pg. 12

"Managing forced labour risks in Malaysia

Of the two cases in Malaysia, one was related to withholding of passports, which was remediated by giving workers unrestricted access to their safety deposit box. The other identified that foreign migrant workers from countries including Bangladesh, Myanmar and Nepal had paid recruitment fees in their home countries and were required to pay a deposit to their employer before being allowed to travel outside of Malaysia.

Where there is a potential for modern slavery, routine audits serve the purpose of identifying red flags for further investigation. As a potential indicator of debt bondage, Woolworths Group triggered our ZT procedure and engaged ELEVATE, to conduct a full investigation at the site. The investigation:

• Found factory management to be generally cooperative and there is no indication of falsification of records or coaching of workers

• Found workers have their own set of keys to access personal lockers to safely store their passports/personal documents (reducing the forced labour risk of restriction on freedom of movement)

• Validated the original audit finding on the payment of recruitment fees and determined that the amounts paid were broadly consistent with the fee payments from other sectors in Malaysia

• Estimated the fees paid by 226 workers to be approximately $3,300 per worker.

As a result:

• Our team and the supplier are finalising a fees reimbursement plan

• We have agreed further corrective actions that seek to address the root cause of the payment of recruitment fees including governance of labour agents and a requirement for pre-departure briefing for migrant workers before they leave their home country

• Additional measures include:

– Providing policies and information in languages workers can understand

– Improvements to bring current dormitory conditions into line with Malaysian legal requirements.

Last year we committed to disseminate supplier guidance and conduct training at sites in Malaysia to address forced labour risks. These were paused due to the prioritisation of remediation and the ongoing impacts of COVID-19. Incorporating the lessons learned from this case will inform our due diligence for other sites in Malaysia and recommencing these activities is a priority in F22."

pg. 17

"Fresh meat in Woolworths Supermarkets

Since our RS Program commenced in 2018, we identified our fresh food supply chain as an area of interest due to the known inherent risk associated with agricultural production. We first prioritised our response in horticulture and from last year commenced work in our Australian meat supply chain. To date: • 100% of our own brand fresh meat is in scope of our RS Program • Fresh meat (beef, lamb and pork) is sourced in Australia from 26 suppliers across 49 abattoirs and boning room sites • Twenty‑seven of the 49 sites submitted an existing social compliance audit with the following outcomes: – Three sites with previous ZT findings related to underpayment of wages and fire safety have been remediated, six sites had critical findings, ten were moderate and eight were minor issues – Following remediation efforts two sites remain critical and under active follow up, three are moderate, and 22 have been downgraded to minor. • The remaining 22 sites will be prioritised for audit in F22."

Pg 23

"This year we investigated 72 supply chain breaches or worker grievances, a decrease of 15% from last year. This decrease can be attributed to a lower amount of grievances being reported through regulators in our trolley and cleaning collection services, but a higher portion of grievances being raised through Speak Up channels for the same services. This indicates increasing awareness of our Speak Up program and less reliance on regulators by workers in operations services. We also had a decrease in audits and self-assessment questionnaires raising concerns, but an increase in ZT cases which are reported separately...