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Wesfarmers concedes, on page 7, that, "Where possible, the Group’s divisions are mapping beyond their tier one

suppliers for high-risk products. Wesfarmers recognises that mapping

suppliers beyond tier one is a complex and ongoing process; it will take

time for the Group to complete a tier two and tier three mapping exercise

for high-risk products. Increased transparency among tier two and other

suppliers is however an important mitigant to modern slavery risks." This demonstrates that Wesfarmers may not have a specific policy to combat modern slavery beyond tier one because they have not necessarily mapped their supply chain beyond tier one.

Wesfarmers also says on page 8 that all supplies are audited if non-compliance with their policy is identified. They also say that, " If the supplier is not willing or able to address

a critical breach or it is considered a ‘business critical breach’ such as

bribery or forced labour violation, the Group’s business may exercise

its rights to terminate their relationship with that supplier"

I did not check any specifics because although the report alludes to some, there is no specific mention of those protections.

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pg. 7

"POLICIES

The policies and frameworks that support the Group’s day-to-day operations require Wesfarmers and its divisions to respect and safeguard universally recognised human rights. Consistent with the principles in its Code of Conduct, Wesfarmers is committed to complying with the laws and regulations of the countries in which its businesses operate and making positive economic, social and environmental contributions, aligned with the principles of honesty, integrity, fairness and respect. The Group’s policies prohibit any activities involving modern slavery and commit to safe and healthy working conditions, including the right to freedom of association and collective bargaining. Wesfarmers is a signatory to the United Nations Global Compact (UNGC) and draws upon the key principles of the United Nations Universal Declaration of Human Rights (UDHR) and International Labour Organisation (ILO) Core Labour Standards within Group policies.

Each Wesfarmers division has developed modern slavery policies appropriate to its industry, which are updated as appropriate to seek alignment with evolving international best practice.

Each Wesfarmers division works with suppliers to source goods and services in a manner that aligns with its policies. Wesfarmers’ businesses encourage their suppliers to promote better practices and continuous improvement, require their suppliers to comply with their policies’ minimum standards and provide the Wesfarmers businesses with rights of termination if the supplier is unable or unwilling to work towards full compliance with those minimum standards. While not all these minimum standards are directly relevant to modern slavery, they reflect and are important to Wesfarmers’ holistic approach to human rights due diligence and ethical sourcing."

pg. 6

"WESFARMERS SUPPLY CHAINS

The Group’s supply chains are complex and multi-tiered. There is less visibility of the risk of modern slavery in complex, multi-tiered supply chains that span across various countries. This can limit the ability to have clear oversight of working conditions, which creates a greater risk of modern slavery issues.

A key inherent modern slavery risk identified for all the Group’s businesses is suppliers not complying with Wesfarmers’ labour standards, including dangerous health and safety practices, excessive working hours, unpaid work, below legal minimum wages, forced labour, child labour and limited or no freedom of association."

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Data copied from Wesfarmers Limited for 2021