It typically includes areas such as leadership training, and could extend to overseas visits to other factories, exchange opportunities or attendance at significant programs run by external tertiary institutions.

Career Paths and Internal Job Applications A career path is a sequence of positions you may take within the Company and the skills you may gain, during your work life. This progression and development is unlikely to follow a fixed pattern from start to finish; but nor is it a matter of chance. It involves planning and actively seeking opportunities for development and advancement in the directions you want to pursue.

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To encourage employees to take new job opportunities, vacant positions are usually, but not always, advertised internally and preferential consideration is given to internal applicants. This does not mean, however, that an internal applicant will necessarily be given the job. The successful applicant will be the person with the skills, qualifications, aptitude, and personal qualities best suited to the position. To avoid unnecessary disruption, cost and inconvenience to the Company, it is company policy that employees completing a period of probation are not permitted to apply for a vacant position, unless an exception to that policy is approved by the Human Resources Department.

Performance Reviews Feedback about how you are performing your job is important, it enables you to improve your performance, identify training that you may benefit from, receive positive feedback and discuss further career opportunities. This feedback may include informal/irregular oral comments/discussions, or may take the form of a more structured approach through the company’s Performance Assessment and Appraisal process.

Requests for Training At any time you can approach your Supervisor or manager to request additional training. This can be in relation to your current position, especially if you do not feel fully competent or knowledgeable of all the requirements of your position. If your interest in training & development extends outside your current role or department, then you may be referred to the Human Resources department, who will be happy to assist and guide you in relation to your career direction within Bega Cheese.

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15. CLEANING AND SANITATION

Water Handling Water must not be splashed from the floor or from unclean equipment onto cleaned equipment or processes during operation.

Water from cleaning operations in one area must be prevented from flowing into areas where product is being produced.

Sanitary Handling of Sanitation Tools and Equipment To prevent product contamination, certain tools and equipment must be used only for the intended purpose, dedicated to these specific uses, and handled and/or stored separately. For example, tools and equipment used, dedicated, handled and/or stored:

In raw areas

In ready to eat areas

According to allergen control programs

According to colour code programs

Cleaning and Handling of Product Equipment

Cleaned equipment must be handled in a manner that maintains its sanitary condition and that prevents damage, including:

Cleaned equipment, parts, cleaning aids/tools, etc., must not be placed directly on walking surfaces. Examples of sanitary storage include placement on sanitary rubber mats designated by colour for their intended use or on designated sanitary carts or racks.

Cleaned equipment must not be dragged across the floor or walking surfaces.

Clean parts must not be stored in unclean containers.

Clean parts must not be stored with dirty parts.

Sanitary Mats

Designated sanitary mats must be handled to maintain sanitary conditions, including:

The mats must not be stepped on. One side of the mat must be marked to distinguish between the floor contact side and the container or part contact side. An “X” or colour-coding can be used for this purpose.

When not in use, mats must be stored off of the floor in a manner that allows them to dry (e.g., on a hanger designed to hold mats).

Note: Rubber mats used for employee comfort at workstations need to be distinguishable (e.g., by colour) from sanitary mats.

Good Housekeeping Practices in Production Areas

General Do’s and Don’ts Avoid spillage and damage to product by careful handling.

Maintain bagged product in a neat and orderly manner.

Avoid product overhang on pallets.

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Damaged bags or drums must be immediately sealed to prevent product spillage and contamination.

Contaminated ingredients must not be used.

Littering or practices that cause poor housekeeping or other unsanitary conditions are prohibited.

Put all waste and refuse in trash containers, which must be labelled as “trash” or otherwise identified by specific plant programs and training.

Trash containers must be maintained in a sanitary condition by using liners and / or routine cleaning of the containers.

Personal accessories in work areas Radios, televisions, cameras, mobile electronic devices (including phones, iPods, iPads, PDAs and games), books and magazines are not allowed in work areas, unless specifically permitted by local policies.

Preventing Aerosols on Finished Product and Product Contact Surfaces Near sanitized equipment and in areas of exposed finished product, water hoses or compressed air hoses should not be used to clean the floor or equipment due to the formation of aerosols.

Use of high-pressure water greater than 100 psi / 7bar should be restricted to use 2 hours prior to sanitizing and shall not be used during operation.

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16. RECEIVING, HANDLING, STORAGE AND SHIPPING

Receiving Unloading Bulk Materials

When unloading bulk raw materials from vehicles, all dome openings must be adequately screened to protect the materials from contamination.

The screening device must allow sufficient airflow into the tank to permit normal unloading and provide adequate protection from rainwater. Bulk ingredients will be properly transferred through sanitary pipes and/or hoses, and filtered, screened or sifted as required.

Storage and Handling Storage and Handling of Finished Product All items should be stored to avoid direct contact with the floor or walking surfaces (eg: on pallets, slip sheets or racks). Where slip sheeting operations are used, the slip sheeted product may be stored directly on the floor provided there are no sources of contamination. Sitting or standing on product shipping cases is not acceptable. Over-stacking of product must be avoided. Product must be stacked to appropriate heights.

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17. PROPER STORAGE

Designated Storage Practices

Product or ingredient containers must not be stored immediately adjacent to containers for waste or non-product items (e.g., cleaning compounds, laboratory solvents).

“Non-Product items should be stored in separate, designated areas”

Ingredient Storage Practices

Ingredients must be adequately protected and stored in a sanitary manner.

Packaging Storage Practices

Packaging Materials in full or partial quantities must be adequately protected and stored in a sanitary manner.

Material should be covered to prevent contamination (i.e. closures, films, etc.)

Packaging material must be removed from the area during wet cleaning.

Packaging materials must not be stored directly on walking surfaces.

Maintain the identification and traceability of packaging materials.

Rework Handling and Storage Rework product must be adequately covered / protected during breaks, lunch periods, downtime, etc. with clean plastic or other suitable material. Traceability of rework shall be maintained.

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18. LEAVING YOUR EMPLOYMENT

Whilst we hope that employees will enjoy a long and rewarding career with the company, there will come a time when all employees will leave the business. When this occurs, for whatever the reason, we aim to ensure that the separation process is conducted with absolute integrity and fairness.

Separations: Separation refers to all forms of termination of employment, for whatever reason. All separations will be handled fairly and with integrity. The main types of separation are:

Abandonment: You have abandoned your employment if you simply stop coming to work or don’t return from leave without advice to your Supervisor or Manager within three days. This is a breach of your contract of employment.

Dismissal: This means that Bega Cheese terminates your contract of employment, either summarily because of misconduct on your part, or following disciplinary procedures as a result of continued sub-standard performance.

Resignation: This means that you decide you don’t want to work for Bega Cheese anymore. You must give notice as set out in your contract of employment, usually one week or one month.

Retirement: This means that you finish work and leave the workforce permanently.

The separation process normally involves:

Notification: Your advice in writing to Bega Cheese that you are terminating your employment.

Return of Company property: You must return any Company property you have, such as swipe cards, keys, clothing and files.

Superannuation: Written advice to the superannuation fund of what you would like done with your fund balance.

Exit interview: An exit discussion with the Human Resources Department.

Summary Dismissal The counselling and discipline procedure shall not limit the right of Bega Cheese to summarily dismiss an employee for serious or willful misconduct. An employee can be dismissed without warning for acts of misconduct. Incidents of misconduct that may lead to instant dismissal include:

being at work under the influence of alcohol or other drugs

possessing, taking or selling illegal drugs on Company premises

unauthorised possession or consumption of alcohol by employees on Company premises

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theft or willful damage of Bega Cheese or other employee’s property. Borrowing items from Bega Cheese without permission will be considered theft.

jeopardising your own safety or that of another person

swiping on or off someone else’s swipe card

disloyalty to Bega Cheese this list is not exhaustive.

Termination Payments Termination payments are set according to legislation and the Industrial Agreements to which Bega Cheese is a registered party. Termination payments will be paid by direct credit to your usual account on the first normal payday date after your final day of work. A final pay-slip will be forwarded to you, showing all payments made to you on the completion of your employment.

References Verbal references should only be provided to prospective employers and with the permission of the former employee.

Verbal references should only be provided by the former employee’s direct supervisor, manager or site Human Resources Manager, and then only where the supervisor/manager has direct knowledge of the employee’s job performance.

Before providing a reference, the responsible supervisor/manager should verify the identity of the person requesting the reference. If in doubt about the identity of the person requesting the reference, the staff member should ask for the request in writing. The supervisor/manager should not give out any information to parties that do not have a legitimate "need to know".

In considering whether to provide a verbal reference, the responsible supervisor or manager shall:

• take reasonable care;

• provide information which is, as far as possible, true, accurate and fair, and which does not give a misleading impression;

• provide only honest opinions;

• express opinions as opinions rather than statements of fact;

• limit the information given to the employee's job-related performance (any negative comments about an employee’s job performance should not be made, unless the employee had been made aware of the performance problem or behavioural concern at the time); and

• avoid any non work-related comments, comments on medical issues or comments based on hearsay.

Any employee may act as a personal referee for a former work associate however, if made in writing, such references must be made on the staff member’s own notepaper and must say that the reference is being made in a personal capacity. On no account should a personal reference be provided on the company’s letterhead or in any way that may suggest that the company endorses the reference.”

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Acronyms, Key Words and Names As is the case in most organisations, there are numerous acronyms, key words and names that are peculiar to Bega Cheese. Understanding the meaning of this unique ‘language’ is particularly important for Bega Cheese employees & their ability to communicate and contribute effectively to the business. The Human Resources department will ensure that a list of current acronyms, key words and names applicable to each site is maintained and posted under the Human Resources tab on the company’s Intranet site, as well as being included in training materials used in the company’s Induction and Refresher training activities.

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19. VISITORS

Scope Any person attending a Bega Cheese location where they are not employed is considered to be a visitor to that site.

This includes, but is not limited to: • Contractors • Corporate/ company employees • Supplier representatives • Product developers • Bega Retirees • Religious inspectors • Truck drivers • Consultants • Any employees’ family members • Customer representatives • Military inspectors • Government or regulatory agency visitors/ inspectors • Independent inspection/ testing firm representatives

Supervisors Visitors must be accompanied (escorted) by a site management person, or designee, when required by site management.

All visitors are required to sign-in on arrival at company sites. The manager responsible for arranging/hosting the visit is responsible for the visitor whilst they are on site. All visitors must sign-out from the site when leaving. At the request of the responsible management, the Human Resources Manager at each site will arrange for any visitors regularly required to attend the site to undertake the site Induction Program. Whilst visitors who have completed a site Induction Program are not required to be escorted and directly supervised whilst on site, any visitor who has not completed the site Induction Program (including company employees from other sites) must be escorted and directly supervised whilst on site, with responsibility for arranging such supervision, as well as for providing any appropriate personal protective equipment, resting with the site manager responsible for arranging/hosting the visit.”

Restricted/Sensitive Areas Visitors are not permitted to access restricted/sensitive areas without the site manager responsible for the visitor having arranged with the manager of the restricted/sensitive area for such access. This requirement applies to all visitors, including those who have completed the site Induction Program. The host site manager is also responsible for ensuring that all visitors, without exception, observe site rules, including those applicable to GMP areas.

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NOTES

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NOTES