The purpose of the CFS Third Party Code of Conduct ('Code') is to share our approach on responsible procurement.


The Code outlines our commitments, the principles and expectations of Third Parties that provide goods or services to or on behalf of CFS, including sub-contractors. We expect Third Parties to comply with this Code.

Our Commitments


At CFS our purpose is to help our Members achieve their individual retirement goals. To achieve this our people commit to the highest ethical standard and professional standards, which include:

  • Ensure our behaviours, decisions and actions align with the CFS' Code of Conduct and Values (including a 'Should We?' test);

  • Compliance with applicable laws and regulations;

  • Acting responsibly and compliantly, doing the right thing, managing risk, and achieving the outcomes that serve our Members and Communities, People and Governance; and

  • Managing our Third Party relationships in an ethical, transparent and responsible manner

Guiding Principles


CFS will apply the same fundamental principles, applied for Responsible Investment, to guide our decisions regarding Environmental, Social and Governance (ESG) risks and opportunities in our supply chain:

  • Integrity: putting our Members, stakeholders and the community best interests at the heart of everything we do;

  • Balance: listening carefully to all sides of the conversation to deepen our understanding;

  • Transparency: incorporating ESG into decision making, understanding impacts, and being open about our progress on sustainable and responsible sourcing commitments; and

  • Focus: promoting acceptance and the implementation of sustainable and responsible sourcing for our sourcing needs.

Expectations of Third Parties


CFS requires that our Third Parties:

  • Conduct their business, compliant with applicable laws, rules, and regulations of the jurisdiction

    in which they operate;

  • Review this Code and ensure compliance, inclusive of their supply chain and subcontractors

  • Self-monitor their compliance with this Code and to inform us of any non-complianc;

  • Respond to any reasonable requests for information from CFS, ensuring all information is a true and accurate reflection of their operations and supply chain; and

  • Remedy any non-compliance, as a priority, partnering with CFS in defining agreed corrective actions and timescales to complete these actions.

How CFS works with Third Parties


We recognise that working with suppliers while they address non-compliance to this Code within their own operations and by their own suppliers may be a better long-term solution than ending the relationship. If a supplier is unable or unwilling to meet our minimum standards, we may choose to end the relationship subject to contractual obligations.


Third Parties have access to CFS' SpeakUp service, a trusted avenue to raise matters on conduct of concern relevant to CFS. Please refer to the CFS website:


There are options available for reporting via the SpeakUp service, including identifying yourself, remaining anonymous, or as a whistleblower.


If you have any questions or feedback on this Code, please contact:

Social Expectations


We require Third Parties to comply with applicable employment standards, labour, non-discrimination and human rights legislation.


Third Parties' minimum requirements in their workplaces include:


Human Rights, Modern Slavery and Labour Practices
  • Modern Slavery: Modern slavery can take many forms, including forced labour, child labour, domestic servitude, sex trafficking and human trafficking. Third Parties will not use, or in any way benefit from or contribute to modern slavery and must actively support the abolition of modern slavery by taking measures to identify, manage and mitigate modern slavery risks in their supply chain;
  • Child Labour: Not employ or exploit children below the minimum legal age;
  • Freedom of Association: Allow freedom of association and collective bargaining for workers; and
  • Workers Entitlements: Provide fair pay and working conditions for employees.
Work Health and Safety (WHS)
  • Provide a safe and hygienic working environment through proactive management and controls that minimise health and safety risks, support accident prevention, with appropriate training to perform their jobs safely.
Respect and Diversity
  • Third parties must not tolerate discrimination, harassment, violence, disrespect, inappropriate behaviour and have the appropriate policies in place to meet or exceed requirements of any relevant laws;
  • Ensure work environment and culture is inclusive with recruitment and employment practicesare based on an individual’s ability and are not based on gender, personal characteristics and physical appearance, medical condition, union membership or political affiliation; and
  • Encourage the principles of diversity and inclusion through their supply chain by affording for businesses in the supply chain for those in supplier diversity categories.


Environment and Climate Risk Expectations


We require that suppliers to CFS will, as a minimum:

  • Meet all relevant local and national environmental protection laws, regulations and standards;
  • Seek to actively manage the adverse environmental impacts of their operations and across their value chain, and take responsibility for minimising the negative impact of their goods and services throughout their lifecycle;
  • Expect Third Parties to have an environmental policy and management systems appropriate to size and nature of their operations, tracking and disclosing on performance; and
  • Have suitable sustainable certifications related to the primary materials in their product.
Transparency and Governance


We will require, as a minimum:

  • Demonstrate appropriate risk management and governance to comply with all local and national laws and regulations pertinent for their operations and supply chain;
  • Implement procedures for their employees to comply with applicable anti-bribery and corruption laws including zero tolerances to corruption in any form;
  • All contractual obligations are to be fulfilled including, but not limited to reporting customer complaints, managing incidents, notifications for breaches of Privacy, Data, Information Security, Legislation, and Continuous Improvement, Innovation and managing risks; and
  • Have a grievance mechanism or whistleblower policy or process that is clearly communicated and understood by employees, protecting employee whistleblowers and prohibiting retaliation or victimisation.
Management Systems


CFS emphasises the importance of suppliers having management systems that support the implementation of this Code.We require that Third Parties to CFS will:

  • Have a member of their leadership team/management review and accept this Code;
  • Proactively work with their own supply chain to ensure the principles within this Code are met; and
  • Be able to give an account of where goods ordered by CFS are produced.


Avanteos Investments Limited ABN 20 096 259 979, AFSL 245531 (AIL) is the trustee of the Colonial First State FirstChoice Superannuation Trust ABN 26 458 298 557 and issuer of FirstChoice range of super and pension products. Colonial First State Investments Limited ABN 98 002 348 352, AFSL 232468 (CFSIL) is the responsible entity and issuer of products made available under FirstChoice Investments and FirstChoice Wholesale Investments.


Information on this webpage is provided by AIL and CFSIL. It may include general advice but does not consider your individual objectives, financial situation, needs or tax circumstances. You can find the target market determinations (TMD) for our financial products at which include a description of who a financial product might suit. You should read the relevant Product Disclosure Statement (PDS) and Financial Services Guide (FSG) carefully, assess whether the information is appropriate for you, and consider talking to a financial adviser before making an investment decision. You can get the PDS and FSG at or by calling us on 13 13 36.