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Woolworths : Modern Slavery Statement (print friendly)

09/07/2022 EST

are Woolworths Group


Modern Slavery Statement

Woolworths Group Limited

ABN 88 000 014 675



Section 1

CEO message


Section 2

Our structure, operations and supply chain


Section 3

Identifying and taking action to address modern


slavery risks

Section 4

Grievance and remediation


Section 5

Assessing the effectiveness of our actions


Section 6

Engaging with ecosystem entities


Looking forward: our plans for F23




Appendix: List of reporting entities


Our corporate reporting suite


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 the 2022 Sustainability Report Appendixfor more information.

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.


Group Woolworths Statement Slavery Modern 2022

1 Section

2 Section

3 Section

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.



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

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.

4 Section

5 Section

6 Section


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.

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


Group Woolworths Statement Slavery Modern 2022

1 Section

Progress against our objectives

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,

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

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.


Supply Chain





2 Section

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

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

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

3 Section

4 Section

5 Section

impacted workers but lift standards through enhanced policies and procedures. Our team worked diligently

Chief Executive Officer 23 August 2022


Partially complete

cotton and at supplier sites in Malaysia

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

6 Section


Section 2

Our structure, operations and supply chain


Woolworths Modern 2022

Our operations

Group Slavery

Woolworths Group is Australia's largest retailer with a collective store footprint spanning all states and territories.


Our 1,261 stores in Australia are comprised of 1,085 food stores (Woolworths Supermarkets and Metro Food Stores)

and 176 BIG W stores. We are also the largest retailer in New Zealand with 190 Countdown supermarkets. Our retail

entities are supported by other businesses and platforms, including our logistics business Primary Connect, our circular

economy initiative Woolworths360 (W360), retail media business Cartology, and venture capital and innovation fund

W23. Our 19 support offices span 5 countries, with the majority in Australia and New Zealand.

Our workforce comprises the approximately 197,000 directly employed team members who work across Woolworths Group

Woolworths Group is a food and everyday needs ecosystem which includes some of Australia and New Zealand's most trusted retail brands, unified by our purpose of creating better experiences together for a better tomorrow. Our food and everyday needs ecosystem consists of our core retail food businesses, leading eCommerce, digital and data capabilities, and complementary platforms and partnerships that enhance the customer experience and provide adjacent growth opportunities.

Details of each reporting entity covered by this Statement, together with a description of their respective activities and key brands, is set out in the Appendix on pages 38 to 39. Woolworths Group also has a number of controlled entities and these are discussed in Section 6 on pages 31 to 34.

Business to Consumer (B2C) Food:

Our cornerstone retail food stores and online channels are famous for fresh produce and Woolworths branded products made by our dedicated Woolworths Food Company team.

More Everyday:

This segment complements our focus on food and includes everyday categories, such as BIG W, to provide more value for our customers.

in our stores, distribution centres, logistics and support offices. Our operations also include indirect workers, including a F22


average of approximately 7,900 professional services contractors, as well as sub-contractors and labour-hire resources

that support our business with ongoing labour or the provision of services in Woolworths Group's facilities.

Our supply chain

Woolworths Group has one of the largest and most complex retail supply chains in Australia. We work with approximately

18,270 direct suppliers across trade (vendor and non-vendor branded) and non-trade.Non-vendor branded refers to


suppliers that produce or pack products for a Woolworths Group brand and fresh categories. These are commonly

referred to as our 'own brands'.

Woolworths Supermarkets prides itself on being Australia's Fresh Food People, this year sourcing 97% of all fresh fruit and

vegetables and 100% of fresh meat, sourced by Greenstock, from Australian farmers and growers. Similarly, 100% of fresh


meat for Countdown Supermarkets is sourced from New Zealand, as is 83% of fresh fruit and vegetables.

Of the other Woolworths Group branded products, 75% of the food category is manufactured in Australia, with non-food categories sourced mainly from China (76%) and Australia (10%). There are 417 sites supplying BIG W branded products

- of these 91% are sourced from China and Bangladesh.

Non-trade suppliers provide goods and services to support our operations. The largest non-trade supplier categories by


spend are supply chain, corporate services, construction and equipment, IT and property services.

Direct suppliers are also known as tier one suppliers. There are thousands of other suppliers that contribute to the Group's

supply chain through the provision of goods or services to direct suppliers. These suppliers are indirect suppliers, often


B2C Food

More Everyday


eCommerce Products





Supply &

Network &


International Wholesale

& data





Business to Business (B2B) Food:

Building on our strength in food, we continue to expand into new customer segments and international markets.

Retail Platforms:

Our technology and supply chain platforms help bring our business to life through data, analytics and logistics capabilities that support the Group and our partners.

referred to as suppliers beyond tier one or tier two, three or four suppliers. We know that modern slavery risks are often

found beyond tier one suppliers at different stages of production, including raw material extraction. We have prioritised

risk management in extreme risk categories beyond tier one suppliers, and this is discussed further in the Statement.

Our suppliers

Our team

Our stores

4 Section




total direct suppliers

team members





1,085 Australian Food



197,028 1



directly employed



175,154 Australia


New Zealand Food


Own brand




Woolworths Food

contracted (Australia)



21,447 New Zealand






  • Excludes Statewide Independent Wholesalers Pty Ltd, Quantium Group Holdings Pty Ltd, Quantium Group Pty Ltd and PFD Food Services Pty Ltd.


Human Rights Program governance and ways of working

Our Human Rights Program framework

Our approach to human rights has been in place for five years and we have made solid progress in that time.


Woolworths2022 GroupSlavery Modern

We manage modern slavery and broader human rights risks in our operations and supply chain through our Human Rights Program. It is informed by the United Nations Guiding Principles on Business and Human Rights (UNGPs), the International Labour Organization's (ILO) Declaration on Fundamental Principles and Rights at Work, our Woolworths Group Risk Management Framework and the Board approved Risk Appetite Statement, which identifies human rights as a level one risk, meaning we work 'towards zero'.

Our Group Sustainability team, like the rest of Woolworths Group, is transitioning towards agile ways of working. Agile allows teams to focus on delivering projects at pace through iterations and helps to actively prioritise activities, based on feedback and other changes. Agile at Woolworths Group follows the principles of:

  • Platforms-buildcapability to scale across Woolworths Group and deliver value in the businesses
  • Chapters-technicalexperts responsible for providing thought leadership and partnering with squads to deliver work
  • Squads-cross-functionalworking groups that accelerate the work
  • Businesses-deliveringdirectly to our customers with ownership for delivery relating to their businesses.

Human Rights is a Chapter within the Group Sustainability Platform. The Group Human Rights team is responsible for developing the overarching human rights strategy

and annual work plan. Human Rights team members in Australia, New Zealand, China, Hong Kong and Bangladesh are supported by allocated business partners that come together in Squads based on annual priorities.

This operational approach is supported by the Human Rights Steering Committee (SteerCo) that is sponsored by the Chief Sustainability Officer (CSO). Members of SteerCo are reviewed annually based on the strategic priorities of that year, aligned to risk. In F22, this included the Director of Sourcing for Australian Food Group, General Manager of Procurement, Head of Quality Assurance, Ethical Sourcing and Packaging Sustainability for BIG W, Woolworths Group Company Secretary, and General Counsel for Australia Food Group.

SteerCo oversees the implementation of the Group's Human Rights Program, including strategic direction, prioritisation, risk management, resourcing, reporting and program effectiveness. Progress is reported to the Board through periodic updates via the CEO report, and the Board Sustainability Committee (SusCo) through the quarterly CSO report and deep dive paper into human rights each financial year.

This year, for the first time, Woolworths Group's incentive scheme for the senior executive team included a reputation metric measured externally by RepTrak.

This represents an important step in further aligning and embedding delivery of our strategy against purpose, which includes our human rights strategy.

The first phase (2017-2020) focused on the development, rollout and embedding of the Responsible Sourcing Program (RS Program) across own brand and fresh product categories. In this current phase (2021-2025) we are scaling up human rights due diligence across our value chain, including non-trade, operations and ecosystem partners, while maintaining a focus on higher-risk commodities and countries in our trade supply chain.

To maximise our impact we take a risk-based approach to supply chain management. This means we:

  • Prioritise our work where there is a higher likelihood of severe human rights impacts, including modern slavery, occuring
  • Look for opportunities where we have greater influence to drive change within our supply chains
  • Use a supplier and category segmentation approach based on inherent risk to determine which suppliers are in scope of the RS Program.

Our Human Rights Program includes three sub-programs though which we manage key human and labour rights risks in our supply chain:

  • Responsible Sourcing-Trade: the most developed program, includes supplier segmentation and due diligence of own brand and fresh suppliers
  • Responsible Sourcing-Non-trade: includes category level risk segmentation and supplier engagement for non-trade procurement
  • Bespoke and targeted risk-baseddue diligence: focuses on industry and country specific modern slavery due diligence in extreme risk areas, including supplier capability, advocacy and industry memberships.

Suppliers of vendor branded goods and services are required to have established arrangements and processes which are consistent with our commitment to responsible sourcing and upholding human rights outlined in the Responsible Sourcing Policy (RS Policy).

Suppliers and categories in scope of our RS Program, operationalised through our Responsible Sourcing Standards (RS Standards), are listed in the table below:




Woolworths Own Brand (Including any product carrying Woolworths name and address)

and Metro

Fresh Meat and Seafood (Including products sold behind the counter)


1 Section

2 Section

3 Section

Woolworths Group Board

Responsible for reviewing, appraising and approving the Group's Sustainability Plan 2025,

which includes human rights and our annual Modern Slavery Statement

Sustainability Commiee (SusCo)

Reviews and monitors the Group's human rights initiatives and due diligence. SusCo is responsible for reviewing the

Group's Modern Slavery Statement and recommending it to the Board for approval

The CEO and Executive Commiee, including the CSO

Accountable for the implementation of our Human Rights Program and managing human rights risks across the Group. Progress is reported to SusCo quarterly

Supported by external human rights advisory partners, ELEVATE and Verité

Human Rights Steering Commiee (SteerCo)

Oversees the implementation of the Group's Human Rights program



Third party labour


Sustainable Cotton


governance (operations)

(Woolworths Food Group)

(Woolworths Group)

Functions and Business Units (BU)

Woolworths Supermarkets

Woolworths Food Company




Primary Connect

Brand and Reputation



Group Risk

Food Stores

Fresh Produce (Fresh fruit, vegetables and floral products)


BIG W Own Brand (Including any product carrying BIG W's name and address)

GNFR (Goods

Suppliers of high-riskservices (Including but not limited to cleaning, trolley collecting, security and logistics)

not for resale)

Suppliers of branded goods not for resale (Including but not limited to shopping bags, baskets,

trolleys, signage and uniforms)

Understanding our risks of involvement in modern slavery

In identifying and assessing the modern slavery risks in our operations and supply chain, we use the UNGPs continuum of involvement to determine whether we may cause, contribute to or be directly linked to harm. Under the UNGPs:

  • A company may cause modern slavery if its own acts or omissions directly result in the modern slavery occurring (for example, if it engaged children in hazardous work)
  • A company may contribute to modern slavery if its own acts or omissions are significant in facilitating, encouraging or enabling another party to cause a situation of modern slavery (for example, if its purchasing practises put significant cost and time pressures on suppliers that they could only met through the use of forced labour)
  • A company may be directly linked to modern slavery by its operations, products or services through a business relationship (for example, if a product it purchases was manufactured using workers in debt bondage).

4 Section

5 Section

6 Section


Woolworths Ltd. published this content on 07 September 2022 and is solely responsible for the information contained therein. Distributed by Public, unedited and unaltered, on 13 September 2022 06:59:04 UTC.

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