Modern Slavery Policy

1. Purpose:

Associated Retailers Limited (ARL) is committed to identifying and mitigating the risk of modern slavery occurring within its own business and to set steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and supply chains. The purpose of this Policy is to ensure that the ARL is compliant with local, national, and other applicable laws and regulations in the areas in which the businesses operate, sources products and services in accordance with legal obligations, and act to prevent, mitigate and where appropriate, remedy modern slavery in their operations and supply chain.

2. Modern Slavery:

According to Commonwealth Modern Slavery Act 2018, the types of modern slavery are:

a) Trafficking in persons describes the recruitment, harbouring and movement of a person for exploitation through modern slavery.

b) Slavery Describes situations where the offender exercises powers of ownership over the victim, including the power to make a person an object of purchase and use their labour in an unrestricted way.

c) Servitude Describes situations where the victim’s personal freedom is significantly restricted, and they are not free to stop working or leave their place of work.

d) Forced labour Describes situations where the victim is either not free to stop working or not free to leave their place of work.

e) Forced marriage Describes situations where coercion, threats or deception are used to make a victim marry or where the victim does not understand or is incapable of understanding the nature and effect of the marriage ceremony.

f) Debt bondage Describes situations where the victim’s services are pledged as security for a debt and the debt is manifestly excessive or the victim’s services are not applied to liquidate the debt, or the length and nature of the services are not limited and defined.

g) The worst forms of child labour Describes situations where children are exploited through slavery or similar practices, including for sexual exploitation, or engaged in hazardous work which may harm their health, safety, or morals or used to produce or traffic drugs.

3. To whom the policy applies:

This company's policy applies to all employees, whether permanent, fixed term, or temporary, suppliers and contractors, trainees, homeworkers, and agency staff.

4. Policy Statement:

a) ARL will engage towards zero tolerance in modern slavery in its operations and supply chain.

b) ARL will comply with all applicable modern slavery laws in Australia and all other jurisdictions in which it operates.

c) ARL will assign yearly CSR targets to identify and mitigate the risk of modern slavery starting from direct suppliers to indirect suppliers, by encouraging them to provide awareness to their employees, demonstrating their own modern slavery policy and by requiring them to submit annual modern slavery declaration to ARL.

d) Every employee and others to whom the policy applies, must follow policies and procedures to ensure that they are addressing modern slavery and ethical sourcing risks in its operations and supply chains.

e) Zero tolerance approach towards modern slavery should be included in operational and supplier contract terms, requirements that suppliers comply with all local, national, and other applicable laws and regulations in the areas in which they operate.

f) In case modern slavery is identified in relation to any supplier, the supplier will need to provide clarification to ARL. ARL management will support the supplier in identifying and mitigating modern slavery from its supply chain wherever possible and may require additional verification in order to confirm compliance.

g) Any identified case of modern slavery should be immediately reported to ARL.

h) The modern slavery reporting can be done by directly reporting it to your manager or to the ARL representative to whom you are in contact with. Reporting can also be done through ARL email address specifically made to handle modern slavery queries and complaints

i) In case the act of modern slavery was deliberately hidden from ARL and supplier was found to have full knowledge of it. Then ARL management have the right to terminate further business relation with the supplier.

5. Relevant Policies:

We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations. Our policies are clearly defined and communicated to all employees.

a) Company handbook - We have zero tolerance of any threat of physical or sexual violence, harassment, or intimidation against employees and their family, or close associates. All our employees are treated fairly and equally and are paid at least the national minimum wage. Our employees will not be forced to work more than the number of hours permitted in law.

b) Supplier code of conduct and purchasing policy - The organisation is committed to conducting purchasing activities in a fair, objective, and transparent manner that satisfies the requirements of accountability and internal controls to fulfil legal and financial obligations and effectively manages commercial risk. Emphasis is placed on selecting suppliers and service providers that demonstrate Corporate Social Responsibility (CSR) standards including but not limited to compliance with laws and regulations, respect for human rights, labour working conditions, equal opportunities, health and safety accreditation and acceptable corporate ethics.

6. Due Diligence:

We undertake due diligence when considering taking on new suppliers and review our existing suppliers on a periodic basis. We are currently reviewing our due diligence procedures and future reviews may include:

a) Mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking.

b) Evaluating the modern slavery and human trafficking risks of each new supplier.

c) Conducting supplier assessments which have a greater degree of focus on slavery and human trafficking where general risks are identified.

d) Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.

7. Training and Communication:

ARL is currently implementing a company-wide training program in order to raise awareness of modern slavery issues by circulating information and case studies to employees.

We have provided Ethical and Sustainability supply chain training with modules regarding modern slavery to general managers within the company. This training will now be provided to each department by the general managers. These trainings will help employees to identify and prevent slavery and human trafficking and teach them what they can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation. The training is also included in employee’s induction process.

8. Approval and Review:

This policy has been approved by the organisation's CSR manager, who will review and update it annually. Our Executive Management team take responsibility for implementing this statement and its objectives. They will ensure adequate resources and investment to ensure slavery and human trafficking is not taking place within our organisation or within our supply chains.