Woolworths : Modern Slavery Statement

are Woolworths Group

2022

Modern Slavery Statement

Woolworths Group Limited

ABN 88 000 014 675

b

Contents

Section 1

CEO message

2

Section 2

Our structure, operations and supply chain

4

Section 3

Identifying and taking action to address modern	8
slavery risks

Section 4

Grievance and remediation

27

Section 5

Assessing the effectiveness of our actions

28

Section 6

Engaging with ecosystem entities	31
Looking forward: our plans for F23	35
Partnerships	36
Appendix: List of reporting entities	38
Our corporate reporting suite	40

Acknowledgment of Country

Woolworths Group acknowledges the Traditional Custodians of Country throughout Australia and recognises their continuing connection to land, waters and community. We pay our respects to them and their cultures; and to Elders both past and present.

Aboriginal and Torres Strait Islander people should be aware that this report may contain the names and images of deceased persons.

Statement on reporting entity

Woolworths Group Limited (ACN: 000 014 675) is an Australian public company listed on the Australian Securities Exchange (ASX: WOW). The company is registered at 1 Woolworths Way Bella Vista NSW, Australia. This Statement has been published in accordance with the Modern Slavery Act 2018 (Cth) (MSA or Act). It identifies the steps Woolworths Group Limited and its controlled entities (including the reporting entities listed in the Appendix) (together, for the purposes of this Statement, 'Woolworths Group' or 'Group') took to identify, assess, mitigate and remediate modern slavery risks in its operations and supply chain during year ending 26 June 2022 (F22). Woolworths Group Limited makes this joint Modern Slavery Statement (Statement) to cover the Woolworths Group.

All amounts are expressed in Australian dollars unless another currency is indicated.

This report contains forward looking statements, please read our disclaimer on page 2 of the2022 Sustainability Report Appendixfor more information.

Mandatory reporting criteria of the Modern Slavery Act

This Statement was prepared to meet the mandatory reporting criteria set out under the Modern Slavery Act 2018 (Cth). The table below identifies where each criterion of the Act is disclosed within sections of this Statement.

MSA CRITERIA	REFERENCE IN THIS STATEMENT
Identify the reporting entity	Inside front cover
Describe the reporting entity's structure, operations and supply chains	Pages 4 to 5, 32, 38 to 39
Describe the risks of modern slavery practices in the operations and supply	Pages 8 to 27
chains of the reporting entity and any entities it owns or controls
Describe the actions taken by the reporting entity and any entity it owns	Pages 8 to 28, 31 to 32, 36 to 37
or controls to assess and address those risks, including due diligence and
remediation processes
Describe how the reporting entity assesses the effectiveness of these actions	Pages 28 to 30
Describe the process of consultation with any entities that the reporting entity	Pages 31 to 34
owns or controls (a joint statement must also describe consultation with the
entity giving the statement)
Provide any other relevant information	Pages 35 to 37

Human rights is increasingly integrated into the way we go about our business every day, so that every decision we make has our purpose at heart; creating better experiences together for a better tomorrow.

Our Human Rights Program is underpinned by our core values of caring deeply, listening and learning, and always doing the right thing. We are committed to continuous improvement so that our processes and interventions remain effective

in preventing and remediating modern slavery.

These approaches come together in our Human Rights Program principles that guide our work in this area:

No global retailer is immune to modern slavery risk in their operations and supply chains.

We adopt a human rights-based approach in our modern slavery strategy. That means that we consider risks to people alongside risks to the business.

Identifying actual or potential situations of modern slavery demonstrates our program is effective. It means we are better placed to provide remedy to affected workers and address root causes.

Where potential situations of modern slavery are identified,

we will always do the right thing, which means acting in the best interests of potentially affected workers.

Modern slavery can only be ended by working with others. We will work collaboratively to drive change that addresses the root causes of modern slavery.

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Group Woolworths Statement Slavery Modern 2022

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Section 1

CEO message

This year's Modern Slavery Statement is a reflection of our commitment to being truly purpose-led;creating better experiences together for a better tomorrow.

As a people business, upholding respect for human rights is critical across our operations and supply chain as we continue to be guided by our core values of caring deeply, listening and learning, and always doing the right thing.

Modern slavery can only be ended by working with others, and partnerships are a key principle of our approach. This year we focused on building long-term strategic partnerships that will help us play a broader proactive role in our ambition to end modern slavery via international peer learning, dedicated engagement and advocacy streams. These include joining

The Consumer Goods Forum Human Rights Coalition, entering into a Memorandum of Understanding with the Retail Supply Chain Alliance and the reintroduction of Woolworths Group hosted roundtables on modern slavery. Further information on partnerships established this year can be found on page 36.

We are moving to a deeper phase of program maturity. This year we intentionally focused on getting the right policies and frameworks in place to provide our teams and suppliers appropriate guardrails to manage key risk areas. These governance enhancements included updating our Responsible Sourcing Policy and Standards, launching a Sustainable Cotton Policy and delivering an end-to-end governance framework for labour providers used in our business, among others.

Moving forward, we remain focused on embedding delivery against these frameworks, prioritising ongoing strategic work in extreme risk areas, and remediating negative impacts where these are identified.

Last year, Woolworths Group identified and disclosed a potential case of debt bondage at a supplier site in Malaysia. A number of forced labour indicators were identified at the supplier site, including workers having paid excessive recruitment fees, and security bonds that placed restrictions on freedom of movement. Following further work and the support of an independent third party assessment which considered the interplay of these indicators, we've since confirmed this is the first instance of modern slavery identified in our supply chain.

In the interest of current and future workers, the most enduring impact we can have is when we continue engaging with the supplier to not only remediate impacted workers but lift standards through enhanced policies and procedures. Our team worked diligently

in partnership with the supplier and a number

of external stakeholders to secure fees remediation

to impacted foreign migrant workers, and to put systems in place to prevent the recurrence of similar forced labour issues at this site.

This year we agreed with the supplier that approximately $750,000 is to be returned to an estimated 226 migrant workers from Nepal, Bangladesh and Myanmar. We also took learnings from this case and launched a Responsible Recruitment Addendum to our Responsible Sourcing Standards. The Addendum sets out our supplier requirements, guidance and remediation protocols as they relate to migrant workers in higher risk geographies. Roll out will commence in Malaysia in F23.

This is a complex space to navigate, and we are still learning. During the investigation and remediation process, our team was guided by a number of our Human Rights Program principles:

• identifying actual or potential situations of modern slavery demonstrates that our program is effective. It means we are better placed to provide remedy to affected workers and address root causes
• where potential situations of modern slavery are identified, we will always do the right thing, which means acting in the best interests of potentially affected workers.

In sharing our experiences, we hope other companies can learn from and build on our approach. More information on our remediation principles, process and lessons learned can be found on pages 20 to 21.

This Statement was approved by the Woolworths Group Board on 23 August 2022, on behalf of all reporting entities covered by this Statement.

Brad Banducci

Chief Executive Officer

23 August 2022

Key program highlights in F22

• ~$1 million in repayments has been, or is in the process of being, returned by suppliers to more than 990 workers across our supply chain
• 132 passports were returned to migrant workers in our supply chain in Malaysia
• Commenced a cotton supply chain traceability pilot to increase visibility of raw material sourcing
• Developed a labour governance framework to monitor third party labour risks at our sites
• 65 tier two suppliers assessed for modern slavery risks across apparel and dried fruit categories

• Supported our suppliers to manage modern slavery risks and meet the Group's expectations with the launch of three new resources:

1. Child Labour Prevention and Remediation Addendum
2. Responsible Recruitment Addendum
3. Sustainable Cotton Policy

• Strengthened our commitment to collaboration with three partnerships:

1. Centre for Child Rights and Business
2. Consumer Goods Forum Human Rights Coalition
3. Retail Supply Chain Alliance

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Group Woolworths Statement Slavery Modern 2022

1 Section

Progress against our objectives

The ambition of our current five-year Human Rights Program is outlined in the Woolworths Group Sustainability Plan 2025. Our 2025 commitments are underpinned by annual plans and quarterly objectives. We continue to monitor progress against our annual plans and this is outlined below.

Operations		Supply Chain
OBJECTIVES	STATUS COMMENT	OBJECTIVES	STATUS COMMENT

2 Section

Team member training on modern slavery, prioritising those managing higher risk categories

Design and pilot

• mechanism for potentially affected groups to participate in program design and evaluation

Create an end-to-end labour governance monitoring framework to proactively monitor compliance with contractual controls (new for F22)

Commence due diligence framework for controlled entities across the Group ecosystem

Continue in F23. Developed four bespoke modules designed to build awareness of the risks of modern slavery and labour exploitation in our supply chain. Roll out will commence in F23.

Continue in F23. Consulted our Refugee Employment Program team members to understand their views on our human rights program. Engaged 211 cleaners and trolley collectors in a survey on Supplier Speak Up.

Complete. A cross-functional squad designed an end-to-end framework with five key pillars to mitigate modern slavery risks associated

with labour providers used in our operations.

Complete. Held 13 one-to-one engagements with entities that we control (but do

not wholly own) or have

a minority interest in, to share learnings and understand their approach to managing modern slavery risks. We will continue this in F23.

Pilot a due diligence approach with vendor branded suppliers of an extreme risk commodity

(new for F22)

Continue to prioritise due diligence of labour providers

in our Australian horticultural supply chain, engaging suppliers and industry groups (new for F22)

Partner with Woolworths Food Company Strategic Sourcing team to design and deliver due diligence for identified high-risk commodities

Design and deliver a due diligence approach for non-trade suppliers based on category risk segmentation

Prioritise the rollout of strategies in extreme risk areas including seafood,

Complete. Piloted a listen and learn approach with four vendor branded apparel suppliers that offered practical insights into the operationalisation of our sourcing policies.

Continue in F23.

Continued to increase visability of labour providers in high risk categories and conducted a focus group discussion with suppliers on implementation challenges.

Continue F23.

Established a Commodities squad and piloted a due diligence approach at tier two supplier sites for dried fruit and nuts.

Continue in F23. Finalised the 'Supplier Grow' Supplier Management Framework for implementation in F23.

Continue in F23. Launched a seafood supplier gap assessment, Sustainable Cotton

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Complete

Partially complete

cotton and at supplier sites in Malaysia

Policy, and Responsible Recruitment Addendum. Managing extreme risk areas remains a priority.

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