Modern Slavery & Social Procurement Policy

Company Policy

1. Summary

1.1. Caring for You recognises that we must take steps to identify and address any actual or
potential adverse impacts with which we may be involved whether directly or indirectly
through our own activities or our business relationships, or in procurement of goods or

2. Potential Risks

2.1. The below table outlines the potential modern slavery risks for our business:

Non-compliance with our labour
standards in the supply chain
including health and safety,
working hours, wages, forced
labour and child labour, and
freedom of association.

Our business has different modern slavery risks depending on various factors, including the level of human rights protection and enforcement in the countries where they operate or source from. With a high number of suppliers in countries where the level of maturity in the protection of human rights regarding labour conditions is low, there is risk of harm to people.

Previously we considered non-compliance with our labour standards to be high-risk in all regions except for Western Europe, Australia and New Zealand, however, our due diligence process has revealed unfair working conditions such as the underpayment of sub-contracted workers and poor health and safety standards are potential risks in any region including Australia.

Our due diligence process has revealed that there is an increased risk of unfair working conditions for people who are employed by third party labour hire companies. These thirdparty labour hire companies are often contracted to provide manufacturing, call centre and cleaning services.

Non-compliance with broader
human rights which can be
connected to or indicative of
modern slavery risk, including
employee rights to equality, fair
pay, safety and privacy.

We have identified that some level of discrimination based on gender, age, race, disability, sexual orientation, cultural background, religion, family responsibilities or other areas of potential difference is a potential risk in any business.

Australia has a gender pay gap of 15.3%. Since 2010, a Group review of gender pay equity has been conducted annually, with results reviewed by the Board and divisional Managing Directors. Over this period the company has moved to close any pay equity gaps. Any apparent gaps are analysed to ensure such gaps can be explained with reference to market forces which may include, for example, different rates of pay in different industries, location and the relative supply and demand for different qualifications, individual performance and experience.

We recognise the right of those we employ to negotiate their
wages either individually or collectively, with or without the
involvement of third parties. We also believe in maximising the
flexibility of workplace arrangements available to our


3. Actions Taken to Address Risks

3.1. We are committed to regularly undertake the following actions to mitigate the potential
modern slavery risks:

Non-compliance with our labour
standards in the supply chain
including health and safety,
working hours, wages, forced
labour and child labour, and
freedom of association.

Action: Establishing which suppliers to work with

Caring for You Officers will take a risk-based approach when making the decision to conduct detailed due diligence on a supplier of goods for resale, based on the goods or services, country of origin and vendor. Before we contract with a new supplier, we assess its risk against our criteria and require high-risk suppliers to complete a risk assessment questionnaire and/or be audited. We investigate the supplier to understand risks of human rights breaches. We also consider whether there
may be any sanctions that may be in place against that supplier or the country in which it is located.

We will only work with suppliers to supply goods for resale who operate in line with the Caring for You Social Procurement commitment. All suppliers producing goods for our organisation must agree to comply with the following minimum standards in their agreements with our businesses:

    • No forced or bonded labour
    • No child labours
    • Transparent record-keeping of wages and benefits
    • Working hours must comply with applicable local laws
    • No discrimination
    • No harassment or abuse
    • Freedom of association
    • Working conditions: suppliers shall provide a safe and hygienic working environment that is without risk to health, taking into consideration knowledge of the relevant industry and any specific hazards
    • No bribery
    • Approved sub-contracting: there shall be no subcontracting unless previously approved by Caring for You in writing.

While not all these minimum standards are directly relevant to
modern slavery, they are important to Caring for You’s holistic
Social Procurement commitment.

4. Breach of Policy

4.1. Failure to abide by this company policy may result in disciplinary action. In serious cases this
may include termination of your employment or engagement. If you break the law, you may
also be personally liable.

5. Policy Review

5.1. This policy will be reviewed on an annual basis by the People & Culture Manager. Any
proposed changes to this policy must be approved by the Co-CEOs.