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DOC 01 ALDI FOODS PTY LIMITED applicant for the conditional grant of a liquor store licence ALDI WHITFORD CITY Westfield Whitford City Shopping Centre Marmion Avenue, Hillarys PUBLIC INTEREST ASSESSMENT Prepared by Lavan on behalf of ALDI Foods Pty Limited Ref: Jessica Patterson jessica.patterson@lavan.com.au T: (08) 9288 6946 www.lavan.com.au © Lavan 2019
Public Interest Assessment
ALDI Whitford City
Table of Contents
1 Introduction 2
2 Overview of proposal 3
Consultation 7
Community demand 8
3 Applicant’s details and background 9
ALDI supermarkets 16
ALDI pricing and promotion 18
4 ALDI liquor model 20
The premises 22
Stock range 24
ALDI Exclusive Products 25
Low risk features of the proposal 28
5 Locality 29
Nature and character of local community 31
Westfield Whitford City Shopping Centre 33
6 Section 5 38
7 Harm or ill-health – section 38(4)(a) 39
At risk groups and sub-communities 39
Social health indicators 42
Minimising harm and ill-health 45
8 Impact on amenity, quiet or good order – section 38(4)(b) 53
Outlet density 53
9 Offence, annoyance, disturbance or inconvenience – section 38(4)(c) 63
10 Tourism, community or cultural matters – section 38(4)(ca) 65
11 Other matters 67
Patronage 67
Security and crime prevention 67
12 Conclusion 70
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1 Introduction
1.1 ALDI Foods Pty Limited (ACN 086 210 139) seeks the conditional grant of a liquor
store licence to operate from a small space within the new ALDI supermarket that will
be constructed at Westfield Whitford City Shopping Centre, Marmion Avenue,
Hillarys. If granted, the licence will trade as ALDI Whitford City.
1.2 This detailed Public Interest Assessment (PIA) supports the application and
addresses all relevant aspects of the public interest in accordance with both the
Liquor Control Act 1988 (WA) (Act) and the licensing authority’s Public Interest
Assessment policy1 (PIA Policy).
1.3 Pursuant to the PIA Policy, the standard Locality for Hillarys is a 3km radius area
surrounding the proposed site (Locality).
1.4 This PIA is part of the Applicant’s Case and should be read in conjunction with the
other parts, all of which are itemised in the document titled Index of Material Before
the Director and Applicant’s Case (Index). Where this PIA cites particular documents
with “DOC” followed by a number (eg “(DOC 1)”), it references material in the
Applicant’s Case by way of its listing in the tables contained within the Index.2
1.5 In particular, referred to throughout this PIA are two detailed reports prepared by
experts that the applicant engaged in respect of this application (DOCS 8 and 9).
1.5.1 Patterson Research Group3 (PRG) surveyed people living in the Locality to
assess their attitudes toward the ALDI liquor proposal. This research was
done in June 2019 through a series of expertly prepared questions that
were put to a representative sample of residents.
1.5.2 Deep End Services4 (DES) has provided expert in-depth analysis of the
Locality, including a detailed analysis of demographics, planning policies
and strategies, trade catchment and density of licensed premises.
1.6 The findings in the reports prepared by these two experts supplement the applicant’s
own research and submissions in this PIA. Collectively, the documents provide a
significant volume of evidence to support the Applicant’s Case for the grant of the
ALDI Whitford City licence.
____________________________________________________________________________
1
https://www.dlgsc.wa.gov.au/department/publications/publication/public-interest-assessment-policy. Last amended 3
October 2018
2
Supporting material referred to in this document not produced by or for the applicant has been obtained from public sources
under licence. Where relevant, personal information within the supporting material has been redacted for privacy reasons.
Full copies of some of the source material accompany this PIA and are listed in the Index. Other material not so listed in the
Index can be made available in full if required and has only been left out of the Index to lessen the burden of paper on the
licensing authority.
3
https://www.marketresearch.com.au/about_us/overview.phtml
4
http://deependservices.com.au/index.php/about-us/
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2 Overview of proposal
2.1 This application is made by a highly sophisticated and experienced packaged liquor
operator, which enjoys extensive supermarket and liquor retailing experience within
Western Australia, elsewhere here in Australia and overseas.
2.2 ALDI has been operating in Australia since 2001 when the first ALDI store opened in
Sydney. There are now over 580 stores throughout Australia, including
approximately 520 stores in the eastern states. Around 330 of those stores in the
eastern states include a liquor component.
2.3 The company is in the midst of a $700 million expansion into other states in Australia,
with approximately 70 stores to open in Western Australia and up to 50 stores in
South Australia in total.
2.4 ALDI opened its first four supermarkets in Western Australia on 8 June 2016. By the
end of 2016, ALDI had opened 19 stores in total and served approximately 3.2 million
WA shoppers.5 There are currently 43 supermarkets operating throughout this State,
with several more expected to open this year.
2.5 ALDI is one of the largest and most popular retailers in
the world. Some customers are such passionate and
dedicated fans of ALDI’s wide range of household and
consumable products that they have developed their
own name, “ALDIholics”. There is a customer-driven
Facebook page named, ALDIholics, with its own logo
depicted to the right,6 devoted to information for ALDI
lovers.
2.6 Further in terms of social media, ALDI boasts strong following and popularity, as
shown in the screenshots below.7 These mediums are the modern day voice of the
public and significant representations of community sentiment.
5
http://www.perthnow.com.au/news/western-australia/aldi-to-open-14-more-stores-in-wa-in-2017/news-
story/0de29965fcd9712852ab9b2919908286
6
https://www.facebook.com/ALDIholics/
7
https://www.facebook.com/ALDI.Australia/ and https://www.facebook.com/ALDI.Australia/app/116943498446376/
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ALDI Whitford City
2.7 The emergence of the ALDI retailing concept into Western Australia, following the
company’s significant popularity in the eastern states, has been and continues to be
exciting and highly anticipated from the general public’s perspective.
2.8 The proposal is for a small liquor display/browse section of only approximately 30m2
within the ALDI Whitford City supermarket. A carefully selected and exclusive range
of unrefrigerated liquor is proposed to be available in a discrete and clearly
designated licensed area within the supermarket.
2.9 This liquor model is entirely unique to ALDI. Its various features referred to
throughout this PIA, make for a bespoke manner of trade. The boutique type of liquor
service is designed specifically to complement and accompany the diverse and
attractive ALDI supermarket services and facilities. This creates a true one-stop-
shopping8 convenience for customers, which is a key feature of the ALDI offering.
2.10 The ALDI liquor service was first made available in WA at the end of August 2017 in
five of its supermarkets. A total of 35 ALDI supermarkets have been approved to sell
liquor in WA, 26 of which are currently operating with the liquor service.
8
This is addressed in detail in the applicant’s accompanying Legal Submissions (DOC 7).
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ALDI Whitford City
2.11 The ALDI liquor offering is described as follows by ALDI Australia’s Wine and
Sparkling Buyer, Mr Jason Bowyer:9
Like our grocery offer, ALDI’s liquor range is focused, ensuring that we offer great value
and exceptional quality. Since establishing in WA more than a year ago, customers
have spoken loudly about their desire for us to bring our popular liquor offering to the
West.
ALDI partners with a number of high calibre international and Australian wine suppliers,
who each share our passion for quality. We have built strong relationships with these
suppliers, who are committed to ensuring that our wine products offer great value at their
respective price points.
2.12 In recognition of the launch of the ALDI liquor
service in WA, renowned wine expert Ray Jordan
was invited to sample six of the wines in ALDI’s
WA stores. Mr Jordan remarked that one of the
wines in particular, being a $7 bottle of One Road
South Australian Heathcoate Shiraz 2015
(pictured to the right), was “damn good”.10 That
Shiraz has also won several other awards,
including Double Gold & Best Value Shiraz of the
Year at the 2017 Melbourne International Wine
Competition. This Shiraz is just one example of
ALDI’s many high quality, value-for-money, award
winning liquor products.
2.13 The debut of the ALDI liquor service in WA was widely embraced by the public. The
announcement on the ALDI Australia Facebook page11 (pictured below on the left)
received a swarm of favourable reactions. Many of the comments revolved around
members of the public wanting the liquor service at their local ALDI supermarkets.
Some examples are provided below.12 There is clearly a significant demand for the
ALDI liquor service throughout WA. This anticipated demand has since translated
into significant patronage and sales at the ALDI liquor stores that have begun trading.
9
https://www.aldi.com.au/fileadmin/fm-dam/Products/Groceries/Liquor/WA_Launch/ALDI_Media_Release_-
_WA_Liquor_Launch_1_.pdf
10
http://www.perthnow.com.au/news/western-australia/aldi-will-start-selling-alcohol-in-perth-stores-from-today/news-
story/c59014afc215ba475dd1265a0e89eb4c
11
https://www.facebook.com/ALDI.Australia/posts/1716136855110475
12
Personal details have been redacted for privacy reasons. A fully copy of the post can be provided to the licensing authority
if required.
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2.14 The layout of the ALDI Whitford City supermarket is pictured below. It shows the
proposed liquor display/browse area outlined in the bold red line. This is clearly a tiny
proportion of the overall supermarket footprint.
2.15 Pictured below is a 3D aerial image the area proposed to be licensed in respect of the
liquor display/browse and checkout area.
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2.16 This display/browse space will take the shape of a square and the displays
themselves will form a basic U shape. This design enables convenience and a high
level of surveillance of the area. The display/browse area will also comfortably
accommodate shoppers with their trolleys for added convenience.
2.17 The checkout closest to the liquor display/browse area is proposed to be licensed for
the purposes of the liquor transactions. Staff operating at this checkout will be able to
monitor all patron activity in this area.
2.18 The very small size and layout of the liquor display/browse area clearly confirms that
the liquor section is a complementary service to the supermarket and will help ensure
the area is well-controlled and supervised.
2.19 Additional details of the ALDI liquor offering are provided further on in this PIA.
Consultation
2.20 As part of its thorough preparation of this application, the applicant consulted
extensively with relevant authorities and the local community. In doing so, the
proposed liquor service has been explained and feedback sought.
2.21 The following consultation has been undertaken:
2.21.1 In 2013 a representative from the applicant company met with officers from
the Racing, Gaming & Liquor arm of the Department of Local Government,
Sport and Cultural Industries (as it is now known) and notified the
Department in July 2015 that applications for liquor store licences would
soon be lodged. The applicant has subsequently liaised with the
Department in respect of modifications.
2.21.2 Representatives from ALDI and Lavan met with Police officers in the Liquor
Enforcement Unit on 31 July 2015.
2.21.3 Representatives from ALDI and Lavan met with the Chief Health Officer on
31 July 2015 and again with representatives from the Chief Health Officer’s
office on 12 March 2019.
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ALDI Whitford City
2.21.4 An information and promotional flyer was distributed to households within
the Locality. A copy of that flyer is included in the Applicant’s Case (Pages 29
and 30 of DOC 8).
2.22 As referred to in the next section and also throughout this PIA, the applicant also
consulted extensively with the community through the market survey conducted by
PRG. The findings from the survey are contained in the expert’s report (DOC 8) and
show overwhelming support for the proposal and demand for the liquor service.
Community demand
2.23 The market research found that an estimated 98% of people it surveyed would at
least try the ALDI Whitford City supermarket when it opens.13
2.24 Specifically as to the liquor proposal, the market research reveals demand from the
local community for the ALDI liquor service. “[A]lmost nine in ten (88%) respondents
who ever buy packaged alcohol indicated that if shopping in an ALDI store which
contained a liquor section, they would purchase their take-away liquor requirements
in that store. This proportion was heightened to 92% amongst respondents who buy
packaged alcohol at least once a month.”14
2.25 The ALDI liquor display/browse area being confined within its supermarket footprint
was found to be of at least moderate appeal by 92% of respondents who are
packaged liquor buyers.15
2.26 The following extract from the PRG report (DOC 8) also supports the proposition that
the ALDI liquor concept certainly has the potential to change and enhance the
shopping behaviours of the local community:16
The packaged alcohol purchasing pattern for this locality shows that currently the most
common pattern of buying packaged liquor is on a special shopping trip to a “walk in and
browse” store. 46% report doing all or most of their packaged liquor purchasing on a
special trip to a “walk in and browse” store, compared to 28% who shop for their
packaged liquor requirements in connection with their grocery shopping.
The finding that a further 30% report buying their packaged liquor requirements on about
half their liquor shopping occasions (creating a net of 58% who report that they do so on
at least half their grocery shopping behaviours) suggests an emerging behaviour
pattern of purchasing alcohol in conjunction with grocery shopping, though with
the potential to expand further. (Emphasis added)
It was not surprising to find that the option of being able to buy their packaged liquor
requirements from a liquor section within the grocery store would be seen as more
convenient.
13
PRG report (DOC 8) at page 5
14
PRG report (DOC 8) at page 5
15
PRG report (DOC 8) at page 16
16
PRG report (DOC 8) at page 5
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ALDI Whitford City
2.27 The local community members are entitled to enjoy the full range of ALDI’s offering,
including its liquor service. The ALDI retailing concept is enormously popular with
shoppers all around Australia and in other countries.
2.28 Further in terms of ALDI’s popularity within the general community, in response to the
initial refusal of the ALDI Harrisdale liquor store licence application at first instance in
June 2016, a massive 8,637 people took it upon themselves to participate in an
Internet survey conducted by Nine News Perth which asked: “Do you think ALDI
should be banned from selling alcohol because it’s too cheap?” Within just two days
86% of those who participated answered “no”. This represents a staggering 7,428
people. A print out of the survey results and the thousands of personal comments in
support of ALDI in Western Australia is included in the Applicant’s Case (DOC 17).
Relevantly, the survey was conducted without any involvement from the applicant. It
was totally unsolicited.
____________________________________________________________________________
3 Applicant’s details and background
3.1 ALDI now operates more than 10,000 stores across 18 countries. The company has
become a world-leading supermarket operator since it was founded in 1913 in
Germany as a family business. The following provides some detail about the history
of the organisation.17
The first foundation stone was laid in 1913 with the opening of a small food store in the
German town of Essen. It didn't take long for this little 'service store' to become a
popular place to shop.
During the '40s, an expansion program was created and more ALDI stores were
opened. In 1954, a celebration was held for the opening of the 50th store in Germany.
By 1960 ALDI had grown to a network of over 300 stores between the Ruhr Valley and
Aachen. The prosperous family business was then divided into two independent
companies: ALDI Süd - to service the South, and ALDI Nord - for the North.
'Self-service' was still a relatively new retail structure in the '60s and ALDI became the
first company in Germany to adopt this new retail concept. While customers were still
able to take advantage of the same high quality products as before, they could now
purchase them at much more competitive prices.
In 1983, ALDI Süd started chilled distribution depots and sold fresh products such as
cheese, yoghurt and sausages. Frozen products came in 1998 and were closely
followed by fresh meat. ALDI, to this day, continues to keep up with the ever-evolving
taste of the modern consumer.
3.2 ALDI’s published mission is to provide the public with “incredibly high quality at
impossibly low prices.”18 This is achieved through a highly sophisticated business
model involving a very focused selection of products and advanced levels of
17
https://corporate.aldi.com.au/en/about-aldi/aldi-history/
18
https://www.aldi.com.au/en/about-aldi/customer-information/
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ALDI Whitford City
systemisation and organisation designed for optimum efficiency and product control.
ALDI is dedicated to maintaining consistency in its philosophy of incredibly high
quality at impossibly low prices.
3.3 ALDI is a responsible and sophisticated corporate citizen and operates pursuant to
very high standards and key performance indicators, which include the following
published principles:19
ALDI works to ensure customers quality products at the best price. Our responsibility to
customers is intrinsically linked to the health and nutrition of all our products, and we are
constantly reviewing our range to improve its nutritional content.
We have a number of initiatives that go above and beyond mandated legal
requirements. These include:
• Providing clear product information, including easy to read nutritional and allergen
labelling
• Maximising the positive nutritional benefits of our products through dialogue with
independent bodies
• Minimising any potential harmful impacts of our products
• Meeting or exceeding nationally recognized standards for health and safety
3.4 Included in the Applicant’s Case is a copy of the ALDI Corporate Responsibility Policy
(DOC 11) and other ALDI published policies in respect of consumers, resources,
suppliers, operations and community (DOC 12). These policies, together with other
information in this PIA, collectively illustrate the applicant’s very high standards and
superior level of corporate responsibility.
3.5 ALDI has published the following statements in its Smarter Shopping brochure (DOC
16):
We are exacting in our pursuit of quality and work closely with all our suppliers to deliver
products that meet stringent international standards for quality, nutrition and taste. Every
single product that appears on ALDI’s shelves has been sampled, tested and signed off
by senior management before it is added to our range.
Once it is in our stores, the rigour does not stop there. Each and every product that
appears on our shelves is tested a number of times throughout the year to ensure it still
meets the strict specifications we set at the very beginning.
3.6 ALDI’s corporate responsibility principles also apply to its partners and suppliers. For
example:
3.6.1 ALDI encouraged Australian suppliers to support and work with a range of
international ethical sourcing groups. The following was reported in
September 2017:20
19
https://corporate.aldi.com.au/en/corporate-responsibility/consumers/
20
http://www.ausfoodnews.com.au/2017/09/11/aldi-tightens-supplier-corporate-social-responsibility-standards.html
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ALDI Whitford City
Aldi has asked Australian suppliers to sign up to a range of international ethical
sourcing groups and start auditing their own supply chain and manufacturing
systems.
…an Aldi spokesperson said Aldi’s corporate responsibility principles guide Aldi
through its day-to-day actions and it is important it partners closely with its suppliers
to achieve high standards.
“In addition to requiring high social standards throughout the supply chain, we also
aim to: source raw materials responsibly, lessen our impact on the environment,
support Australian businesses and give back to the communities we operate in, and
help make healthy choices affordable for our customers,” Aldi’s spokesperson said.
3.6.2 ALDI announced in October 2017 that it will help support the delivery of the
New South Wales Government’s sustainability initiative, dubbed Return and
Earn Container Deposit Scheme. The initiative aims to halve the number of
bottles and cans thrown away in parks, beaches and waterways. In a
statement, ALDI said it was “committed” to supporting and “participating in
the largest litter reduction initiative in NSW.”21
3.6.3 Most recently, ALDI announced its goal to “reduce the amount of plastic
packaging by 25 per cent by 2025 through a number of steps, including
replacing the packaging of fresh produce to more sustainable alternatives
and phasing out unnecessary single-use plastics by the end of next year”22.
The company will work with its business partners to identify ways and
innovate solutions to reduce their reliance on plastics.
3.7 ALDI operates pursuant to a highly-evolved corporate structure (DOC 10) and very
sophisticated hierarchy whereby staff at each level are entrusted with a high degree
of responsibility and are provided with extensive and comprehensive training and
support.
3.8 ALDI’s pursuit of excellence and quality in all things is evident in the many accolades
it has won in Australia. The following paragraphs describe some of its awards just
within the past couple of years.
3.8.1 ALDI was named the 2016 Retailer of the Year by the Australian Retail
Association.23 In awarding ALDI this prestigious title, the Australian Retail
Association noted that a key factor behind the organisation being selected
was its strong track record for creating innovative staff programs, investing
heavily in its staff with above-industry standard pay and staff development
opportunities. ALDI won the award “in recognition of its growth, influence
and market leading policies, which have seen the supermarket chain
21
https://www.insideretail.com.au/blog/2017/10/10/woolworths-and-aldi-sign-up-to-can-scheme/
22
https://www.heraldsun.com.au/business/companies/aldi-announces-plastic-bag-ban-support-will-phase-out-singleuse-
plastic-by-2020/news-story/0737f2d3da9e6547efee0a28eda09803
23
http://www.smartcompany.com.au/industries/retail/73746-aldi-crowned-australias-retailer-year-embarks-major-expansion-
100-new-stores/
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significantly challenge the majors in its category and beyond with the
implementation of innovative sales approaches.”24
3.8.2 ALDI was also nominated Roy Morgan Research Supermarket of the Year
2016. This is the fourth time since the customer satisfaction-based awards
were first established in 2011 that ALDI has claimed this title.25
3.8.3 ALDI won several awards in BrandSpark International’s 2017 Best New
Products Awards, “taking out the top prize in 16 different categories,
including household cleaning, skin-care and fabric softener.”26
3.9 ALDI’s momentum in achievements has not stopped. Just last year alone the
company was recognised for its popularity and success in the market place:
3.9.1 In July 2018 it was announced that ALDI was voted as “the most trusted
brand” in Australia in a Roy Morgan Research survey.27 It was reported
that the success of this global retailer in the Australian market “has been
built not only on discount prices but also a reputation for reliability and
meeting the needs of consumers.” Roy Morgan Research highlighted that
important drivers of trust “include reliability, customer focus, knowledgeable
staff, ease of contact and previous good experiences with the company, in
addition to other key performance indicators.” This latest accolade of
ALDI’s is a testament to its high level of corporate social responsibility and
dedication to its customers.
3.9.2 ALDI recently rated at the top of Canstar Blue’s 2019 customer satisfaction
ratings for supermarkets, again.28
24
https://www.retail.org.au/mediacentre/australias-top-retailers-crowned-at-2016-eftpos-ara-australian-retail-awards/
25
https://www.aldi.com.au/en/groceries/awards/roy-morgan-supermarket-of-the-year-2016/. Roy Morgan Research is
Australia’s best known and longest established market research company, https://www.roymorgan.com/about
26
http://www.ausfoodnews.com.au/2017/02/20/products-of-the-year-awards-for-2017-announced.html
27
https://www.roymorgan.com/findings/7653-aldi-most-trusted-brand-in-australia-201807060755
28
https://www.canstarblue.com.au/stores-services/supermarkets/. Canstar is Australia and New Zealand’s premier research
and expert ratings agency: http://www.canstarblue.com.au/about-canstar-blue/
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3.9.3 In October 2018, ALDI was crowned 2018 Retail Employer of the Year at
the Australian Retailers Association awards. “To be in the running, [ALDI]
had to demonstrate a strong track record across a range of areas, including
staff education, training and development, internal communication,
community support programs and Corporate Social Responsibility”.29 The
Association remarked that “ALDI have proven to be “fierce contenders” with
a strong commitment to diversity, non-discrimination and support to all
29
https://www.aldiunpacked.com.au/Article/October-2018/ALDI-crowned-Retail-Employer-of-the-Year
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employees.”30 The Association even considered ALDI to be “pioneers in
the retail sector”.31
3.10 More specifically, ALDI is also an award-winning retail liquor supplier. ALDI was
named Liquor Store of the Year 2017 at the Roy Morgan Research Customer
Satisfaction Awards.32
3.11 These awards by Roy Morgan Research recognise companies across a range of
industries that go the extra mile to please its clients and customers. These awards
are “the benchmark by which customer satisfaction is measured in Australia, New
Zealand and Indonesia. Reliable, accurate and totally objective, the Australian
awards reflect the experiences of some 50,000 consumers, as aggregated in [Roy
Morgan’s] Single Source survey over 12 months.”33 There can be no question as to
the credibility of these awards and certainly no doubt that ALDI customers are
immensely satisfied with the liquor service ALDI provides.
3.12 Jason Bowyer gave the following remarks on this achievement of ALDI’s:34
At ALDI Australia, we are delighted to win the Roy Morgan Customer Satisfaction Award
for Liquor Store of the Year 2017. We believe that all our products, from our award-
winning $19.99 Monsigny Brut Champagne to our red and white wines, deliver
exceptional value, quality and consistency. It’s great to see our customers across
Australia agree.
Our success is based on the close relationships we have with our suppliers, who all
share our passion for awesome quality. Aldi partners with some of the best producers
and winemakers both in Australia and internationally, which means we can deliver
exceptional quality, value and consistency to our customers. Our partnerships with our
suppliers are focused on a desire to see the customer win with great-tasting wines at
unbeatable prices.
3.13 The title of Liquor Store of the Year 2017 follows many individual product awards that
ALDI has received locally and internationally over the years. “It recognises the
30
https://insidefmcg.com.au/2018/10/19/aldi-awarded-ara-employer-of-the-year/
31
https://insidefmcg.com.au/2018/10/19/aldi-awarded-ara-employer-of-the-year/
32
https://www.aldi.com.au/en/groceries/awards/roy-morgan-liquor-store-of-the-year-2017/
33
http://www.roymorgan.com/findings/7505-roy-morgan-announces-winners-of-the-2017-customer-satisfaction-awards-
201802201125
34
https://www.theshout.com.au/news/aldi-wins-roy-morgan-liquor-store-year/
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unique value ALDI can offer [its] customers with [its] tightly focused range,
unwavering passion for quality and longstanding relationships with local and
international suppliers.”35
3.14 ALDI certainly enjoys many accolades for its exclusive product range (DOC 14). The
following are but a few examples of ALDI’s acclaimed liquor products and awards
won over the past several years:
3.14.1 In 2014: “The Sydney International Wine Competition found a $6.99
Cabernet Sauvignon from South East Australia and a $9.99 Semillon,
blended specifically for the Aldi discount supermarket chain, to be in its top
100. And Aldi’s $4.99 Spanish Tempranillo snagged a Blue Gold award —
the equivalent of a silver medal.”36
3.14.2 In 2015: “The Sydney International Wine Competition has deemed Aldi’s
discounted wine offerings among the best of the best”.37
3.14.3 In 2016: ALDI’s Prosecco “was voted as the ‘Best Value Buy’ in Winestates
Annual Edition 2016” and “based on the frequency by which it was out of
stock during the summer months, has been a strong performing item for
Aldi”.38
3.14.4 In May 2017: “The $8 Aldi Côtes de Provence Rosé has taken out an
amazing silver medal at the International Wine Challenge – an event
dubbed ‘The Oscars of the wine Industry’, according to The Sun UK. The
award-winning drop was competing against bottles three times its price,
even beating a vintage version of the drop, which retails for over $30”39.
3.14.5 In June 2017: ALDI’s Highland Black Eight-Year-Old Scotch Whiskey
received a Double Gold prize in the Melbourne International Spirits
Competition. This product “beat some rivals valued three times more in
price”.40
3.14.6 In July 2017: ALDI’s Oliver Cromwell London Dry Gin won a gold medal at
the International Spirits and Wine Competition and was named one of the
best gins in the world.
35
https://www.aldiunpacked.com.au/Article/May-2018/Lifting-the-lid-on-ALDI’s-liquor-story
36
http://www.news.com.au/lifestyle/food/drink/six-of-aldis-cheap-wines-judged-among-best-at-sydney-international-wine-
competition/news-story/eb163e6f8d5e9b85a5522a8d1b622d50
37
Australian National Retailer, February 2015 at page 16: http://en.calameo.com/read/0003734959f4c8982c4bc
38
ALSA – IRI State of the Industry Report, March 2017 (DOC 22) at page 62
39
http://www.elle.com.au/culture/aldi-rose-is-one-of-the-best-wines-in-the-world-13255 and
http://fortune.com/2017/05/30/best-rose-wine-challenge-aldi/
40
http://www.news.com.au/lifestyle/food/drink/35-aldi-whisky-takes-out-top-prize-for-being-a-phenomenal-drop/news-
story/14ca83dce732c7f46232a283eff29110
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ALDI Whitford City
3.14.7 In August and November 2017: ALDI’s $6.99 bottle of One Road South
Australian Heathcoate Shiraz 2015 won the Double Gold award at the 2017
Melbourne International Wine Competition and the Gold medal at the Great
Australian Shiraz Challenge.
3.14.8 In October 2018: ALDI’s Blackstone Paddock Limited Release Chardonnay
2017 took home two awards at the 2018 Wine Show of Western Australia.41
This wine retails for just $14.99 and is exclusive to ALDI. Even at its price
point, this Chardonnay “beat a hot field of WA chardonnays that included
other more famous gold medal winners such as Vasse Felix Heytesbury,
Flametree SRS Wallcliffe, Xanadu Stevens Road and Deep Woods Estate
SV in winning the best chardonnay and best white wine of the show.”42
3.15 The various accolades described above, which are only a few examples, “[paint] Aldi
in a positive light and [they reinforce] the fact they’re offering quality products at a
value price.”43
3.16 ALDI has clearly enjoyed great success across various aspects of its organisation,
including liquor. In another online article published this year44, Jason Bowyer briefly
explains some of the company’s strategies and its plains to maintain its success in
the year ahead:
“Quality and value have always been the main focus for us. When you are focused on
the customer, it’s easier to produce wines they will like and will also perform strongly in
the show circuit. Everything we do is designed with one purpose in mind: to provide the
highest quality products at the best possible prices.
…
“We constantly look for innovation, studying consumer trends and looking domestically
and abroad for new varietals and styles. Rosé is certainly the hot topic at the moment
and we will be focusing on this category, bringing a range of styles and regions to our
customers. Early in 2019 we will launch a Soave (a dry Italian white wine) under our
Corte Carista brand.”
As well as Rosé, Aldi is looking to focus on the growing popularity of sparkling wine
which Bowyer believes is driven by customers’ desire for “aspirational products” and
“affordable luxury”. He sees these approaches as “undeniably different” and knows that
looking ahead, he relishes the challenge of taking things another step further.
ALDI supermarkets
3.17 ALDI supermarkets generally comprise a total footprint of around 2,000m2. Some are
located in shopping centres (such as at Whitford City), while others are free-standing.
41
https://insidefmcg.com.au/2018/10/10/aldis-15-chardonnay-bags-wa-wine-award/
42
https://thewest.com.au/lifestyle/drink/aldi-chardonnay-is-best-white-wine-in-state-ng-b88983629z
43
http://www.smartcompany.com.au/industries/retail/aldi-wins-two-awards-alcohol-whats-unassuming-underdog-right/
44
https://www.theshout.com.au/national-liquor-news/aldi-puts-trust-in-affordable-luxury/
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ALDI Whitford City
3.18 Consistent with other ALDI stores, the Whitford City store will comprise the following
different parts or areas, listed in order of size in terms of the approximate portion of
the total area:
3.18.1 Main public retail area (non liquor) – grocery and other supermarket items.
3.18.2 Storage.
3.18.3 Loading dock/delivery area.
3.18.4 Entrance and trolley bay.
3.18.5 Checkout.
3.18.6 Office and staff facilities.
3.18.7 Liquor display and browse area (proposed).
3.19 ALDI stores are bright and pleasant shopping environments. The following images
depict the stylish and clean appearance that will be found at the ALDI Whitford City
store:
3.20 ALDI operates a generic store modelling concept. The size, layout, colour, product
location and stock range of each ALDI store are almost always the same. Minor
differences may occur from time to time at some stores owing to land formation, town
planning requirements or other unique particulars of the site. For example, the
entrance door may be positioned a few metres away from its usual position to suit a
particular location.
3.21 The standardisation of store layouts engenders familiarity for customers, enhances
shopping comfort, efficiency and convenience. It also enables customers to rely on
consistency of style, standard and overall offer. Importantly, these are key features of
the applicant’s successful superior efficiency model of operation which benefits
customers enormously and is clearly popular with shoppers.
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ALDI Whitford City
3.22 ALDI supermarkets contain only around 1,350 core product lines. There are limited
brand options within each different product line. For example, ALDI may offer only
two or three different brands of plain flour, rather than five or more as is commonly
stocked at most supermarkets. This enables ALDI to operate from a smaller and
more user-friendly footprint and with a more exclusive and carefully selected range.
3.23 Many of ALDI’s products are exclusive versions of mainstream big-brand name items
which are manufactured according to ALDI’s strict specifications to ensure quality and
value for money. Expressi Coffee is one of the most popular examples. The
Expressi Coffee capsule machine and coffee capsules were category winners in the
2017 Product of the Year awards.45 ALDI’s Smarter Shopping corporate brochure
(DOC 16) provides further details of ALDI’s exclusive products.
3.24 ALDI’s liquor range also includes exclusive products that can only be purchased in its
stores. The ALDI liquor offer is explained in further detail later in this PIA.
3.25 “The majority of ALDI’s exclusive brands are sourced from Australian suppliers and
we only source products from overseas when we can’t find the product, quality,
efficiency or innovation we seek, here in Australia.”46
3.26 63% of ALDI shoppers surveyed in the eastern states have said that they buy more of
the ALDI exclusive products than well-known branded products.47
3.27 ALDI supermarkets offer a wide range of quality products including fresh food,
packaged food, other consumables and various household and personal items. In
addition, every Wednesday and Saturday “special buys” are promoted by ALDI which
are specialty short-term product lines that are usually non grocery items. Flat screen
televisions, furniture, clothing, appliances, BBQs, tools, gardening equipment,
vacuums and toys are just some examples. These have proven extremely popular in
the eastern states. Some are repeated occasionally, such as ALDI’s now well-known
annual line of ski gear popular in the eastern states which customers queue for each
year.48
3.28 Included in the Applicant’s Case are copies of pages from various “special buys”
catalogues, by way of examples (DOC 20). A very large and diverse range of products
can be seen to be on offer, including the popular clothing line by Colette Dinnigan,
Dyson vacuum cleaners and a six burner BBQ.
ALDI pricing and promotion
3.29 ALDI prides itself on consistently competitive pricing across all of its product lines and
providing customers with exceptional value for money. The company’s ability to
45
http://www.ausfoodnews.com.au/2017/02/20/products-of-the-year-awards-for-2017-announced.html
46
https://www.aldi.com.au/en/about-aldi/australian-made/
47
http://www.roymorgan.com.au/findings/6242-home-brand-products-have-way-to-go-with-grocery-buyers-201505202311
48
http://www.weekendnotes.com/aldi-snow-gear-sale/
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ALDI Whitford City
achieve such low prices for quality products stems from its highly sophisticated
business model which focuses on operational efficiency. With reference to a 2015
online article, the following are but a few examples of aspects of ALDI’s in-store
operations which heighten productivity and reduce waste:49
3.29.1 “One of the most visible examples is trolleys. To get one you must insert a
gold coin, which is refunded when you return it. That way Aldi doesn’t have
to pay anyone to hang out in carparks retrieving scattered trolleys.”
3.29.2 Products in ALDI stores are displayed on re-usable crates, designed
specifically for ALDI. The crates fit systematically in the ALDI warehouse,
delivery trucks and supermarkets. For example, ALDI’s multi purpose
beverage trays “can go from the factory to the truck to the supermarket floor
without being unpacked. It can store 1.25L bottles or 2L bottles. You
spend less on shelf stackers if you don’t need to stack shelves.”
3.29.3 ALDI’s products “have multiple barcodes or enormous barcodes…so the
checkout person needn’t fumble and fuss to scan them.”
3.30 ALDI’s shelving, storage methods, displays, product placement and other logistical
aspects are designed to coordinate with each other to achieve optimum operational
efficiencies for stocking products and store management. ALDI’s business is highly
systemised and disciplined. As a result ALDI is able to reduce operating costs and
provide better services and facilities for its customers.
3.31 ALDI does not operate by the regular retailing method of rotating discounts each day
or week. Rather, prices are maintained at a consistently low level. This means that
customers know what to expect when shopping at an ALDI store. It also reduces
costs and resources associated with the logistics of managing specials which involves
external promotion, advertising on site, changing ticket prices, reconfiguring product
placement, adjusting till systems and other processes. ALDI does not incur all of
these costs, thereby enhancing its operating efficiency.
3.32 Consistent pricing is also indicative of consistent quality. ALDI does not downgrade
its products through heavy discounting. In this regard in terms of liquor especially,
ALDI’s products very much represent value-for-money. High quality award winning
liquor items are provided at prices accessible to most people. The applicant is driven
by quality.
3.33 ALDI’s policies and practices clearly achieve the goal of managing costs for the
benefit of customers, whilst maintaining quality. ALDI was one of the two best
performers in 2017 for gaining share in the total grocery market, up 0.8% points to
12.1%.50 Indeed “[ALDI’s] influence is growing”51 over the consumer market with its
expansion in Australia.
49
http://thenewdaily.com.au/money/finance-news/2015/05/24/secret-aldis-super-low-prices/
50
http://www.roymorgan.com/findings/7537-woolworths-increases-lead-in-$100b-plus-grocery-war-201803230113
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ALDI Whitford City
3.34 The Australian Liquor Stores Association noted in its March 2017 report that
Australian “shoppers have migrated towards the value messaging of Aldi”.52
3.35 Canstar Blue also made the following statement about ALDI:53
While ALDI doesn’t have the same number of stores as Coles and Woolworths, it’s
fighting back against the duopoly with often lower prices, with its own brands offering
real competition against major brands stacked by other supermarkets. ALDI also
offers something different with its ‘Special Buyers’, one-off or seasonal products
ranging from specialty foods to snow gear to luxury skin cream.
3.36 At the opening of ALDI’s distribution centre in Jandakot in May 2016, former MLA Mr
Joe Francis noted that one of the biggest benefits of ALDI was going to come from
the downward pressure on prices that would be applied to the major supermarkets.54
His statement has clearly been confirmed by the evidence provided above.
3.37 ALDI’s approach to business is neatly encapsulated in its “Good Different” slogan,
which was launched in early 2017. Mr Thomas Daunt, one of the applicant company
directors, explained this campaign as follows: 55
ALDI Australia is unapologetically different –
and that’s a good thing for shoppers. We are
proud of our differences and we stand by
them wholeheartedly, as they are what allows
us to bring unbeatable value to our
customers, maintain strong relationships with
our suppliers and support our staff every day.
3.38 In many aspects, ALDI is distinctly different from alternative supermarket concepts.
Its range of products and services offer outstanding points of difference that have won
high favour with the public. The business model has huge popularity elsewhere in the
country and is proving just as popular in this State. ALDI attracts its own loyal and
faithful patrons who become regular repeat customers relying on ALDI’s consistency
of product, service and value for money.
4 ALDI liquor model
4.1 The ALDI liquor model is designed, in all respects, to complement the supermarket
and to provide adult shoppers with the dual benefit of ALDI’s liquor product range and
convenience of accessing those products whilst doing other household shopping.
51
http://www.ausfoodnews.com.au/2016/10/05/aldi-supermarket-shoppers-are-the-most-satisfied.html
52
ALSA – IRI State of the Industry Report, March 2017 (DOC 22) at page 14
53
https://www.canstarblue.com.au/stores-services/supermarkets/
54
http://www.watoday.com.au/wa-news/supermarket-giant-aldi-opens-60m-distribution-centre-in-jandakot-20160518-
goxuro.html
55
https://insidefmcg.com.au/2017/05/15/aldis-good-different-campaign/
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ALDI Whitford City
4.2 The ALDI liquor section proposed at Whitford City has been designed based on the
eastern states model originally, which has been replicated in WA and proven to
operate extremely successfully. The 35m2 display/browse and checkout area is a
very modest liquor outlet by usual industry standards, but highly valuable to
customers. The particular liquor stock range itself and also as combined with the
supermarket offer, represents a significant evolution in liquor retailing in Western
Australia.
4.3 This liquor model has been developed based on the ALDI’s many years of extensive
supermarket and packaged liquor retailing experience in Australia and overseas.
ALDI has been operating liquor services within supermarkets in Australia for more
than 15 years. The model has been extensively tried and tested in New South Wales,
Victoria and the Australian Capital Territory. In each jurisdiction it has proven to be
very successful and low risk. The ALDI business model and liquor area design and
layout operate with great success, are very popular with the public and have not
caused any undue issues with local governments, police or health authorities at over
300 locations in Australia.
4.4 The unique proposal, unrivalled in this State and having attracted considerable
custom in other locations, will provide the local community with something capable of
catering superbly for the diversity of modern consumer requirements.
4.5 The Whitford City liquor service will operate during the same hours as the
supermarket, subject to permitted trading hours under the Act,56 which the applicant
seeks approval for. If the supermarket were to operate outside of the approved
licensed trading hours, the liquor display/browse area would be clearly closed off to
customers.
4.6 There are many aspects to the ALDI liquor model which differ from virtually all other
packaged liquor outlets. The following key unique aspects of this model, which will
apply at Whitford City should the application be approved, are highlighted:
4.6.1 Combination of the ALDI Whitford City liquor service with the ALDI
supermarket. A one-stop-ALDI shopping convenience.
4.6.2 One transaction convenience.
4.6.3 ALDI exclusive product range.
4.6.4 Its small size and location within the supermarket.
4.6.5 Absence of refrigeration.
4.6.6 Absence of external presence of the liquor section.
4.6.7 The particular level of surveillance of the display/browse area which can be
seen and monitored by staff at all times in its entirety.
56
Namely 8am to 10pm Monday to Saturday and 10am to 10pm on Sunday, with variations for ANZAC Day, Good Friday,
Christmas Day
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ALDI Whitford City
4.6.8 Combined beneficial effects of the features listed above which are
supplemented by the overall manner of trade and harm minimisation
features identified.
The premises
4.7 The following artist illustrations show the proposed sectioned-off licensed area which
is to be established at ALDI Whitford City.
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ALDI Whitford City
Liquor
browse/display area
4.8 The image on the right is indicative of how
the proposed display area will appear from
within the approximate 30m2 of shelved
space. Uncluttered and uncomplicated,
easily accessed, light and bright.
4.9 It is obvious from the above images that the
position, layout and small size of the liquor
display/browse section enable very clear and
uninterrupted visibility of and supervision into
this area. This assists with security,
surveillance, management and control by
staff.
4.10 Thoroughly trained and suitably qualified staff members over the age of 18 will be
positioned at the nearby licensed checkout at all times, where they will be able to see
directly into the liquor area, unobstructed. Such constant and close surveillance is
rarely achievable at most other liquor stores due to their size, location of the aisles
and walk-in cool rooms. Further details of the applicant’s well developed risk
management measures, which include a heavy emphasis on staff training, are set out
elsewhere in this PIA.
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ALDI Whitford City
4.11 The liquor area will be entirely confined
within the ALDI supermarket and have no
access or visibility from outside of the
ALDI supermarket. Some signage
external to the licensed premises may be
displayed which is modest and states
simply that there is “liquor available in
store”, but such signage will not contain
images of liquor products, references to
particular liquor products or prices of
liquor products. An example of this
innocuous kind of external signage that
may be displayed is shown to the right.
4.12 There will be no cool room or other
refrigeration in the liquor area. All products will be stocked and sold at room
temperature. This unique feature further confirms the intention that the liquor service
is genuinely designed to complement the supermarket and provide a one-stop-ALDI
shop. Importantly also, the absence of refrigerated liquor significantly reduces the
risks associated with liquor sold and supplied from the ALDI store. The lack of
refrigeration will dissuade customers from buying on impulse with a view to
consuming the liquor close by or in some other irresponsible manner.
4.13 In addition to the liquor display/browse area and the adjacent checkout, the
supermarket office is also proposed to be licensed solely for the purpose of storing
licensing-related documents including the approved plans, harm minimisation policy
documents and incident register. The applicant also intends to store liquor in the
back-of-house storage area of the ALDI Whitford City supermarket and also at the
applicant’s distribution centre situated within the Jandakot Airport commercial
precinct. No sale or supply will take place from the storage facilities.
Stock range
4.14 The ALDI range of liquor products comprises a modest selection of wines, beers,
spirits, ciders and liqueurs. The in-store range will contain a carefully selected value
for money range of approximately 95 items, many of which are award-winning.
Included in the Applicant’s Case is ALDI’s core stock range of 2018 as well as its
impressive list of awards won in respect of its liquor products (DOC 14).
4.15 The range will vary from time to time as new products become available, in response
to customer requirements and when occasional specialty items are offered.
Generally, the ALDI liquor service will include the following:
4.15.1 60 different wines – red, white, sparkling and fortified.
4.15.2 16 different beers – full, medium and light strength.
4.15.3 15 different spirits – bourbon, brandy, gin, scotch, vodka and liqueurs.
4.15.4 4 different ciders.
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ALDI Whitford City
4.16 ALDI’s award winning and “food-friendly” wines represent excellent value for money
for consumers and ensure that “affordable wines can still deliver the goods”.57
4.17 Included in the Applicant’s Case is a copy of pages of an ALDI catalogue showing
liquor items (DOC 21). It is a relatively modest, yet stylish and elegant advertisement
depicting quality products, including some mainstream items and some products
exclusive to ALDI. The advertisement contains product information for each item,
clearly demonstrating the quality and value-for-money propositions regarding the
ALDI range and the fact the range is indeed carefully selected and responsibly
promoted.
4.18 Within the liquor range available in any given week is a selection of new and different
liquor items which change from week to week, similar to the “special buys” offer
referred to earlier on the PIA. Approximately eight different products per week are
made available to customers until the stocks are depleted and then new ones are
brought in for customers so the product selection remains fresh and vibrant.
4.19 The applicant’s product range also includes Western Australian produced wines.
ALDI has partnered with various wine makers from the Margaret River region to
develop a selection of exclusive ALDI Margaret River region products (DOC 15). Those
items include the following by way of example:
4.19.1 Miles from Nowhere Margaret River Semillon Sauvignon Blanc 2013
4.19.2 A.C. Byrne & Co Margaret River Chardonnay 2013
4.19.3 Vinatero Margaret River Chardonnay 2012
4.19.4 Blackstone Paddock Premium Margaret River Cabernet Sauvignon 2010
4.19.5 Robert Oatley Margaret River Cabernet Sauvignon 2011
4.19.6 A.C. Byrne & Co Margaret River Shiraz 2012
4.20 ALDI’s liquor range is determined following a rigorous process of elimination trialling
and testing of products, then identifying those that offer the very best value for money
which necessitates excellent quality. The optimum range is provided to customers.
Therefore, a smaller quantity of products is stocked than may be found at most other
liquor stores. The ALDI range is much more discerning and refined than most other
liquor outlets. This ensures, as referred to previously, value for money and great
convenience.
ALDI Exclusive Products
4.21 One of the most unique aspects of the ALDI liquor offering is the fact that it includes
an exclusive range of products (DOC 14), made-to-order for ALDI stores that are not
available at any other packaged liquor outlet.
57
http://www.foodwinetravel.com.au/wine/wine-features/aldi-wine/
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