South32 : Modern Slavery Statement 2021

RESPECTING HUMAN RIGHTS

MODERN SLAVERY STATEMENT 2021

Modern Slavery Statement 2021

Contents

About us	1
Reporting entity	2
Consultation	2
Our approvals	2
Introduction	3
Our operations	4
Our business model	6
Our supply chain	8
Our approach	9
Due diligence	10
Risks	14
Empowerment	15
Remediation	16
Governance, monitoring and evaluating	17
Collaborative efforts	18
Appendix 1 - Governance documents	19
Appendix 2 - South32 key data updates and performance
indicators from FY19 to FY21	20
Appendix 3 - South32 performance as against effectiveness
targets, commitments and forward-looking intentions for FY22	21

See our reporting suite athttps://www.south32.net/investors-media/investor-centre/annual-reporting-suite,including the:

Sustainable Development Report

An overview of how our business-wide processes support our sustainability objectives and how we manage our key sustainability topics.

Sustainability Databook

Our supplementary reporting tool containing metrics and additional sustainability information.

Annual Report

Comprehensive information on our activities and financial performance throughout FY21.

Corporate Governance Statement

Our corporate governance practices and a description of our approach to responsible and ethical behaviour.

Tax Transparency and Payments to Governments Report Transparency on our approach to payments of taxes and contributions to governments where we operate.

www.south32.net

ACKNOWLEDGEMENT

We acknowledge and pay our respects to the Indigenous and Tribal Peoples

of the lands, waters and territories on which South32 is located and where we conduct our business around the world.

We respect and acknowledge the unique cultural and spiritual relationships that Indigenous and Tribal Peoples have to the land, waters and territories, and their rich contribution to society.

In the spirit of respect and reconciliation, we will continue to support initiatives that strengthen culture and ways of life so that their legacy continues and extends

to future generations.

South32

About us

SOUTH32 IS A GLOBAL MINING AND METALS COMPANY

We produce bauxite, alumina, aluminium, metallurgical coal, manganese, nickel, silver, lead and zinc at our operations in Australia, Southern Africa and South America. With a focus on growing our base metals exposure, we also have two development options in North America and several partnerships with junior explorers around the world.

Making a difference

Our purpose is to make a difference by developing natural resources, improving people's lives now and for generations to come. We are trusted by our owners and partners to realise the potential of their resources.

See some of the ways we make a difference in our Sustainable Development Report

Optimise, Unlock, Identify

Our purpose is underpinned by a simple strategy which

is focused on optimising the performance of our operations, unlocking their potential and identifying new opportunities to create value for all our stakeholders.

Read more about our strategy in our Annual Report

Care, Trust, Togetherness and Excellence

While our strategy outlines what we do to achieve our purpose, our values of care, trust, togetherness and excellence guide how we do it. Every day, our values shape the way we behave and the standards we set for ourselves and others.

2021 Statement Slavery Modern

1

Learn more about our people in our Sustainable Development Report

South32

Modern Slavery Statement 2021

Reporting entity

In line with Section 14(b) of the Australian Modern Slavery Act 2018 (Cth), we produce one statement that responds to both the Australian Modern Slavery Act 2018 (Cth) requirements and the UK Modern Slavery Act 2015 (against which we report on a voluntary basis).

The submitting entity is South32 Limited (ABN 84 093 732 597) as the parent company of the South32 Group of Companies and its registered office is Level 35, 108 St Georges Terrace, Perth, Western Australia 6000. South32 is listed on the Australian Stock Exchange, the London Stock Exchange and the Johannesburg Stock Exchange. South32 Limited qualifies as a reporting entity under the Australian Modern Slavery Act 2018 (Cth).

The following entities also meet the reporting test set out in the Australian Modern Slavery Act 2018 (Cth): Dendrobium Coal Pty Ltd, Endeavour Coal Pty Ltd, South32 Aluminium (RAA) Pty Ltd, South32 Aluminium Worsley Pty Ltd, South32 Cannington Pty Ltd, Illawarra Coal Holdings Pty Limited and operated joint venture Groote Eylandt Mining Company Pty Ltd. In this statement, unless expressly mentioned otherwise, references to South32 and the South32 Group, the Company, we, us and our, refer to South32 Limited, its subsidiaries and its controlled entities and South32 operated joint operations as a whole. This statement does not cover our non- controlled nor non-operated joint ventures operations.(1)

Consultation

Our corporate governance and risk management framework (which includes the policies, standards, procedures and tools through which modern slavery risks are assessed and managed) is developed centrally by the South32 Board, Lead Team and management and applied across the South32 Group, including at our operated joint ventures. Operations in the South32 Group and operated by South32, as well as South32 functional teams, implement modern slavery risk management processes across South32 by undertaking risk identification, reporting and training as described in this statement. This statement has been prepared with input from, and in consultation with, South32 Lead Team and management representatives responsible for overseeing this work across the South32 Group (including our reporting entities and their controlled entities). For further information on our corporate governance practices, Board, Committees, and risk management and internal controls, please refer to our Corporate Governance Statement.

Our approvals(2)

This statement was endorsed by the Sustainability Committee and approved by the Board of South32 Limited on 2 September 2021.

2

Graham Kerr

Chief Executive Officer, South32 Limited

Date: 2 September 2021

1. Disclaimer: This document has been prepared by South32 Limited and its controlled entities and South32 operated joint operations for reporting under the Modern Slavery Act 2018 (Cth) and disclosure on South32's website in relation to its actions during the period 1 July 2020 to 30 June 2021 and its financial position as at
   30 June 2021. South32 has prepared this document based on information available to it at the time of preparation. The information contained in this document is general in nature, and does not purport to be complete. This document should be read in conjunction with South32's 2021 Annual Report, 2021 Sustainable Development Report and 2021 Corporate Governance Statement and other periodic and continuous disclosure announcements lodged with the ASX, which are available at www.south32.net. Except as required by applicable laws or regulations, the South32 Group does not undertake to publicly update or review any forward-looking statements, whether as a result of new information or future events. South32 Limited shares trade on the ASX, JSE and LSE under the listing code of S32. Monetary amounts in this document are reported in US dollars, unless otherwise stated. Metrics describing performance apply to 'operated operations' that have been wholly owned and operated by South32, or that have been operated by South32 in a joint venture operation, from 1 July 2020 to 30 June 2021. Unless otherwise stated, operations that we divested during the reporting period are shown for the period up until we ceased operational control of those operations (being 31 December 2020 for Tasmanian Electro Metallurgical Company (TEMCO) and 31 May 2021 for South Africa Energy Coal (SAEC)).
2. Mandatory criterion outlined in sections 16(1)(a) and 16(1)(f) of the Australian Modern Slavery Act 2018 (Cth).

"

All human beings are born free and equal in dignity and rights"

Article 1, Universal Declaration of Human Rights

South32

Introduction

As a business with a large and complex global supply chain and operations and projects across Australia, Southern Africa and the Americas, we recognise that modern slavery is a real risk. We are committed to respecting human rights and taking meaningful action against modern slavery. Not only is this the right thing to do and central to our purpose and values, but it is critical to the integrity and success of our business. Addressing modern slavery risks in our operations and supply chain requires collaboration and we work closely with our stakeholders to continually evolve our approach.

In FY21 we finalised "Our Approach to Human Rights" - a set of 13 guiding principles. Each principle is important in addressing risks of modern slavery, but the most relevant are:

- We will work to reduce the risk of modern

slavery within our operations and supply

chains, including human trafficking, forced,

bonded or involuntary labour, and child

labour.

- We will support the rights to freedom of

association and collective bargaining, provide

Modern slavery is not acceptable in our operations or supply chains. Although we	Modern
have found no instances of modern slavery during FY21, this statement outlines
our approach to further reduce the risk of modern slavery in our operations and
supply chains.			Slavery
	Key performance updates in FY21	Page	Statement
	Implemented a third-party supplier screening	11
	platform (EcoVadis) and mapped 5,354
	suppliers for modern slavery country and		2021
	industry risks, as per EcoVadis criteria.
	Invited suppliers, based on risk and
	commercial relationships, to complete the
	EcoVadis in depth supplier assessment, which	12
	includes both modern slavery and broader
	sustainability assessments.
	Completed 14 independent supplier audits.	13
DUE DILIGENCE	Completed Industry Supplier Self-Assessment
Questionnaire ("SAQ") pilot.	10
	595 suppliers have completed the SAQ.
	Signed the Neptune Declaration and
	conducted human rights due diligence on	13
	seafarer welfare across the ports where we
	operate.
	Completed an independent shipping audit
	and agreed a development plan with the ship	13
	owner.

decent work and work towards embedding a

living wage.

- We will provide and maintain a safe

workplace and create and maintain a work

environment free from discrimination and

harassment.

- We will provide accessible and safe grievance

and redress channels for stakeholders to

raise complaints about human rights, and

where we have caused or contributed to an

adverse human rights impact, we will provide

for or cooperate in remediation through

EMPOWERMENT AND REMEDIATION

3

Updated modern slavery training completed	15
by over 1,000 employees and contractors.
Trained 125 supply companies and developed	15
a new supplier training strategy.
Developed an Industry Remediation Action
Plan with the Western Australian Modern	16
Slavery Collaborative Group ("WAMSc").

legitimate processes.

- We will communicate these principles and

our human rights expectations to relevant

stakeholders.

- We will conduct regular human rights training

for employees and contractors, and where

possible, extend these to our suppliers and

interested stakeholders.

- We will track the effectiveness of our

processes to continually improve our

approach and embed human rights across

the business, and publicly report our

progress.

The COVID-19 pandemic continued to impact our modern slavery assessment processes during FY21. Due to border controls and travel restrictions we had less opportunities to conduct in-person supplier audits. The audits that could not be completed will be prioritised for FY22. The pandemic also exacerbated risks for seafarers, which we helped to mitigate through various initiatives.

	Launched updated Sustainability and Business	17
	Conduct - Minimum Supplier Requirements.
MONITORING
AND EVALUATION

Contributed to the WAMSc, Sustainable

Shipping Initiative and United Nations Global 18 Compact Network of Australia Modern Slavery

COLLABORATION Community of Practice.

This is our sixth modern slavery statement. In addition to our FY21 progress update, Appendix 2 summarises the key performance indicators from our three most recent modern slavery statements to demonstrate progress made on identified risks and assessment processes, and in Appendix 3, we report on performance against our targets and commitments. We intend to publish data and analysis every three years, including year-on-year comparisons, to give our stakeholders visibility of our progress and show any changes in our approach.

South32