MODERN SLAVERY & SOCIAL PROCUREMENT POLICY

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 third-party labour hire companies are often contracted to provide manufacturing, call centre and cleaning services.

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 14.1%. Since 2010, a Group review of gender pay equity has been conducted annually, with results reviewed by the Board and CEO’s. 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 employees.

Action: Establishing which suppliers to work with

Caring for You 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 sub-contracting 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 holistic Social Procurement commitment.