Respecting Human Rights - Woolworths Group
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2021 MODERN SLAVERY STATEMENT
Respecting
Human Rights
WOOLWORTHS GROUP LIMITED
ABN 88 000 014 675
1
2021 MODERN SLAVERY REPORT
WOOLWORTHS GROUP
Contents
SECTION 1 SECTION 2 SECTION 3 SECTION 4 SECTION 5 SECTION 6
Chief Executive Our structure, Identifying and taking Grievance and Assessing the Progress on
Officer’s Message operations and action to address remediation effectiveness commitments
supply chain modern slavery risks of our actions
PAGE 2 PAGE 3 PAGE 8 PAGE 22 PAGE 24 PAGE 25
Company directory PAGE 27
Acknowledgement of Country Statement on the reporting entity
Woolworths Group Limited (ACN: 000 014 675) is an Australian public
Woolworths Group acknowledges the Traditional Custodians company listed on the Australian Securities Exchange (ASX: WOW). The
of Country throughout Australia and recognises their continuing company is registered at 1 Woolworths Way Bella Vista NSW, Australia.
This Statement has been published in accordance with the Modern Slavery
connection to land, waters and community. We pay our respects to Act 2018 (Cth) (MSA or Act). It identifies the steps Woolworths Group
them and their cultures; and to Elders both past and present. Limited and other relevant group companies, including each wholly
owned entity of Woolworths Group Limited and other entities over which
We support the Uluru Statement from the Heart and the recognition Woolworths Group Limited has control for accounting purposes such as
Endeavour Group Limited (ACN 159 767 843) during year ending 27 June
of Aboriginal and Torres Strait Islander peoples in the Australian 2021 (F21) (together, for the purposes of this Statement, ‘Woolworths
Constitution. We commit to continued listening and learning from Group’ or ‘Group’). Woolworths Group Limited makes this single joint
Modern Slavery Statement to cover the Woolworths Group.
First Nations voices and to work in partnership to create change.
Due to the timing of the acquisition, The Quantium Group Holdings Pty
We acknowledge that we have a responsibility and must do more Limited (ACN 121 842 957) (‘Quantium’) will publish a separate Modern
to truly live our purpose to create better experiences together for Slavery Statement this reporting period.
a better tomorrow. All amounts are expressed in Australian dollars unless another currency
is indicated.
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2021 MODERN SLAVERY REPORT
WOOLWORTHS GROUP
Key highlights in F21
Chief Executive
Conducted a risk analysis of labour
and service providers in our operations
and strengthened key controls
Officer’s This is Woolworths Group’s second Modern Slavery
Statement, which outlines the progress we have made
Developed bespoke due diligence
strategies for higher risk commodities
including seafood and cotton
message
to identify, manage and mitigate the specific risks
of modern slavery in our operations and supply chain. Oversaw the repayments of $361,851
to 24 workers in the cleaning and
trolley collector sector
SECTION 1
As with F20, F21 was an extraordinary team makes decisions guided by our
year. Our efforts to embed human values – “I care deeply” and “I always Supported our teams
rights due diligence occurred against do the right thing”. to manage modern slavery risks with
a backdrop of the ongoing impacts the launch of three new resources
This year the Woolworths Group Board
of COVID-19. Both our teams and 1.
approved a Risk Appetite Statement
SECTION 2
suppliers globally faced extended A toolkit for addressing modern
that identified human rights at level slavery in our supply chains and
lockdowns, shifts in production, and one: we work “towards zero” and take operations
stricter health and safety protocols. all reasonably practicable measures 2.
The past 18 months have reminded to achieve risk elimination. The Human A guide to drafting and negotiating
us that people – our team, supplier Rights commitments in Goal 4 of modern slavery contract clauses
SECTION 3
partners and workers across our the People Pillar in our Sustainability 3.
supply chain – are not only core Plan 2025, launched in November Human rights due diligence
to our business, they are essential. 2020, reflect a scaling up of human maturity framework
Our purpose is to create better rights due diligence in non-trade and
experiences together for a better operations, while maintaining focus
SECTION 4
tomorrow and we are deeply on commodities and countries with
committed to upholding respect higher modern slavery risks. are some of the ways we speak up
for human rights. Our 2025 Plan is underpinned by and demonstrate our responsibility
As Australia’s largest retailer, taking five guiding principles. Two of these to prevent harm and eliminate risks
action to address modern slavery risks in particular deeply resonate with of modern slavery. There is more
work to do.
SECTION 5
is not only the right thing to do, it is the objectives of our Human Rights
what is expected of us. Stakeholders Program and have set the tone for our This Statement was approved by
continue to identify human rights as ambition in this space: the Board of Woolworths Group.
one of our material environmental, • We act like a leader and speak up
social and governance (ESG) risks. on issues that matter
Our Human Rights Program is the
SECTION 6
• We embrace the power of
cornerstone of our work to address the
partnerships to create change.
‘S’ in ESG, including specific programs Brad Banducci
to mitigate the most extreme risks Continuing to innovate our program CEO
of modern slavery. In designing and design, meaningfully engaging all
implementing these programs, our stakeholders and transparent reporting 24 August 2021
3
2021 MODERN SLAVERY REPORT
WOOLWORTHS GROUP
Our structure, operations and supply chain
Our store
SECTION 1
Supply partners Operations Team network and
customers
Direct active suppliers Support offices Team members Total
SECTION 2
22
19,959
Trade suppliers 11,795
Distribution centres
217,052
Directly employed 210,067
3,416
Procurement suppliers 8,164
20 Contracted (excl. NZ) 6,985
Australian Food 1,074
SECTION 3
Customer fulfilment Located in New Zealand Food 184
7
Number of own brand centres and eStores
suppliers Endeavour Drinks 1,643
10
2,113 Hotels 339
SECTION 4
countries
Shipping containers
BIG W 176
Woolworths Food
Company 1,599 86,000 190,009
BIG W 524
SECTION 5
Pallets per year 20M in Australia
Procurement 46
BWS/Dan Murphy’s 65 Online visits per week
19,636 Group customers served
on average per week
19.7M
27.8M
in New Zealand
Number of sourcing countries
422
SECTION 6
for own brand suppliers
Delivery partners in ANZ
44 10 in Asia
4
2021 MODERN SLAVERY REPORT
WOOLWORTHS GROUP
Our structure, operations and supply chain
Woolworths Group is a food and everyday needs ecosystem, comprising everyday needs businesses and partnerships,
digital and data platforms, eCom enabled customer services and business to business (B2B) adjacencies.
We aim to create value by bringing our customers good food and more every day through truly connected experiences. Not all elements of the ecosystem are,
however, controlled or operated by Woolworths Group. Those shaded grey represent arrangements that are not in scope of our F21 Modern Slavery Statement.
This may be because they are contracted partnerships, or the entity only joined the Group late in the reporting year.
SECTION 1
s together for
xperience a bet
tter e ter t
1 e crea
te be om
orr
ow
2
W
ds
Nee
B2C Food day Produ
cts B2B B2 B2B Food
Our cornerstone retail ery BF Expanding food
Ev oo
SECTION 2
food businesses, famous & Int d into new customer
for good food, prices od om
er
na segments, channels
eC tio
Fo
na
and acts and always and markets
C
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convenient
1
SECTION 3
woolworths.com.au
Wh
es
Stor
oles
to m e r 1 s t
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Metro @
1
Digital, D
Needs
SECTION 4
Team 1st
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dia
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rvi
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SECTION 5
tn
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t fo y
Pl
sh Insurance e l
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a n
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Va
ips
a
Platforms & Partners rm Eve P More Everyday
d
Subscription and Hubs
s& n
Technology, digital and Pa Prop s xte Extending into
vice –E
e
rtn & Furty, Logistics y Ser
analytics enabled retail ers lfillme Everyda ay complementary
eryd
nt
platforms delivering fo r Ev rs everyday categories
ou More de
r cu l
value for Woolworths
e ho and services to provide
SECTION 6
sto ha r
Group and partners m er s more for our customers
s , te a
m s , par tne t ie s and
rs, communi
1 The Quantium and PFD arrangements were completed late in the financial year and as such will be included in the Group’s F22 Modern Slavery Statement.
2 Endeavour Group is included in this Statement but will not be included from next year due to the demerger of Endeavour Group from Woolworths Group.
5
2021 MODERN SLAVERY REPORT
WOOLWORTHS GROUP
Our structure, operations and supply chain
Our operations Our supply chain
People are the core of our business, and our Globally, we work with approximately 20,000 direct
commitment to respect human rights of all workers suppliers across trade (vendor branded and our
starts in our own operations. We work across the brands) and non-trade.
PEOPLE
diverse entities that undertake our retail operations, • Vendor-branded products are bound by our Goal 4
e-commerce, supply chain and logistics, property Responsible Sourcing Policy, and in fresh Activate ethical and mutually beneficial
SECTION 1
development and hotel businesses to create better categories many are captured by compliance partnerships through the whole value chain
experiences for a better tomorrow. activities. In F22 we will pilot an approach with Progress
In F21, our retail entities and their operations were: vendor branded suppliers of an extreme risk
• Australian Food: including Woolworths commodity to explore how retailers can influence
Supermarkets, Woolworths Food Company, Metro risk management in these complex global Sustainable Development Goals
supply chains.
SECTION 2
and WooliesX
• BIG W: our wholly owned discount retailer • Non-vendor branded refers to suppliers that
• New Zealand Food: Countdown Supermarkets and produce or pack products for a Group brand and
CountdownX fresh categories. These are commonly referred
to as our “own brands”. Key sourcing countries
• Endeavour Group: stores include Dan Murphy’s
by business and category are:
SECTION 3
and BWS, and online retailers Langton’s, Shorty’s
Liquor and Jimmy Brings. Endeavour Group – Fresh fruit and vegetables:
Reporting on our Human Rights Program
also fully owns and controls six wineries across ° Woolworths Supermarket: 96% Australia
Our approach to human rights has been in place for three
Australia and New Zealand and a bottling facility ° Countdown Supermarket: 83% New Zealand
years and we have been making solid progress. The first
in South Australia – Fresh meat: phase (2017‑2020) focused on the development, rollout and
• Entertainment venues including bars, ° Woolworths Supermarket: 100% Australia
SECTION 4
embedding of the Responsible Sourcing (RS) Program across
dining, gaming, accommodation and venue ° Countdown Supermarket: 100% New own brand and fresh product categories.
hire operations. Zealand The next program horizon (2021‑2025) will see a scaling
Our aspiration to be our customer’s preferred – Woolworths Food Company food categories: up of human rights due diligence across our value chain,
food and everyday needs provider is fuelled by 75% Australia including non‑trade, operations and ecosystem partners,
entities including Cartology, W23 Investments – Woolworths Food Company non-food while maintaining a focus on higher‑risk commodities/countries
SECTION 5
in our trade supply chain.
and Woolworths360. categories: 75% China and 11% Australia
Our directly employed workforce comprises the – BIG W own brand suppliers: 90% sourced Our RS Program is integrated across our Human Rights
approximately 210,000 directly employed team from China and Bangladesh. Due Diligence Framework, which is why we will now also
report on RS Program outcomes in our Modern Slavery
members who work across the Group in areas such • Non-trade suppliers provide goods and services
Statement. Together, this is how we manage risks to
as our stores, distribution centres and support to support our operations. The biggest non-trade
SECTION 6
workers across our value chain to meet People Goal 4
offices. Our operations also include indirect workers categories are IT, construction, logistics, of our Sustainability Plan 2025.
including contractors, sub-contractors and labour packaging and consumables and marketing.
hire resources that support our business with
ongoing labour or the provision of services in the
Group’s facilities.
6
2021 MODERN SLAVERY REPORT
WOOLWORTHS GROUP
Our structure, operations and supply chain
Human rights governance and
consultation with controlled entities
Our Human Rights Program includes our Groupwide WOOLWORTHS GROUP BOARD
modern slavery framework that is operationalised The Woolworths Group Board is responsible for providing oversight and approval of the Groups’
sustainability strategy, including human rights and our annual Modern Slavery Statement
by each business unit (BU). Our Group governance
approach promotes ongoing consultation with BUs
SECTION 1
on human rights due diligence and the outcomes are
reported annually in this Statement: Board Sustainability Committee (SusCo)
• A centralised Human Rights Steering Committee Monitor and provide oversight of the Group’s human rights initiatives and due diligence. SusCo is responsible
(SteerCo) meets monthly and is attended by senior for reviewing the Group’s Modern Slavery Statement and recommending it to the Board for approval
leaders of each BU
SECTION 2
• Three cross-functional Agile ‘Squads’ meet fortnightly
in the areas of: responsible sourcing (our brands), CEO and Executive Committee
procurement (non-trade), and operations (Group). Accountable for managing human rights risks
These Squads were our F21 focus areas designed
to accelerate due diligence in these businesses
SECTION 3
and will be reviewed in F22 aligned with our strategy. External human rights advisory partners – ELEVATE and Verité
The Managing Director of each BU is ultimately
responsible for managing human rights risks. Human Rights Steering Committee
They are directly accountable to the CEO and Board, Oversees implementation of the Responsible Sourcing Program
and endorse the final Modern Slavery Statement and embedding requirements to meet the Modern Slavery Act
SECTION 4
to the Board Sustainability Committee (SusCo). Squads
Our sustainability transformation
Operations Procurement Responsible Sourcing
Setting up for sustainable success to create a better
Embedding modern slavery due Embedding modern slavery due Forum for operational managers of
tomorrow is key to our Sustainability Plan 2025.
diligence across Group operations diligence across non-trade our Responsible Sourcing Program
Aligned to Agile ways of working, a Group Sustainability
SECTION 5
Chapter has been established to drive our sustainability
transformation, and human rights has been recognised
as one of five strategic areas, or sub-chapters. Key
principles of this approach that will continue to inform Functions and Businesses
our governance approach are:
SECTION 6
• Chapters coordinate our team to ensure we focus on Procurement Legal BIG W Woolworths Countdown Endeavour Australian
what is important Food Group Food Group
• Sustainability Squads are accountable across BUs and Company
for new and emerging areas
• Ownership of delivery is with the BU where the work
gets done.
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2021 MODERN SLAVERY REPORT
WOOLWORTHS GROUP
Our structure, operations and supply chain
Wholly owned Controlled entity Associate Equity investments
Consultation with Group entities
Engagement Regular engagement via SteerCo, Engage with Executive to set Engage with entity Initial risk analysis
Woolworths Group is an Squads and annual senior leader expectations and conduct annually undertaken as part of due
ecosystem of businesses and briefing sessions quarterly check-ins with diligence process and annual
partnerships that deliver value operational teams engagement (where relevant)
to our customers, and we aspire as part of ongoing monitoring
to lead by example to assist
our partners in mitigating the Due diligence Ongoing due diligence through Review relevant policies and Review publicly Conduct due diligence during
SECTION 1
risk of modern slavery in their Group processes request further information to available documents investment and ad hoc as
operations and supply chains. Monitor human rights due inform due diligence advice and request further determined by risk
We have inserted specific diligence via Group program The entity is required to align information to inform
modern slavery questions maturity framework (see page 21) to Group policies related to due diligence advice
into precedent due diligence human rights
SECTION 2
processes, which allow us to
assess an entity’s modern Ongoing Business accountable for ongoing Provide progress reports as Woolworths Group can Where relevant, conversations
slavery risks before we enter monitoring monitoring, supported by Group requested by Woolworths Group request reports and as part of W23 investees
into a relationship with that Business Executive approves Approves any references to the updates yearly review process.
entity or where there are disclosure, including entity in disclosure, including W23 is Woolworths Group’s
changes in levels of control. venture capital arm
SECTION 3
this Statement this Statement
Once an entity becomes part
Ongoing Embedded in Group human Human Rights team supports Human Rights team Human Rights team provide
of Woolworths Group, we
support rights governance and provides guidance material provide guidance material guidance material to support
apply a consultation framework
to entities to support entities entities as required
commensurate with the level of
influence Woolworths Group
SECTION 4
holds over the entity based on the We are constantly evolving our business to meet the needs of our customers, and we are committed
definition of “control” under the to making human rights considerations a part of this evolution. Key changes this year were:
Australian Accounting Standards.
In the event that a recently Increased our shareholding in Quantium from 47% to 75% on During the transaction our Human Rights team met with Quantium to discuss
acquired entity is subject to 31 May 2021. modern slavery risks and governance. Next year we will conduct quarterly
SECTION 5
a historical human rights related Due to the timing of acquisition Quantium will produce its meetings with Quantium with the view to integrate them into our human rights
allegation, we would take the own Statement in F21 and be included in Woolworths Group’s risks and governance bodies by the end of F22.
same approach to remediation Statement from F22.
as any controlled entity and
determine an appropriate course Acquired a 65% equity interest in PFD Food Services Pty Ltd Our team completed due diligence prior to the acquisition, including a review of
(PFD) on 28 June 2021. PFD’s policies and procedures to prevent forced labour. We made and agreed
SECTION 6
of action based on whether the
entity had caused, contributed recommendations with PFD’s management on their human rights due diligence
to, or been directly linked to the processes and in F22 we will execute the agreed action plan.
adverse human rights impact. Decreased our shareholding in Endeavour Group Limited (EGL) During F21 EGL remained integrated in Woolworths Group’s Responsible Sourcing
from 85.4% to 14.6% as of the demerger on 28 June 2021. and Human Rights Program. We completed a human rights handover on demerger
and will continue to engage with EGL in our capacity as an investor in F22.
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2021 MODERN SLAVERY REPORT
WOOLWORTHS GROUP
SECTION 3
Identifying and taking action to
address modern slavery risks
SECTION 1
As the largest retailer in Australia, Woolworths Group’s operations and supply chains are complex
and exposed to dynamic human rights risks. We continue to monitor our risk environment through Team member underpayments
a combination of third party risk assessments and advice, audit trends, grievances raised, team We recognise that underpayments,
when present with other factors,
SECTION 2
member insights, industry commentary and media and civil society reports. Combining these may be an indicator of modern
slavery which could prompt further
multiple risk lenses help us to identify and prioritise the most salient human rights risks. investigation. Since identifying
significant underpayments of
our salaried award covered
Working with our program partner, ELEVATE, a global business risk made wholly or in part with forced labour, regardless of geographic origin. store team members, we have
SECTION 3
and sustainability solutions provider, and their integrated risk platform, worked hard to remediate these
We will continue to monitor legislative initiatives that may increase the
underpayments. We have also
EiQ, our insights into modern slavery risks continues to improve. In F21, requirements of Woolworths Group and review our policies accordingly.
taken steps to ensure future
two timely new indicators were added to the risk assessment process
Our team used these insights to conduct proactive risk analysis, compliance by introducing a range
– data on domestic migrant worker labour; and hygiene and sanitation of measures, such as rostering and
as described throughout this section. In addition to considering
(including COVID-19 risks). Generally, this risk assessment indicated that time and attendance guidelines
these risks, our priority in F21 was developing strategies to address
SECTION 4
the ongoing impact of COVID-19 and changing geopolitical dynamics saw and reporting arrangements to
higher risk areas identified in our previously reported forced labour
a continuation, and in some cases escalation, of macro risk trends such as: enable us to identify and address
risk assessment.
• Deterioration in health and safety practices across global any discrepancies. Due to absence
of other indicators and improved
supply chains Our Operations processes and systems for setting
• Increase in employment-related violations including non-compliance Direct and monitoring salaries across the
SECTION 5
with minimum-wage requirements Group, we consider the likelihood
The vast majority of Woolworths Group team members are employed
• Decrease in audit transparency and integrity, particularly across Asia of modern slavery remains low.
directly, with their employment terms and conditions set out in
• Increase in forced labour risks, notably among countries with large
employment contracts governed by Australian and New Zealand
numbers of economic labour migrants.
employment laws and relevant industrial instruments. Eighty-six
In addition, we proactively monitored international trade policies and percent of Australian team members are covered by 39 enterprise
SECTION 6
enforcement tools that are designed to improve transparency and agreements in Australia, and 90% of New Zealand team members
integrity in the supply chain. These include US Government’s Withhold are in roles that are covered by 11 collective employment agreements
Release Orders (WROs) as well as emerging global policy trends. in New Zealand. Woolworths Group recognises the right of team
For example, in June 2021 the Australian Senate Foreign Affairs, Defence members to negotiate collectively, with or without the involvement of
and Trade Legislation Committee published a report that includes third parties (including industrial associations/unions). An estimated
a recommendation to prohibit the import of any goods into Australia 46% of Australian team members and 47% of New Zealand team
9
2021 MODERN SLAVERY REPORT
WOOLWORTHS GROUP
Identifying and taking action to address modern slavery risks
members are members of a registered • Labour Hire: Labour hire agencies assessment and due diligence on labour
trade union with whom Woolworths employ workers who perform work on hire and operations services providers
Group regularly engages. These factors, the Group’s sites. The labour hire agency who provide regular workers to Group
combined with our comprehensive is responsible for paying the worker, and operated sites as we continue to mitigate
policy framework (see page 18, 2020 the Group oversees the day to day work. this risk. The outcomes of this assessment
Modern Slavery Statement), which is Woolworths Group uses temporary are detailed in the sections below.
communicated to our team members labour to support activities such as
SECTION 1
Strengthening contractual controls
through training, regular monitoring and the picking and packing of pallets at
extensive grievance mechanisms, mean Australian and New Zealand distribution This year we conducted a review of 94
that the modern slavery risk in our direct centres and picking and packing of online contracts for operations service providers
operations is low. orders at customer fulfilment centres, as and 14 contracts for labour hire providers
well as providing information technology to understand what contractual controls
Right to Work Policy exist to mitigate human rights risks,
SECTION 2
services across the Group.
Potential labour compliance risks may • Operations Services: Woolworths Group including modern slavery. We found:
be heightened for approximately 12% outsources various services to third party • 80% of operations services and 78% of
of our directly employed team members service providers to perform regular labour hire contracts include, or will be
who are visa holders. In FY21, we and ongoing work at the Group’s sites. negotiated to include, that the supplier
identified that there was an opportunity The service provider is responsible for must comply with our Responsible
SECTION 3
to strengthen our controls to mitigate COVID-19: Bangladesh and Thailand
delivering the service and pays workers Sourcing Policy and Standards
the risk of non-compliance with right to either directly or through subcontractors. We recognise the ongoing impact of the COVID‑19
work obligations for these team members. • 82% of operations services and 86% pandemic on our team, particularly our 38 team
Woolworths Group uses operations of labour hire contracts include, or
We introduced a Right to Work Policy to members located in Bangladesh and Thailand,
service providers for services such as will be negotiated to include, modern
clearly communicate our commitment to who experienced additional lockdowns this year.
trolley collection, cleaning, security and slavery clauses To support our team, we introduced safeguards
promoting a culturally diverse workplace
SECTION 4
the delivery of food and everyday needs to mitigate the impact of the pandemic including:
where team members’ working rights • Subcontracting was prohibited without
goods to customers, referred to as ‘last
are respected. This was supported by approval in 85% of operations services • Providing shuttle bus services to testing
mile delivery’. facilities for team members and their immediate
compulsory, tailored training to our and 100% of labour hire contracts.
managers, team members and culture and These categories are inherently higher risk families in Bangladesh
As a result we:
people partners to operationalise the policy. due to a workforce often characterised • Delivering care packs to all team members in
SECTION 5
by a higher portion of migrant and • Worked with 11 BUs to strengthen Bangladesh and Thailand with essential items
The program was launched in February
2021, and 93% of relevant team members unskilled workers who may be less human rights contractual controls, and hygiene supplies
have completed the training to date. aware of applicable rights and available such as inserting modern slavery clauses • In the few instances where team members
protections. Woolworths Group has and increasing labour governance tested positive for COVID‑19 we worked with
Indirect less visibility and control over how controls where contracts were currently the team member to ensure they were not
being negotiated financially disadvantaged, delivered fruit
Last year, we conducted a forced labour workers are engaged, and there is a
SECTION 6
baskets and specific COVID care packs with
risk assessment which confirmed that in higher prevalence of subcontracting and • Identified one instance of potential
essential hygiene items for themselves and their
our operations, indirect labour carries an independent contracting models. These risk to workers due to lack of family, and covered the cost of COVID testing
inherently higher risk of modern slavery. factors, combined with tight industry adequate contracts and escalated for team members and their immediate family
There are two categories of indirect labour margins, make workers in these categories for further investigation. in the same household.
who perform work for Woolworths Group more susceptible to exploitation. This
and on the Group’s sites: year we conducted a Group-wide risk10
2021 MODERN SLAVERY REPORT
WOOLWORTHS GROUP
Identifying and taking action to address modern slavery risks
Strengthening controls in New Zealand facilities management
Last year, we outlined the approach that our Woolworths Group
Strengthening contract monitoring Facilities Management team has in place to manage due diligence on
We recognise that contractual mechanisms trolley collection and cleaning service providers at our Australian retail
are an important part of mitigating the sites. We recognised the need for similar levels of due diligence for
risk of modern slavery, but they are only cleaners and trolley collectors in New Zealand, so this year Countdown
effective when accompanied with robust increased controls by partnering with the Building Service Contractors
compliance monitoring. To understand New Zealand Ltd (BSCNZ). Countdown now requires all cleaning
how key human rights clauses operate, and trolley collection suppliers and subcontractors to be certified Reviewing our arrangements with
SECTION 1
we conducted a baseline assessment BSCNZ members. This includes complying with BSCNZ’s Code of security providers
to map how contractual controls were Practice, undertaking social audits and applying collective employment The security industry had been identified
monitored in practice. Overall, capability agreement conditions. by the Group as a higher risk service in our
to monitor compliance with human rights operations. Underpayments, sham contracting
Countdown has also been proactive in communicating our
controls of service providers and labour hire and other forms of worker mistreatment are a
expectations to New Zealand suppliers. For example, in February
SECTION 2
arrangements across the Group is varied for concern across the sector in general, and this
the New Zealand Employment Relations Authority determined that
several reasons, notably: has been recognised publicly in parliamentary
an unauthorised subcontractor to one of Countdown’s cleaning
• There can be multiple touch points for the contractors from 2019 had failed to keep correct employment records and government reports. At the onset of the
same service provider across the Group and failed to pay over $12,000(NZD) in employee entitlements. pandemic, we increased the visible security
with different compliance approaches While the subcontractor was liquidated in March 2020, Countdown presence in our stores to protect our team
SECTION 3
• A lack of clarity and consistency in used the Authority’s decision as an opportunity to communicate our in response to panic buying and increased
consequences of supplier non-compliance human rights expectations to our cleaning suppliers, particularly customer aggression, and to make our stores
• Limited two-way communication regarding the requirement to obtain Countdown’s authorisation for a safe place to shop for our customers. This
between procurement and the use of any subcontractors. Countdown now has greater visibility saw an increase in our supplier base in a short
operational/compliance functions of subcontractors in its supply chain and has, to date, authorised space of time from two suppliers to six.
SECTION 4
following the procurement activity seven cleaning subcontractors in its supermarkets. Recognising that fast onboarding of
• Degrees of subject matter expertise suppliers can exacerbate already existing
in operational teams. human rights risks, in F21 we worked
We have a plan to address this gap through cross functionally to conduct a review of
the creation of an end-to-end labour all security providers in our Australian
operations. This review involved requests
SECTION 5
governance monitoring framework that can
be applied consistently across all Group for documents and information from all six
businesses. This will equip our teams with security suppliers, and follow up interviews
the tools to proactively monitor compliance with four suppliers. As a result of the review,
with labour governance contractual controls one supplier’s contract was not renewed
and mitigate the risk of modern slavery and we are implementing recommendations
SECTION 6
indicators in our indirect workforce. to strengthen contractual requirements for
remaining suppliers. These controls include
unannounced audit rights and implementing
stricter subcontracting controls, with a goal
of lowering levels of subcontracting across
all suppliers over time.11
2021 MODERN SLAVERY REPORT
WOOLWORTHS GROUP
Identifying and taking action to address modern slavery risks
Our Supply Chain – Trade
Woolworths Group sources non-vendor as an ingredient or raw material than in final fresh products. During onboarding, suppliers Initial audit gradings from our RS Program
branded products for our own brand products stage manufacturing. are segmented into four risk categories with
from 40 countries. Certain products and corresponding due diligence requirements.
categories present higher risks of modern Our Responsible Sourcing (RS) Program
Simply put, the greater the risk, the more
slavery. These risks are more prevalent in provides the governance for how we manage
controls we have in place. 400 21%
commodities that contribute to a final product social compliance of our own brand and
SECTION 1
The third party audit for moderate, priority
and specialised risk-segmented suppliers 350
includes checks on key forced labour
300
Our RS framework articulates how our risk-based supplier segmentation drives indicators. All audits are graded against four
due diligence requirements. possible outcomes – zero tolerance (ZT), 250
‑23%
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critical, moderate, and minor – and forced labour
indicators, among others, are considered a 200
All Minimum Moderate Priority Specialised ZT issue. Moderate or minor non-conformances
(NCs) are addressed during the audit cycle as 150
Number of non‑vendor branded
716 233 453 464 part of the scheme follow-up, while our team
supplier sites 100
prioritises ZT and critical NCs for follow up. ‑5%
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8. Annual Unannounced Site Visit 1
In F21 we achieved a 23% decrease in the 50
1%
overall number of critical audit gradings
7. Implementing a Corrective
through a targeted remediation strategy. This 0
Action Plan
strategy included a focus on working hours Minor Moderate Critical ZT
6. Sharing Audit Report non-conformances including the rollout of
SECTION 4
our Supplier Guidance on Overtime Hours, F19 F20 YoY% change
5. Mutual Recognition and engagement with suppliers in India and
Audit Schemes 2 China to close out critical audit outcomes.
4. Supplier Self‑Assessment Critical NCs that become overdue, in spite In F21 we saw a decrease in the number
of follow-ups and reminders, may indicate a of critical issues raised in our RS audit
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3. Training and Education more systemic issue. NCs related to safety program. This shift towards more moderate
(56%) and the environment (25%) continue risk findings is indicative of an improved
2. Responsible Sourcing Standards to be overdue, and this is consistent with our residual risk profile among our directly
findings last year. We recognise that auditing contracted own brand and fresh suppliers.
1. Responsible Sourcing Policy alone will not be sufficient to resolve these
SECTION 6
issues in the long term, so in F22 we will
1 Selected based on risk profile. partner with strategic suppliers to explore
2 We accept 8 social compliance schemes: amfori BSCI, Sedex, SA8000, ICTI, WRAP, Fair Farms, Global GAP
GRASP, and the NZGAP Social Compliance Add-on.
the root cause of these issues and pilot
improvement KPIs in an attempt to make
progress on these industry-wide issues.12
2021 MODERN SLAVERY REPORT
WOOLWORTHS GROUP
Identifying and taking action to address modern slavery risks
Managing zero tolerance cases
This year 20 ZT cases were identified in five Breaches related to transparency and integrity are passports/personal documents (reducing the
countries across our food, hardgoods, soft goods, consistent with risk trends identified in our F21 risk forced labour risk of restriction on freedom
medicinal and non-trade categories. Thirteen cases assessment. Each audit scheme has a process for of movement)
have been resolved, three factories have been exited responding, and our team follows up directly with • Validated the original audit finding on the payment
due to repeated non-compliance with our Standards, the supplier. Despite being a ZT finding, the issues of recruitment fees and determined that the
SECTION 1
and four cases are under follow-up. related to business integrity were relatively minor. In amounts paid were broadly consistent with the
F22 we will review our ZT audit grading protocols so fee payments from other sectors in Malaysia
F21 ZT issues by country these are proportionate to the act. • Estimated the fees paid by 226 workers to be
Three suppliers recorded a ZT against a forced labour approximately $3,300 per worker.
indicator of the RS Standards. One was a case in India As a result:
SECTION 2
related to underpayment of wages and following a
root cause assessment the vendor decided to exit the • Our team and the supplier are finalising a fees
Australia 2
factory due to repeated non-compliance. reimbursement plan
• We have agreed further corrective actions that
China 5 2 4 1 Managing forced labour risks in Malaysia seek to address the root cause of the payment of
Of the two cases in Malaysia, one was related to recruitment fees including governance of labour
SECTION 3
withholding of passports, which was remediated by agents and a requirement for pre-departure
Country
India 1 1 1
giving workers unrestricted access to their safety briefing for migrant workers before they leave their
Korea 1
deposit box. The other identified that foreign migrant home country
workers from countries including Bangladesh, • Additional measures include:
Myanmar and Nepal had paid recruitment fees in – Providing policies and information in languages
Malaysia 2
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their home countries and were required to pay a workers can understand
0 2 4 6 8 10 12 deposit to their employer before being allowed to – Improvements to bring current dormitory
No. of issue travel outside of Malaysia. conditions into line with Malaysian legal
Where there is a potential for modern slavery, routine requirements.
audits serve the purpose of identifying red flags Last year we committed to disseminate supplier
¢ Business Integrity & Ethics
SECTION 5
for further investigation. As a potential indicator of guidance and conduct training at sites in Malaysia to
¢ Health & Safety debt bondage, Woolworths Group triggered our ZT address forced labour risks. These were paused due
¢ Forced Labour Indicators procedure and engaged ELEVATE, to conduct a full to the prioritisation of remediation and the ongoing
¢ Transparency investigation at the site. The investigation: impacts of COVID-19. Incorporating the lessons
¢ Freedom of Association • Found factory management to be generally learned from this case will inform our due diligence
cooperative and there is no indication of for other sites in Malaysia and recommencing these
SECTION 6
¢ Wages & Benefits
falsification of records or coaching of workers activities is a priority in F22.
• Found workers have their own set of keys to
access personal lockers to safely store their13
2021 MODERN SLAVERY REPORT
WOOLWORTHS GROUP
Identifying and taking action to address modern slavery risks
Broadening visibility in our fresh
produce supply chain Countdown
Globally, horticulture remains an inherently Number of direct fruit and veg supplier sites in Australia audited based on third In New Zealand, Countdown has been
higher risk industry for labour exploitation due party scheme working closely with New Zealand
to its seasonal nature and reliance on temporary Good Agricultural Practice (NZGAP)
and informal workers. The rollout of our RS to develop their Social Practice Add-on
SECTION 1
Program in Australia remains a priority to which will enable New Zealand
support our suppliers in mitigating these risks. produce suppliers to demonstrate
Our goal is to have every direct supplier compliance to our RS Standards.
complete an initial audit to establish a baseline To date, 67% of Countdown’s fresh
risk profile. This year there were an additional produce direct suppliers are using
SECTION 2
59 new audits conducted, bringing the total the NZGAP Social Practice Add-on,
to 165 (36%) produce suppliers having carried NT 32% are using the Global GAP Risk
out at least one audit at their main site. 0 1 1 Assessment on Social Practice and
Aligned with our risk-based principles, we have 1% are using Sedex SMETA. Of the
prioritised audit requests in seven higher risk 32 completed audits, 29 have been
QLD
categories and have 54% coverage in higher graded as Green and 3 have been
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WA
risk fruit categories (berries, cherries, grapes, 22 9 0 graded as Amber with our team
14 9 1
stone fruit and citrus) and 33% coverage following up on non-compliances.
SA
in vegetables (tomatoes and cucumbers).
While this might seem low, our audit request 19 2 0
commenced in mid-2019 and has been stalled NSW & ACT
SECTION 4
due to the summer bushfires during 2019–2020 30 5 1
and COVID-19 travel restrictions that have
been ongoing since March 2020. VIC
37 4 2 2
The current audit grading of the 165 conducted
to date are: 140 (85%) had minor non- TAS
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conformances, 14 (8%) had moderate findings,
3 1 4
nine identified critical issues and two remain a
ZT. The two ZT cases relate to underpayment of Sedex (SMETA)
wages and both are under investigation. Other Fair Farms
top audit non-conformances include inadequate GLOBAL GAP GRASP
management systems for labour providers,
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insufficient emergency exits and underpayment
of overtime premiums.14
2021 MODERN SLAVERY REPORT
WOOLWORTHS GROUP
Identifying and taking action to address modern slavery risks
Grower visibility and labour hire
due diligence
We continue to focus on the unique risks to migrant compliance. This will remain a priority for our team
workers in horticulture. In line with our Requirements in F22, and we will: Pre-harvest briefing sessions and union engagement
for Labour Providers in our Australian Horticulture • Re-communicate our Requirements to all COVID‑19 travel restrictions have meant our team could
Supply Chain (Requirements), suppliers are expected suppliers and provide additional guidance not resume on the ground pre‑harvest briefs nor worker
SECTION 1
to conduct basic due diligence in their operations, material as required engagement sessions. Instead, we conducted two virtual
for growers and any labour hire providers (LHPs) pre‑harvest briefing sessions which enabled us to open the
• Conduct workshops with key suppliers to embed
used in their supply chains. Information for both forum to industry. More than 90 participants joined the
our Requirements further in the supply chain
supplier sites and their grower’s, including the names sessions which were attended by suppliers and LHPs to both
of LHPs and which accreditation scheme they • Engage key industry groups and activate their major retailers, with presentations from key regulators and
meet, is submitted to Woolworths Group. support in educating growers unions. Workplace compliance, COVID‑safe harvest and the
SECTION 2
• Continue to contribute to industry and importance of worker rights education were the topics covered.
Focussed engagement and follow-up with government dialogue on LHPs.
suppliers has resulted in an increase in response
rate to grower information requests from 63%
to 96%. Across the 532 sites using LHPs, 257
unique providers were identified. In our first
SECTION 3
Current status of grower and labour hire information checks in higher risk fresh produce categories
phase due diligence, 130 (51%) LHPs were
identified as meeting the Requirements. Of
#Indirect # total sites # of labour # of labour hire
these, 81% have state-based labour hire licences,
Response # Direct supplier using labour providers providers meeting
17% have registered employer status on the
Category rate suppliers sites hire identified requirements
Seasonal Worker Program, and 2% hold StaffSure
SECTION 4
accreditation.
Berries 100% 43 158 128 74 30
Of the 127 LHPs who were not yet confirmed as
meeting licensing requirements, three (2%) have Cherries 100% 20 38 26 21 9
been verified as ‘under application’, ten (8%)
were based in NSW or WA where state licensing
SECTION 5
Grapes 97% 33 132 85 52 27
is not yet in place, and 114 (90%) stated they
were compliant with either a state licence or the
Seasonal Worker Scheme. Verification of these Stonefruit 100% 34 129 106 60 21
providers is our next focus area. We further
engaged Verite to conduct research and a deep Citrus 95% 46 255 123 65 41
SECTION 6
dive with four suppliers and their LHPs. Verite
found that supplier management systems for Tomatoes 91% 32 129 57 35 24
LHPs are not well documented, and that LHPs
themselves have limited documented processes. Cucumbers 89% 20 67 7 7 5
Both of these elements make it difficult to verify15
2021 MODERN SLAVERY REPORT
WOOLWORTHS GROUP
Identifying and taking action to address modern slavery risks
Our forced labour risk assessment is a step beyond the RS risk assessment. It considers key forced labour indicators as well
as third party sources such as the Global Slavery Index and NGO reports. This year, we expanded on the results of our F20
forced labour risk assessment by overlaying this information with specific supply chain data from our RS Program. The table
highlights our supply chain footprint in higher risk manufacturing countries and the actions we have taken to mitigate these risks.
Inherently higher
SECTION 1
risk product # Direct Top non-conformances
Country categories suppliers from supplier audits Examples of actions taken
China Footwear, 534 Lack of internal RS policies Resumed in-person site visits to 15 factories and held
furniture, toys and procedures 15 remote virtual assessments, reducing six sites from
SECTION 2
& games Excessive overtime critical to moderate risk.
Bangladesh Footwear, 20 Lack of machine safety Completed 54 remote virtual assessments (initial and
garments guards follow up), addressed 47 issues and reduced health and
Lack of personal protective safety risk through monitoring PPE.
equipment (PPE)
SECTION 3
India Garments, textiles 22 Fire safety mechanisms Completed 18 remote virtual assessments and six
not maintained factories improved their audit outcome from critical to
moderate. Three sites were exited due to repeated ZT
audit outcomes.
SECTION 4
Malaysia Hardgoods 12 Excessive overtime Conducted an investigation into recruitment fees (see
Workers not provided page 12) and monitored an indirect supplier identified in
one days rest a Withhold Release Order (see page 17).
Thailand Garments, rice, 27 Excessive overtime Completed three virtual assessments and held an
SECTION 5
seafood Lack of internal RS policies emergency COVID management meeting with one
and procedures factory during an outbreak.
Vietnam Furniture, seafood 12 Limited internal RS Completed an emergency COVID management meeting
governance with one factory during an outbreak.
SECTION 6
Employment contracts do
not comply with applicable
local laws and/or
international standards16
2021 MODERN SLAVERY REPORT
WOOLWORTHS GROUP
Identifying and taking action to address modern slavery risks
Our progress to date on managing
extreme risk commodities Seafood Cotton
Last year we also reported on Forced labour, human trafficking and debt bondage are known modern The human rights risks for workers along the cotton supply
extreme risk commodities. We found slavery risks across the global seafood sector. The severity of these chain include low wages, undocumented labour and allegations
risks varies across geographical location and species, and may be of child and forced labour across different producing markets.
modern slavery risks tended to be
exacerbated by structural challenges including illegal, unreported or As part of our program, we monitor cotton‑growing regions
more prevalent at lower supply
unregulated fishing, flags of convenience, and transshipment, which that are the subject of allegations or known cases of child
chain tiers where raw materials
SECTION 1
permits extended time at sea. labour and forced labour. These include certain regions in
are extracted and/or in early stage
There are three main avenues of seafood entering the Group’s supply Bangladesh, Uzbekistan, India, and the Xinjiang Uyghur
processing. In this context, supply
chain: fresh or ‘behind the counter’, own brand ‘long‑life’ (e.g. tinned Autonomous Region of China. We audit our direct suppliers to
chain visibility and traceability will
salmon), and as an ingredient in other products. Fresh and own brand check that they do not utilise forced labour and are improving
be key to effectively managing seafood is sourced from 43 direct suppliers spanning operations our processes to gain visibility on cotton sourced as a raw
multi-tiered risks. As key operational and fisheries in 22 countries. Sixty‑eight percent of fresh seafood material in the supply chain.
SECTION 2
principles, we define these as: is fished in Australia followed by transboundary waters to the north BIG W apparel utilises the majority of cotton sourced for own
• Visibility: being able to identify east and west of Australia, Vietnam and New Zealand. In line with our brand products and is leading the Group’s cotton response.
and know suppliers, both direct RS Program requirements, a third of these were required to submit This year BIG W established a Cotton Sourcing Steering
and indirect, in our supply chain, a social compliance audit based on their risk segmentation. The Committee that governs the cotton traceability working
remainder have completed a self assessment questionnaire (SAQ).
without them being linked to group. The working group conducted a review of our current
The review of these audits identified top non‑conformances in health
SECTION 3
specific orders procedures for cotton sourcing and found:
and safety, and working hours. No indicators or instances of modern
• Traceability: knowing exactly slavery have been identified among direct seafood suppliers. • All sourcing divisions have full visibility over direct Tier 1
where a product comes from suppliers of finished goods
This year, expanding on our RS Program, we:
including all stakeholders that • We continue to gain visibility over Tier 2 suppliers, though
• Reviewed existing seafood ranges to assess the human rights there were inconsistencies in the approach to the collection
have added value during the
coverage of current third party accreditations: and recording of relevant information
manufacturing process.
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– 100% of our own brand seafood suppliers are covered by our • We have traceability procedures for certified products with
RS Program and their fisheries are covered by an approved a sustainability claim.
accreditation
Based on these findings, we have:
– 58% of behind the counter seafood is certified by an approved
accreditation • Developed an improved approach to supply chain mapping
• Developed a Cotton Sourcing Policy for release in H1 F22
SECTION 5
– Accreditations for seafood are MSC for wild caught, and ASC,
BAP, Global GAP for farmed. • Established an internal cotton tracing protocol to support the
• Proposed a human rights seafood strategy based on benchmarking, implementation of the Policy. The Protocol will be piloted in
subject matter expert recommendations, and key industry H1 F22.
stakeholder consultations. The strategy covers governance, Aligned with our 2025 Sustainability goals we are committed
enhanced due diligence, traceability, grievance mechanisms and to greater traceability of our cotton so that we know it has been
SECTION 6
access to remedy and participation in international initiatives. It will produced sustainably and responsibly. We further encourage
be launched in the first half of F22. the use of recycled and reclaimed cotton in manufacturing
where possible.17
2021 MODERN SLAVERY REPORT
WOOLWORTHS GROUP
Identifying and taking action to address modern slavery risks
Monitoring international trade
enforcement tools
This year we proactively monitored international
trade policies and enforcement tools that are
designed to improve transparency and integrity
Woolworths Food Company (WFC) Commodities in the supply chain. These include withhold
We have made progress on our commitment to design and deliver due diligence for high risk commodities. Identified high risk release orders (WROs) and findings published by
SECTION 1
commodities from our risk assessment include, but are not limited to, dried fruit and nuts, coffee, palm oil, cocoa, coconut US Customs and Border Protection (CBP). CBP
and rice. The WFC Strategic Sourcing team buys bulk commodities that are then sold as products or used as ingredients in our issues a WRO when the agency has reasonable
own and exclusive brands. This year our Human Rights team began to strengthen our bulk commodities sourcing process by:
evidence of the use of forced labour in the
• Shadowing the Strategic Sourcing team to better understand their sourcing process manufacturing of goods entering the US supply
• Reviewing the new product development process and implementing recommendations chain. Using this information, in F21 we reviewed
SECTION 2
• Piloting controls in the sugar sourcing activity, including a review of the Bonsucro certification our supply chain to check if any direct suppliers
• Commenced mapping of the human rights controls in third party commodity certifications – UTZ/Rainforest Alliance, had been identified through such mechanisms.
Fair Trade, and RSPO To date, no direct suppliers have been identified.
• Including human rights in the review of our Sustainable Palm Oil (Food and Non Food), Soy, Tea Coffee Sugar and Cocoa We then worked with our sourcing teams to
Policies, to be launched in the first half of F22. understand whether any indirect suppliers
SECTION 3
In F22 we will continue to focus in this area and implement our due diligence framework across prioritised high were impacted.
risk commodities.
In December 2020, it came to our attention
that a WRO was placed on all palm oil coming
from Sime Darby Plantation’s (SDP) Malaysian
operations, due to allegations of forced labour on
SECTION 4
their plantations. Sime Darby is an high volume
indirect supplier to Woolworths Group. SDP
has established an Expert Stakeholder Human
Fresh meat in Woolworths Supermarkets Rights Assessment Commission and appointed
Since our RS Program commenced in 2018, we identified our fresh food supply chain as an area of interest due to the known Impactt, an ethical trade consultancy, to conduct
inherent risk associated with agricultural production. We first prioritised our response in horticulture and from last year a comprehensive independent assessment of
SECTION 5
commenced work in our Australian meat supply chain. To date:
SDP’s labour practices across its Malaysian
• 100% of our own brand fresh meat is in scope of our RS Program operations. SDP has committed to releasing this
• Fresh meat (beef, lamb and pork) is sourced in Australia from 26 suppliers across 49 abattoirs and boning room sites publicly, as well as any remediation measures the
• Twenty‑seven of the 49 sites submitted an existing social compliance audit with the following outcomes: company will take in response. This is expected
– Three sites with previous ZT findings related to underpayment of wages and fire safety have been remediated, six sites in early F22. We have identified one direct
SECTION 6
had critical findings, ten were moderate and eight were minor issues supplier sourcing from SDP and we will continue
– Following remediation efforts two sites remain critical and under active follow up, three are moderate, and 22 have been to work with them to monitor the situation.
downgraded to minor.
• The remaining 22 sites will be prioritised for audit in F22.You can also read
