Topic 2: Aboriginal Procurement Policy

• The total number of workers on the project
• Aboriginal workers on the project who are:
  • Full-time, part-time or casual employees
  • Apprentices, trainees
  • Engaged through labour hire arrangements (minimum of one hour’s paid work per week)
  • By the head contractor or the direct subcontractors

• Workers not linked to project delivery

• Timesheets, payroll records, employee contracts
• Site attendance registers or sign in/out records

• Personal details – worker name, Indigenous status,
• Role type – full-time, part-time, casual, apprentices, trainees and labour hire employees
• Work information – employer, job title, start and finish dates

The head contractor would include:

• Procurement spend with Aboriginal-owned subcontractors and suppliers on the Aboriginal Business Directory WA or Supply Nation’s Indigenous Business Direct
• Procurement spend with Joint ventures where Aboriginal businesses hold at least 50% ownership
• Contract Details – Documentation of contracts awarded to registered Aboriginal businesses and ACCOs

The head contractor would exclude:

• Procurement spend with subcontractors and suppliers not listed on the Aboriginal Business Directory WA or Supply Nation’s Indigenous Business Direct
• Procurement spend with Joint ventures where Aboriginal businesses do not hold at least 50% ownership
• Procurement spend with subcontractors and suppliers not awarded directly by the head contractor

• You can showcase Aboriginal businesses in your supply chain as a competitive advantage during the tender
• However, sub-subcontractors do not count towards the Aboriginal Business target

• Contract breach penalties – defined by contract but may include withholding security or retention and damages
• Damage to reputational with both clients and community
• Jeopardise ability to win future contracts off previous performance
• Can trigger audits that can result in loss of time and could identify contract breaches

• Contract breach penalties – defined by contract but may include withholding security or retention and damages
• Damage to reputational with both clients and community
• Jeopardise ability to win future contracts off previous performance

During the tender stage we need to demonstrate our capability and track record to secure the job. We review all documentation for references to the Aboriginal Procurement Policy and identify how the head contractor expects us to contribute to the Aboriginal participation requirements. Where targets are not achievable, we highlight these clearly and propose alternative ways we can add value.

1. Check if the Policy forms part of the tender documentation

• A key indicator is if the developer is a WA government department (eg. Development WA, Department of Health, Department of Education etc)
• Search (Ctrl F) the tender documents for key words such as Aboriginal business, APP, Aboriginal employment

2. Can we meet the contractual clauses asking us to contribute to the Aboriginal participation requirements?

• Liaise with the delivery team to assess our capability to deliver our contribution to the Aboriginal participation requirements
• Identify risks and opportunities associated with contributing to these requirements using the Capability Assessment Template

3. Showcase our previous performance for Aboriginal employment and procurement:

• Submit the Past Performance Template with the tender submission

4. Provide a written statement of how you will contribute to Aboriginal participation

• Complete the Social Procurement Commitments Template with project‑specific opportunities for Aboriginal businesses and employment
• Flag any targets we cannot achieve and highlight any additional value we can provide. The Social Procurement Commitments Template has prompts to help identify risks and opportunities
• Submit the completed Social Procurement Commitments Template with the tender submission
• In some instances, the tender may require commitments to be written directly into Response Schedules. If this is the case, use the Social Procurement Commitments Template as guidance when drafting responses

5. Liaise with the head contractor throughout the tender phase to ensure clear understanding of the Aboriginal participation requirements

• Document any exclusions or negotiated amendments to the Policy requirements

The contract stage is where tender commitments are formalised. It ensures that negotiated requirements are accurately captured, achievable obligations are confirmed, and any agreed value‑adds are included before project delivery begins.

1. Liaise with Tender team to ensure the contract reflects what was agreed during the tender phase

• If not, request for the contract to be updated to reflect what was negotiated during the tender
• Ensure any requirements we cannot achieve are not in the contract

2. Liaise with Project Delivery team to ensure those commitments can still be met and ensure any ways we can add value are in the contract

3. Document any exclusions or negotiated amendments

The planning stage ensures that Aboriginal participation requirements are embedded into project delivery from the outset. It sets clear responsibilities, establishes processes for compliance, and prepares the team to collect and report accurate data throughout the project lifecycle.

1. Nominate a project lead. This person will be responsible for:

• Conducting a hand over with the Contract Negotiation team to understand the Aboriginal participation requirements
• Ensuring the Aboriginal participation requirements are met throughout the project
• Reporting project outcomes to the head contractor

2. Write a project plan to ensure smooth compliance throughout the project delivery and clarify roles and responsibilities

• Complete the Project Plan Template outlining the targets, action required to meet those targets, and reporting methodology
• Use the  Project Planning Guide to identify sourcing channels for Aboriginal participation
• The Project Plan in an internal working document used to assist the project team in delivering a compliant project. It’s not shared with the head contractor or developer.

3. Set up a data collection folders and templates

• Use the Folder Structure Guide to implement the data collection process in preparation for the project delivery stage

4. Train project team on the Policy and it’s requirements

• Give project staff access to this training module
• Learn more about the Aboriginal Procurement Policy in the Requirements Guide

The delivery stage is where plans are put into action. It focuses on engaging Aboriginal businesses and workers, collecting accurate evidence of participation, and reporting progress to the head contractor. Strong delivery ensures compliance with the Aboriginal Procurement Policy and demonstrates tangible outcomes.

1. Follow the Project Plan

• The project lead is responsible for ensuring the project team are following the Plan
• Engage Aboriginal businesses and workers as outlined in the Plan
• Partner with oganisations to deliver capability uplift to Aboriginal businesses and workers

2. Collect evidence

• Record Aboriginal employment and contracts with Aboriginal businesses using the Social Procurement Tracker 
• Include subcontractor and supplier outcomes for Aboriginal employment and contracts

3. Submit reports to the head contractor monthly with your progress claim

• Use the Monthly Reporting Template to provide consistent and accurate updates

The close‑out stage captures the results of the project and ensures lessons are carried forward. It focuses on reporting achievements, documenting outcomes, and refining processes so future projects can build on what has been learned.

1. Provide the head contractor with a final report to showcase project outcomes

• Use the Project Completion Report Template

2.Draft a case study for use in future tenders

• Refer to Case Study Template to highlight key achievements and demonstrate capability

3. Document achievements and lessons learned

• Use Project Reflection Template to record successes and areas for improvement

4. Reflect and adjust

• Apply insights gained to strengthen Indigenous participation strategies in upcoming projects
• Adjust any templates or processes to improve efficiencies on future projects