Work Health & Safety Policy — ASI AI Solutions

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Policy Owner: People & Culture / WHS Officer

Approved By: Chief Operating Officer

Effective Date: 1 January 2026

Review Date: 1 January 2027

Classification: Internal

Version: 1.0

Legislation: Work Health and Safety Act 2011 (NSW)

Regulation: Work Health and Safety Regulation 2017 (NSW)

1. Purpose

ASI AI Solutions is committed to providing a safe and healthy workplace for all workers, contractors, visitors, and other persons who may be affected by our operations. This policy sets out our approach to managing health and safety risks in compliance with the Work Health and Safety Act 2011 (NSW) (the "WHS Act") and the Work Health and Safety Regulation 2017 (NSW) (the "WHS Regulation").

2. Scope

This policy applies to all workers (employees, contractors, labour hire, volunteers, and work experience students), officers, visitors, and other persons at any ASI AI Solutions workplace, including the Botany office, client sites, co-working spaces, home offices, and any location where work is performed on behalf of the Company.

3. Definitions

Term	Definition
PCBU	Person Conducting a Business or Undertaking — ASI AI Solutions Pty Ltd (WHS Act s 5).
Officer	A person who makes or participates in making decisions that affect the whole or a substantial part of the business (WHS Act s 27). Includes directors and senior executives.
Worker	Any person who carries out work for the PCBU, including employees, contractors, subcontractors, and labour hire workers (WHS Act s 7).
HSR	Health and Safety Representative — an elected worker representative for a designated work group.
HSC	Health and Safety Committee — a consultative body comprising worker and management representatives.
Notifiable Incident	Death, serious injury or illness, or a dangerous incident as defined in WHS Act ss 35–37.
Reasonably Practicable	That which is, or was at a particular time, reasonably able to be done to ensure health and safety, taking into account relevant matters in WHS Act s 18.

4. Policy Statement

ASI AI Solutions will, so far as is reasonably practicable, ensure the health, safety, and welfare of all workers and that other persons are not put at risk by our work activities. We recognise WHS as a shared responsibility and are committed to continuous improvement in WHS performance.

Specifically, the Company will:

Provide and maintain a work environment, plant, and systems of work that are without risks to health and safety (WHS Act s 19(3)(a)).
Ensure the safe use, handling, and storage of plant, structures, and substances (WHS Act s 19(3)(b)).
Provide adequate facilities for the welfare of workers (WHS Act s 19(3)(c)).
Provide information, training, instruction, and supervision necessary to protect workers from risks (WHS Act s 19(3)(f)).
Monitor the health of workers and conditions at the workplace (WHS Act s 19(3)(d)).
Maintain a system for identifying hazards, assessing risks, and implementing controls.
Consult with workers and their representatives on WHS matters.
Allocate adequate resources for WHS management.
Comply with all applicable WHS laws, codes of practice, and Australian Standards.

5. PCBU Duties (Primary Duty of Care)

As the PCBU, ASI AI Solutions has the primary duty of care under s 19 of the WHS Act. This duty is owed to all workers, and is non-delegable — while activities may be delegated, the duty cannot be transferred to another person.

The duty extends to ensuring, so far as is reasonably practicable:

The provision and maintenance of a safe work environment without risks to health and safety.
The provision and maintenance of safe plant, structures, and systems of work.
The safe use, handling, and storage of plant, structures, and substances.
The provision of adequate facilities for the welfare of workers.
The provision of information, training, instruction, or supervision necessary for safety.
The monitoring of the health of workers and the conditions at any workplace under the management or control of the PCBU.

6. Officer Due Diligence

Officers of the Company (directors and senior executives) must exercise due diligence to ensure the Company complies with its WHS duties (WHS Act s 27). Due diligence includes:

Acquiring and keeping up-to-date knowledge of WHS matters.
Understanding the nature of the Company's operations and associated hazards and risks.
Ensuring the Company has appropriate resources and processes to eliminate or minimise risks.
Ensuring the Company has processes for receiving and considering information about incidents, hazards, and risks, and for responding in a timely way.
Ensuring the Company has and implements processes for complying with its WHS duties.
Verifying the provision and use of those resources and processes.

7. Worker Responsibilities

Under s 28 of the WHS Act, all workers must:

Take reasonable care for their own health and safety.
Take reasonable care that their acts or omissions do not adversely affect the health and safety of other persons.
Comply, so far as reasonably able, with any reasonable instruction given by the PCBU.
Cooperate with any reasonable WHS policy or procedure of the PCBU.

In addition, workers at ASI AI Solutions are expected to:

Report all hazards, near misses, injuries, and incidents promptly.
Use personal protective equipment (PPE) as directed.
Participate in WHS training, consultations, and emergency drills.
Not wilfully or recklessly interfere with or misuse anything provided for health, safety, or welfare.
Not attend work while impaired by alcohol, drugs, or other substances.

8. Risk Assessment Process

8.1 Hazard Identification

The Company will systematically identify hazards through:

Regular workplace inspections (quarterly for office environments).
Consultation with workers, HSRs, and the HSC.
Review of incident and near-miss reports.
Review of relevant industry guidance and SafeWork NSW alerts.
Analysis of workers' compensation claims data.
Change management assessments (for new plant, processes, or work arrangements).

8.2 Risk Assessment

Identified hazards will be assessed using the following risk matrix to determine the level of risk and priority for action:

	Insignificant	Minor	Moderate	Major	Catastrophic
Almost Certain	Medium	High	High	Extreme	Extreme
Likely	Low	Medium	High	High	Extreme
Possible	Low	Medium	Medium	High	Extreme
Unlikely	Low	Low	Medium	Medium	High
Rare	Low	Low	Low	Medium	Medium

8.3 Hierarchy of Controls

Risks will be eliminated or minimised using the hierarchy of controls (WHS Regulation cl 36):

Elimination — remove the hazard entirely.
Substitution — replace the hazard with something less risky.
Isolation — separate the hazard from people.
Engineering controls — use physical measures to reduce the risk.
Administrative controls — change work practices, procedures, training, or signage.
Personal Protective Equipment (PPE) — last resort, used in combination with other controls.

8.4 Review of Controls

Control measures will be reviewed: when the control measure does not adequately control the risk; before a change at the workplace that may create new risks; if a new hazard or risk is identified; if consultation indicates a review is necessary; or at least annually.

9. Incident Reporting and Investigation

9.1 Reporting

All workers must report the following to their manager and the WHS Officer immediately or as soon as practicable:

Any workplace injury or illness (no matter how minor).
Near misses (an event that could have resulted in injury or illness).
Hazards or unsafe conditions.
Property damage.

Reports should be submitted via the Company's Incident Report Form (available on the intranet and in hard copy at reception).

9.2 Notifiable Incidents

Notifiable incidents must be reported to SafeWork NSW immediately by the fastest possible means (phone: 13 10 50). The site of a notifiable incident must not be disturbed until an inspector arrives or directs otherwise, unless to protect the health and safety of a person, to assist an injured person, or to make the site safe (WHS Act ss 38–39).

A notifiable incident includes: the death of a person; a serious injury or illness requiring immediate treatment as an in-patient in a hospital, or treatment for amputation, a serious head or eye injury, serious burns, spinal injury, loss of bodily function, or serious lacerations; or a dangerous incident (e.g., uncontrolled escape of gas, electric shock).

9.3 Investigation

All incidents and near misses will be investigated proportionate to their severity and potential. Investigations will identify root causes, contributing factors, and recommend corrective actions. Findings will be documented and corrective actions tracked to completion.

10. Emergency Procedures

10.1 Emergency Plan

The Company maintains an Emergency Management Plan for each workplace, covering:

Fire and evacuation procedures.
Medical emergencies and first aid.
Bomb threats and suspicious packages.
Natural disasters (storm, flood, earthquake).
Active threat / hostile person situations.
Utility failures (power, water, gas).

10.2 Key Personnel

Role	Responsibility	Training Required
Chief Warden	Overall coordination of emergency response.	Chief Warden course (annual refresher).
Floor Wardens	Sweep designated areas, guide evacuation.	Warden training (annual refresher).
First Aid Officers	Provide first aid response. Minimum 1 per 50 workers.	HLTAID011 Provide First Aid (3-year currency).
Fire Extinguisher Trained Personnel	Operate fire extinguishers if safe to do so.	Practical extinguisher training (annual).

10.3 Drills

Evacuation drills will be conducted at least twice per year. All workers must participate. Post-drill debriefs will identify improvement opportunities.

11. Mental Health and Wellbeing

ASI AI Solutions recognises that psychological health is as important as physical health. The Company is committed to:

Identifying and managing psychosocial hazards in accordance with the Code of Practice: Managing Psychosocial Hazards at Work (SafeWork NSW, 2022) and the WHS Regulation Part 3.2A.
Providing access to a confidential Employee Assistance Program (EAP), offering counselling and support services at no cost to workers (currently provided by Assure Programs: 1800 808 374).
Training managers to recognise signs of psychological distress and have supportive conversations.
Promoting a culture where seeking help is encouraged and destigmatised.
Managing workload and work design to prevent burnout, fatigue, and excessive stress.
Addressing bullying, harassment, and conflict promptly in accordance with the Anti-Discrimination & Harassment Policy.

Key psychosocial hazards relevant to our industry include: high job demands, low job control, poor support, remote work isolation, unclear role expectations, organisational change, and exposure to traumatic content (e.g., in content moderation AI work).

12. Ergonomic Assessment

12.1 Office Workers

All office-based workers will receive an initial workstation assessment upon commencement or change of workstation. Assessments will be conducted using the Company's Ergonomic Self-Assessment Checklist, with follow-up by a qualified assessor where risks are identified.

Key ergonomic considerations include: chair height and lumbar support, monitor height and distance, keyboard and mouse placement, lighting and glare, and regular stretch and movement breaks (at least every 60 minutes).

12.2 Remote / Home Workers

Workers who work from home or remotely must complete the Home Office WHS Self-Assessment (available on the intranet) prior to commencing remote work and annually thereafter. The Company will:

Provide guidance on setting up an ergonomic home workstation.
Offer a Home Office Equipment Allowance (refer to Remote Work Policy) to support appropriate ergonomic setup.
Arrange a professional ergonomic assessment where a risk is identified or requested.
Ensure remote workers have access to the same WHS reporting and EAP services as office-based workers.

13. WHS Consultation

13.1 Commitment to Consultation

The Company will consult with workers, so far as is reasonably practicable, on WHS matters that directly affect them (WHS Act Part 5). Consultation involves sharing information, giving workers a reasonable opportunity to express views, and taking those views into account before making decisions.

13.2 Health and Safety Representatives (HSRs)

Workers are entitled to request the election of one or more HSRs for their designated work group (WHS Act ss 50–67). The Company will:

Facilitate the establishment of work groups through negotiation with workers.
Support the election process (which must be conducted by workers themselves).
Allow HSRs to exercise their powers and functions under the WHS Act, including issuing provisional improvement notices (PINs) and directing cessation of unsafe work.
Provide HSRs with access to approved HSR training (5 days initial, 1 day annual refresher) at the Company's expense, with no loss of pay.

13.3 Health and Safety Committee (HSC)

The Company will establish and maintain a Health and Safety Committee comprising:

At least half of the members being worker representatives (HSRs or elected workers).
Management representatives including the WHS Officer.

The HSC will meet at least quarterly and will facilitate cooperation between the Company and workers in developing and carrying out WHS measures. Minutes will be made available to all workers.

14. Training

The Company will provide WHS training including:

Induction: All new workers complete WHS induction covering this policy, emergency procedures, hazard reporting, and relevant safe work procedures.
Role-specific training: As identified through risk assessment (e.g., manual handling, working at heights, electrical safety).
Refresher training: Annual refresher for all workers on key WHS topics.
Manager training: WHS responsibilities, incident investigation, psychosocial hazard management, and return-to-work coordination.

Training records will be maintained and reviewed during the annual WHS audit.

15. Workers' Compensation and Return to Work

The Company maintains a workers' compensation insurance policy as required by the Workers Compensation Act 1987 (NSW) and the Workplace Injury Management and Workers Compensation Act 1998 (NSW). Injured workers will be supported through the return-to-work process with the goal of safe, early, and sustainable return to meaningful work, in consultation with the treating medical practitioner and the insurer.

16. Responsibilities

Role	Responsibility
CEO / Officers	Exercise due diligence. Ensure adequate resources for WHS. Set safety culture from the top.
WHS Officer	Day-to-day WHS management. Coordinate risk assessments, inspections, training, and incident investigation. Maintain WHS documentation. Report to SafeWork NSW as required.
Managers & Team Leads	Implement WHS procedures in their area. Conduct team-level risk assessments. Ensure workers are trained and supervised. Report incidents promptly.
All Workers	Comply with this policy and WHS procedures. Report hazards and incidents. Participate in training and drills. Cooperate with WHS requirements.
HSRs & HSC	Represent workers on WHS matters. Participate in consultation. Monitor WHS performance.

17. Review

This policy will be reviewed annually, or sooner following a notifiable incident, significant change to operations, legislative change, or audit finding. Reviews will be conducted in consultation with workers and the HSC.