Modern-Slavery-Statement-FY22

Complete Office Supplies Pty Ltd Modern Slavery Statement 2022 5 RISK ASSESSMENT METHODOLOGY We utilise a risk assessment methodology which considers a number of indicators of modern slavery risks including geographic location and the level of automation in the production of goods. Using this methodology, we undertook risk assessments of modern slavery risks in our operations and supply chains over the reporting period to consider the extent to which we cause, contribute to, or are directly linked to modern slavery practices. These risk assessments have confirmed that our operations and supply chain continue to have a medium potential for modern slavery risks. Since our previous reporting period, we have expanded our risk assessment to consider circumstances where accommodation is provided as part of an employment offer. We acknowledge that our recruitment of casual labour via hire agencies has a higher risk of modern slavery, due to reports of some agencies targeting specific individuals and groups from marginalised or disadvantaged communities. Whilst use of labour via hire agencies is relatively low, COS has implemented a number of safeguards to mitigate this risk including only using Australian agencies who are subject to Australian laws and regulations and imposing minimum standard on these recruitment processes including through COS terms and conditions and policies such as our ethical sourcing policy, Therefore, our key area of vulnerability remains our exposure to manufacturing processes as well as some jurisdictions with an elevated risk. Our broader risk profile is summarised in the table below. MODERN SLAVERY RISKS We recognise that modern slavery may impact our business activities and we endeavour to take responsibility for reducing the risk that we might contribute to modern slavery through our operations and supply chains. Risk Description of risk People Reliance/ Level of Automation in Manufacturing Process We acknowledge that manufacturing processes that rely heavily on manual labour have an increased risk of unfair labour practices, particularly in developing countries. We have identified certain product categories, that as a result of their manufacturing process, have a higher risk than others. On Site Dormitory We understand that providing accommodation as part of an employment offer creates an increased risk of modern slavery. We acknowledge these circumstances have a risk in the exchange of value for the accommodation as well as the potential of the employer to control living conditions and freedom of movement. We have identified industries such as product manufacturing which have a higher risk of exposure to on site dormitories or offsite accommodation. Geographic/ Country of Manufacture Embedded at heart of the modern slavery is the local labour law and employment laws of individual countries. Local regulations establish the minimum conditions relating to employment, such as minimum working age, minimum hourly wage and freedom to leave. We have identified a number of elevated risk jurisdictions in our supply chains, including China, Indonesia, and Malaysia.