Modern-Slavery-Statement-FY22

Complete Office Supplies Pty Ltd Modern Slavery Statement 2022 6 DUE DILIGENCE As noted above, we undertook risk assessments to identify any key modern slavery risks that existed within our operations and supply chains. Consistent with previous reporting periods, the results of our due diligence have confirmed that our highest risk remains in the products we procure and resell to our customers, and this therefore remains our key focus area. All product suppliers were assessed (or re-assessed in many instances) and given a risk rating under our Modern Slavery Risk Assessment Framework (which as noted above is based on a matrix of geographic location and the level of automation in the production of goods). In FY2022, we categorised two suppliers as high risk as a result of concerns reported from customers through our internal grievance mechanisms. We continue to manage these high risk suppliers through increased monitoring and regular communication. We will continue this support throughout FY23 to reduce and mitigate the modern slavery risks of these suppliers in future. In addition to those suppliers identified above we identified 14 Tier 1 and Tier 2 suppliers as presenting a medium risk of modern slavery. GOVERNANCE AND ACCOUNTABILITY FRAMEWORK An internal modern slavery working group leads the assessment of our risks of modern slavery and implement actions to address those risks. The Modern Slavery working group comprises the General Manager – People & Culture, Import Category Manager as well as two Group Category Managers (who are the responsible for the appointment and management of suppliers). Since our last reporting period we have further embedded this working group into our business and have expanded membership to include our Co-CEOs. ACTIONS TO ASSESS AND ADDRESS RISK We understand the importance of working collaboratively with our employees, suppliers, and the broader industry to combat modern slavery. Over this reporting period, we have made significant progress in implementing further steps to assess and address modern slavery in our operations and supply chains. As noted further below, these additional steps include enhancing our risk assessment framework, expanding the rollout of our supplier terms and conditions to our Tier 2 suppliers, and engaging more closely with our clients on modern slavery risks – including by making our grievance mechanisms available to them. POLICIES AND PROCEDURES Our policies and procedures ensure we have strong frameworks to enable us to assess and address modern slavery risks. These policies and procedures include: - a Modern Slavery Risk Assessment Framework which allocates suppliers a risk rating and was modified in FY22 to include consideration of the additional risk of dormitories. All suppliers were reassessed, and risk ratings modified accordingly. - Self-Assessment Questionnaires – which were implemented across: • local and import suppliers with which we have preferred supplier arrangement in place, and we spend more than 0.5% of annual purchases (Local & Import Tier 1 Suppliers) ; and • local suppliers with which we have preferred supplier arrangement in place, and we spend more than 0.3% of annual purchases (Local & Import Tier 2 Suppliers) . - Ethical Sourcing Policy – which includes an overview of modern slavery. - our new supplier introduction process – for both direct and indirect suppliers and includes a modern slavery risk assessment. - Supplier Terms and Conditions which includes a commitment to our Ethical Sourcing Policy were implemented across approximately 80% of our procurement purchases through: • local and import suppliers with which we have preferred supplier arrangement in place, and we spend more than 0.5% of annual purchases (Local & Import Tier 1 Suppliers) ; and • local and import suppliers with which we have preferred supplier arrangement in place, and we spend more than 0.3% of annual purchases (Local & Import Tier 2 Suppliers) ; and - Grievance mechanism – which allows employees to raise concerns of modern slavery easily and anonymously within our operations and supply chains. In FY22 this process was also extended to allow our customers to anonymously raise concerns of modern slavery.