M O D E R N S L AV E R Y S TAT E M E N T
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CONTENTS
INTRODUCTION
MYER IS COMMITTED TO ETHICAL, SUSTAINABLE AND SOCIALLY RESPONSIBLE PROCUREMENT AND BUSINESS PRACTICES, WHICH INCLUDES MANAGEMENT OF MODERN SLAVERY RISKS AND PROTECTION OF EMPLOYEES AND WORKERS WITHIN OUR OPERATIONS AND SUPPLY CHAIN.
1 | 2 | 3 | 6 | |||
INTRODUCTION | ROADMAP | OUR BUSINESS & | OUR MODERN | |||
SNAPSHOT | SUPPLY CHAIN | SLAVERY RISKS | ||||
8 | 14 | 15 | 15 | |||
MEASURING | MODERN SLAVERY | |||||
DUE DILIGENCE | CONSULTATION | ACT REPORTING | ||||
EFFECTIVENESS | ||||||
CRITERIA | ||||||
As one of Australia's largest retailer groups, we have a longstanding history of fostering ongoing relationships with suppliers in order to provide compelling value to our valued customers and
to ensure that we work together to address the challenges associated with safeguarding human rights.
This is Myer's second Modern Slavery Statement, which highlights the progress made against our three-year roadmap outlined in our first Statement in 2021. Following the publication of our first statement last year, we have continued to strengthen our knowledge of possible modern slavery risks within our complex supply chain and enhanced our Ethical Sourcing Program to assess and address risks identified.
Some of the key progress highlights include:
- Increasing our understanding of modern slavery risks across our operations
- Continued to risk assess labour and service providers in our operations to strengthen controls and embedding considerations of modern slavery risks in our processes
- Supplier self-assessment questionnaire sent to high risk suppliers, and forms part of supplier engagement process
- 423 factory audits assessed against ethical trade criteria's
- Introduced supplementary grievance mechanism for workers
- Expanded and delivered bespoke training to employees
- Updated supplier code of conduct to reinforce our position on human rights
- Enhanced traceability and transparency program
- Expanded social compliance audit program scope
- Partnering with industry peers to align best practice
Modern slavery is a severe violation of human rights and relates to situations where a person is coerced into work and exploited for personal or commercial gain. It also includes conduct that undermines a workers right to freedom and includes offences such as forced labour, child labour, servitude, debt bondage and deceptive recruitment.
This statement has been prepared for Myer Holdings Limited, in accordance with the Australian Modern Slavery Act 2018 (the Modern Slavery Act), and covers reporting entities Myer Pty Limited, sass & bide Pty Limited, and Marcs David Lawrence Pty Limited. The statement describes the risks of modern slavery in our own operations and our supply chain during the period 26 July 2020 to 31 July 2021 (reporting period or 2021). It also details the steps taken by Myer to minimise the risks of modern slavery and its effectiveness of these actions. This Statement has been reviewed and approved by the Directors of the Myer Holdings Limited Board.
Myer Holdings Limited (ABN 14 119 085 602) is listed on the Australian Stock Exchange (ASX: MYR), registered at 1000 La Trobe Street Docklands Vic 3008. This Statement is prepared for Myer Holdings Limited covering Myer Pty Limited, sass & bide Pty Limited, and Marcs David Lawrence Pty Limited during year ending 31 July 2021. References to "Myer, we, our or us" in this Statement refers to Myer Holdings Limited
2021 Statement Slavery Modern
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ROADMAP SNAPSHOT
WE HAVE A THREE YEAR ROADMAP THAT FOCUSSES ON CONTINUOUS IMPROVEMENT OF OUR ETHICAL SOURCING FRAMEWORK AND INCLUDES ACTIONS TO IMPROVE AND EFFECTIVELY MANAGE OUR RISK AND SUPPLY CHAIN MANAGEMENT, MONITORING, COMMUNICATION AND TRAINING. THE ROADMAP CONTINUES TO GUIDE OUR MODERN SLAVERY RISK MANAGEMENT ACTIONS.
OUR BUSINESS & SUPPLY CHAIN
MYER IS ONE OF AUSTRALIA'S LEADING RETAILERS OFFERING PRODUCTS
ACROSS WOMENS, MENS AND KIDS FASHION, BEAUTY, HOMEWARES, ELECTRICAL GOODS, TOYS AND GENERAL MERCHANDISE THROUGH OUR STORE NETWORK AND ONLINE STORE.
FY20
ENHANCE FRAMEWORK
• Update policies and procedures |
• Risk assessment, mapping of |
supply chain and gap analysis |
• Engage with high priority tier one |
suppliers |
• Refresh employee training |
FY21
MONITOR & ENGAGE
• Monitor targets and KPIs |
• Update due diligence program |
to ensure that it addresses key |
salient modern slavery risks and |
is fit for purpose |
• Continue to engage tier one |
FY22
REVIEW & ASSURANCE
• | Validate framework |
• Risk based assessment of second | |
tier and beyond | |
• | Explore more effective |
mechanisms for addressing | |
modern slavery risks |
AUSTRALIA BASED | OVERSEAS BASED | TOTAL DIRECTLY | COUNTRIES | |||
SOURCED | DIRECTLY | |||||
EMPLOYEES | EMPLOYEES | |||||
SUPPLIERS | SOURCED FROM | |||||
9,000+ | 49 | 284 | 15 | |||
• | Strengthen supplier contracts |
with additional clauses on | |
compliance with Modern Slavery | |
Act | |
• | Supplier questionnaire |
suppliers | |
• | Strengthen worker engagement |
and training | |
• | Engage and collaborate with |
industry and peer groups |
• Review options to move |
beyond audits and build worker |
engagement program |
• Communicate Ethical Sourcing |
Program and modern slavery |
initiatives to customers |
Our workforce consists of over 9,000 Australian based employees across our support office, warehouses and retail stores; as well as contractors and agents engaged either by contractor or under award agreements.
Our retail store network encompasses 60 Myer department stores1, 41 sass
- bide stores2, 83 Marcs stores2 and 80 David Lawrence stores3 across Australia and New Zealand, and is supported by our Support Office team based in Docklands, Victoria. We have
a small sourcing office in Hong Kong which employs 49 employees across locations in China, Hong Kong, and a small number in India and Bangladesh for the purpose of quality control and assurance.
RETAIL STORE NETWORK
Queensland
13 9 17 16
Western Australia
6 5 12 10
South Australia | ||||||||||
3 | 2 | 5 | 5 | |||||||
Victoria | ||||||||||
14 | 10 | 19 | 16 |
New South Wales
20 12 25 27
Australian Capital Territory
2 1 3 4
2021 Statement Slavery Modern
LEGEND | ||||||||
Myer Pty Ltd | ||||||||
Tasmania | ||||||||
Sass & bide | ||||||||
Marcs | 2 | 0 | 2 | 2 | ||||
David Lawrence | ||||||||
- includes Knox City store closed during the reporting period
- comprises of standalone and department store formats
- In department store formats
New Zealand
0 2 0 0
2021 Statement Slavery Modern
2 | 3 |
OUR BUSINESS
- SUPPLY CHAIN (CONTINUED)
Our approach to modern slavery is company-wide, with a governance structure overseeing the management of modern slavery risks. The Myer code of conduct outlines the expectations of all employees, including company directors. The code requires awareness of, and compliance with, laws and regulations relevant to Myer's operations, including occupational health and safety and employment practices. The Myer Ethical Sourcing
Program focuses on the identification, assessment and mitigation of modern slavery risks. Each employee of Myer has a responsibility to ensure compliance with our Ethical Sourcing Program with oversight by the Audit, Finance and Risk Committee of the Board.
The Myer Board is accountable for and approves the Myer Ethical Sourcing Policy and framework, and through the Audit, Finance and Risk Committee
of the Board, reviews and monitors effectiveness of ethical sourcing risk processes, activities and initiatives. The Executive Management team is responsible for the execution of the policy and framework in their area of responsibility. The Assurance team, reporting to the Chief Financial Officer, is responsible for the development, implementation and management of the broader Ethical Sourcing Program, including modern slavery initiatives.
OUR SUPPLY CHAIN | that goods are manufactured, and | of workers in our supply chain. We work | ||||||||||
Our supply chain network is extensive, | accordingly rely upon long-term | collaboratively with our suppliers to | ||||||||||
relationships we have developed | ensure ethical sourcing requirements | |||||||||||
interconnected and complex with | ||||||||||||
with our suppliers over many years | and milestones are met and continually | |||||||||||
global tiered supplier networks. We | ||||||||||||
together with our due diligence | improved upon. | |||||||||||
do not own or operate any factories | ||||||||||||
processes to ensure the safeguarding | ||||||||||||
EXAMPLE OF A COMPLEX SUPPLY CHAIN | ||||||||||||
UPSTREAM (Inputs and materials needed for production) | DOWNSTREAM (final or finished goods) | |||||||||||
Tier three | Tier two | Tier one | Distribution centre | Retailer | ||||||||
Raw Materials 1 | ||||||||||||
Inputs | Manufacturing 1 | |||||||||||
MYER BOARD
Responsible for overseeing the performance and operations, including setting the values and monitoring of compliance with
Myer's code of conduct and ethical standards. Approves annual Modern Slavery Statement
BOARD COMMITTEES
Audit, Finance and Risk Committee | Human Resources and | Nomination Committee |
Risk management and financial | Remuneration Committee | Nomination criteria's, succession and |
reporting, includes reviewing Modern | Remuneration framework and people | Board appointments |
Slavery Statement and recommending to | and culture initiatives and schemes | |
Board for approval |
Policies and Procedures
Includes Code of Conduct, Ethical Sourcing Framework, Risk Management Framework, Whistleblower
EXECUTIVE MANAGEMENT TEAM REPORTING TO CHIEF EXECUTIVE OFFICER | ||
Modern | ||
BUSINESS AND FUNCTIONAL UNITS | ||
Slavery | ||
Statement | ASSURANCE TEAM | |
2021 | Oversees and responsible for the development, embedding and management of the Ethical Sourcing Program within business | |
including modern slavery initiatives, and the company's whistleblower program | ||
Raw Materials 2 | Supplier 1 | RDC 1 | |
Manufacturing 2 | |||
Retailer 1 | |||
Raw Materials 3 | |||
RDC 2 | |||
Retailer 2 | |||
Raw Materials 4 | RDC 3 | ||
Manufacturing 3 | Retailer 3 | ||
Inputs | RDC 4 | ||
Raw Materials 5 | |||
Supplier 2 | |||
Manufacturing 4 | |||
Raw Materials 6 | RDC = Regional | ||
Distribution Centre |
Our supply chain operation is categorised as follows: | |||
MERCHANDISE SUPPLIERS | NON-MERCHANDISE | ||
Private brand supplier | SUPPLIERS | ||
Myer owned brands manufactured under a Myer owned trade mark | Goods and services not for resale | ||
to customers, engaged to support | |||
National Brand supplier | our operations such as packaging | ||
Branded suppliers with local and/or international proprietary rights for resale by | materials, stationery, transportation, | ||
visual merchandise equipment, | |||
Myer where trademark is not owned by Myer | |||
marketing, security, cleaning and | |||
Brand Partner supplier | professional services. | Modern | |
Licensed suppliers selling branded product owned by the licensed business, | Non-merchandise suppliers are | ||
operating a store-in-store business within Myer stores | typically found in industries such | Slavery | |
Whilst we do not own or control National Brand and Brand Partner suppliers, | as cleaning, security and transport | ||
which these industries are generally | |||
they are contractually obligated to follow Myer protocol including modern slavery | Statement | ||
considered at high risk of modern | |||
and may be required to report under Modern Slavery Legislation. To increase | |||
slavery and exploitation, and likely | |||
our visibility of our supply chain, reviews of the management processes of key | |||
to be migrant workers | |||
suppliers through their Modern Statement is undertaken to assist in identifying | 2021 | ||
possible areas of risks that may have not been recognised | |||
4 | 5 |
OUR MODERN SLAVERY RISKS
MYER'S MODERN SLAVERY PROGRAM UTILISES
A RISK BASED AND CROSS-DEPARTMENTAL MODEL.
Our operations and supply chains are complex and potentially exposed to human rights risks. We continue to monitor our risk through ongoing assessments including third
party audits and advice, supplier questionnaire, grievances raised, industry trends, media reports and collaboration with our suppliers.
Our internal business units and departments continually monitor relevant risks in order to maintain a risk
suppliers to ensure the risk profile is maintained or reduced.
Ongoing risk assessments allow us to better understand areas of focus and priorities. These assessments consider the relevant changes both internally and externally, accounting for the nature of the relationship with the supplier and its network, the type and spend of goods or services, the geographic location, the level of human rights protection and vulnerability, and
of controls. In the reporting period, we did not have any instances of modern slavery within our operations or supply chain reported.
All countries in which private brand manufacturing takes place have undergone a risk assessment and been approved by our risk framework. No new sourcing country or supplier can be on boarded without a prior risk assessment completed. This country risk profile is based on a number of
PRIVATE BRAND SUPPLIERS
Myer currently engages 284 private brand textile and manufacturing suppliers in over 400 factories across 15 sourcing countries. Private Brand suppliers are suppliers that present the greatest risk as the product is manufactured directly for Myer, providing increased leverage and influence to identify and remediate
non-conformances. During the reporting period, our supplier base was consolidated to a smaller number of countries and suppliers in order to provide greater influence and importance of each of our suppliers and their factories. This also includes ensuring that Myer's requirements are met and assured throughout their operations, fostering a better relationship with final production
suppliers and allowing for greater information shared with regard to mills and raw materials. We are committed to continuously improving the transparency of our tier one Private Brand suppliers, as we recognise this is an important component of our ethical sourcing program.
Products were sourced from
15 countries, with our concentration of tier one sourcing locations as below
profile, prioritise efforts and to validate existing controls. Our buying, ethical sourcing and procurement teams work closely to monitor new and existing
the ongoing monitoring of reputable media reports. It also reviews possible modern slavery risks and general human right issues, and assesses the adequacy
social and economic indicators such as ILO Rights and Protection Index, OECD, Corruption Index etc.
TIER ONE SOURCING LOCATIONS
Our risk assessment identified the key risks to our operations and supply chain, and areas of focus
Forced labour
There is a risk that forced labour could exist in our extended supply chain in manufacturing | |||
and raw materials | |||
Child labour | |||
Where a child is exploited for personal or commercial gain, and exposed and required | |||
to work in hazardous conditions or the work is harmful to the child's physical and mental | |||
development. | |||
There is a risk that child labour could exist in our extended supply chain in manufacturing, | |||
inputs production and raw materials | |||
Bonded labour | |||
Where a person is required to pay debts (such as recruitment fees) to their employer or | |||
recruiter. Workers are often bound to the employer until the debt has been paid and in most | |||
instances such debts are extremely difficult to pay off. | |||
There is a risk that bonded labour could exist where subcontracting occurs or in areas where | |||
low skilled or migrant workers are employed. Migrant workers are generally at higher risk of | |||
Modern | exploitation due to lack of knowledge of local laws, reluctance to raise concerns or questions | ||
for fear of losing their job or facing deportation and possible better conditions compared to | |||
their home country or area | |||
Slavery | |||
Deceptive recruitment | |||
Where a person is enticed to work using false or deceptive practices about the details and | |||
Statement | working condition of a job, and is later left in a vulnerable position once employment has | ||
commenced. | |||
There is a risk that deceptive recruitment could occur where third parties use to recruit | |||
2021 | |||
workers, particularly vulnerable workers such as migrant workers, undocumented workers or | |||
workers from areas with high unemployment or poverty | |||
TOP 4 COUNTRIES (BASED ON SPEND) | |||
CHINA | INDIA | BANGLADESH | VIETNAM |
80.3% of purchases | 9.5 % of purchases | 3.8% of purchases | 3.5% of purchases |
Active factories - 327 | Active factories: 52 | Active factories: 9 | Active factories: 8 |
Key merchandise - Apparel | Key merchandise - Apparel | Key merchandise - Apparel | Key merchandise - Apparel |
Whilst we have a clear understanding of the final stage of our production, currently audits are not common for raw materials and inputs suppliers. In such instance, we utilise the supplier questionnaire and through discussions seek to understand their operations and processes. Contractual arrangements are generally between final stage production and Myer. Additional diligence and validation processes are consistently being explored to ensure transparency and supply chain is free from modern slavery.
2021 Statement Slavery Modern
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Myer Holdings Limited published this content on 28 January 2022 and is solely responsible for the information contained therein. Distributed by Public, unedited and unaltered, on 31 January 2022 10:18:04 UTC.