Topic 3: Priority Start Policy

• Headcount data of in-scope trades workers (including labor hire)
• Headcount data of in-scope apprentices and trainees (include workers through Group Training Organisations)
• All in-scope trades workers, apprentices and trainees working in WA during the reporting period, NOT just those working on the project

• In-scope trades workers, apprentices and trainees outside of the reporting period

• Training agreements
• Employment contracts
• Timesheets
• Payroll data

• Project name
• Your ABN
• Reporting period
• Head count of in-scope trades workers, apprentices and trainees

• May be treated as a contract breach
• Possible penalties include:
  • Withholding of payments
  • Liquidated damages
  • Loss of future tendering opportunities
• Non-compliance damages company reputation with both government and community
• Can trigger audits and further investigation

• 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 Priority Start Policy and identify how the head contractor expects us to contribute to the apprentice targets. 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 apprentice, cadet etc 

2. Can we meet the contractual clauses asking us to contribute to apprentice targets?

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

NOTE: Keller avoids committing to apprentice and trainee targets in our contracts. Engineering and civil construction don’t have formal apprenticeship qualifications, so our scope of works falls outside this framework, and targets are not achievable. Instead, Keller invests in cadetships, delivering practical pathways into the industry, without over committing.

3. Showcase our previous performance for apprentices

• Submit the Past Performance Template with the tender submission

4. Provide a written statement of how we can contribute to the head contractor’s apprentice percentage

• Complete the Social Procurement Commitments Template with project‑specific apprentice opportunities
• Flag any apprentice 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 apprentice 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
• We recommend removing contract clauses  committing to apprentice and trainee hours in our contracts. You can supplement this by offering to do additional Other Workforce Training hours or offering apprentice and trainee hours performed offsite. Refer to the Social Procurement Planning Guide for assistance in providing additional value.

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 apprentice targets 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 handover with the Contract Negotiation team to understand the apprentice targets
• Ensuring the apprentice targets are met throughout the project
• Reporting project outcomes to the head contractor in monthly progress claims

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

• Complete the Project Plan Template outlining the apprentice targets, actions required to meet those targets, and reporting methodology
• Use the Social Procurement Planning Guide to identify sourcing channels for apprentices
• The Project Plan is an internal working document used to assist the project team in delivering a compliant project. It is not shared with the head contractor or Agency

3. Set up 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 the project team on the Policy and its requirements

• Give project staff access to this training module
• Learn more about the Priority Start Policy by reading the Fact Sheet

The delivery stage is where plans are put into action. It focuses on meeting the targets, collecting accurate evidence and reporting progress. Strong delivery ensures compliance with the Policy and demonstrates tangible apprentice outcomes.

1. Follow the Project Plan

• The project lead is responsible for ensuring the project team follows the Plan
• Deliver apprentice commitments as outlined in the Plan

2. Collect evidence

• Record apprentice and trainee outcomes using the Training Tracker and Social Procurement Tracker
• Include subcontractor contributions

3. Report progress

• Submit apprentice and trainee outcomes to the head contractor or Agency at the end of each financial year using the Reporting Template

The close out stage captures the results of the project and ensures lessons are carried forward. It focuses on reporting achievements, documenting apprentice and trainee 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 Reporting Template to summarise compliance with apprentice and training and trainee targets

2. Draft a case study for use in future tenders

• Refer to the Case Study Template to highlight key achievements and demonstrate capability in meeting apprentice and trainee targets

3. Document achievements and lessons learned

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

4. Reflect and adjust

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