Question: Has the company reviewed business KPIs to ensure they are not increasing risk of modern slavery? (E.g. expansion to production countries that have a lot of migrant workers)
Walk Free
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pg. 11


Forever New is committed to developing a strong, consistent, group-wide approach to address and minimise the risks of modern slavery in its operations.

To help meet this commitment, ADT Group Holdings Pty Ltd developed this joint statement in consultation with Forever New Clothing Pty Ltd, being its wholly-owned subsidiary and a reporting entity under the Australian Act and it’s subsidiaries located around the world. Each subsidiary operates under a common governance framework to address modern slavery risks which is centrally managed.

The directors of Forever New Clothing Pty Ltd are also directors of ADT Group Holdings Pty Ltd. ADT Group Holdings Pty Ltd is the holding company of Forever New Clothing Pty Ltd and as such, does not engage in any operations itself. Trading and operational activity is conducted via its subsidiaries.

All controlled entities operate within the same sector.

In preparing this statement, input was sought from key management personnel of Forever New Clothing Pty Ltd from central functions including production, finance, operations, human resources, legal and logistics. Initially, focus was on compiling information across these functions which was then analysed by a small working group. From there, modern slavery risks were identified and plans devised to address those risks. This statement is the result of that work.

The Audit and Risk Committee of ADT Group Holdings Pty Ltd reviewed and approved this statement before it was approved by the respective boards of ADT Group Holdings Pty Ltd and Forever New Clothing Pty Ltd."

pg. 10


Of the 70 audits we conducted during the reporting period, we oversaw the closure of 55% of non-compliances raised during those audits within the same period. The most prevalent findings related to working hours, social insurance payments and safety. During the reporting period, we did not terminate any factory due to non-compliance with our ethical sourcing requirements."

Singh Anjali.....2021-11-16 14:10:07 UTC

Consultation with controlled entities and the reporting of audits and non-compliances addressed to closure are not evidence of the company having reviewed its KPIs as there is no disclosure of KPIs related to their negative impacts. Therefore, I changed the answer from Yes to No.

Sofia Gonzalez De Aguinaga.....2021-12-08 02:09:22 UTC