Region : 2022 Modern Slavery Statement

1. Introduction

1. This Modern Slavery Statement (Statement) is made in accordance with Section 16 of the Australian Modern Slavery Act 2018 (Cth) (the Act). Region comprises Region Management Trust, Region Retail Trust (together, Trusts), Region RE Limited ("Region RE") and any entities owned and/or managed, either beneficially or legally, by the Trusts or Region RE ("Region") for the financial year ending 30 June 2022.
2. This Statement sets out the steps Region has taken from 1 July 2021 to 30 June 2022 to address modern slavery in its business and supply chains. This Statement has been approved by the Region Board.
3. Region firmly believes that all work should be done voluntarily and without slavery, servitude, forced or compulsory labour or the involvement of human trafficking. It takes the risk of modern slavery occurring in its business and its supply chain seriously and views relationships with its suppliers as an opportunity to encourage behaviour and practices that are consistent with its own ethical practices.

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2. FY22 Highlights

During the reporting period, Region:

1. continued to build on its organisation's purpose "Together we build thriving communities through local convenience";
2. continued to build and develop its internalised Tenancy Coordination Design and Delivery Management function to control and monitor lessor tenancy construction works, tenancy defits, modifications to base building services and tenancy hoardings;
3. reviewed its risk map of active suppliers to various risk categories in order to determine the inherent modern slavery risk in Region's Tier 11 supply chain;
4. monitored adherence to its Supplier Code of Conduct designed specifically to assist with the management of modern slavery risks;
5. developed its supplier engagement contract templates to address modern slavery risks within contractual arrangements with suppliers and service providers;
6. provided all employees with modern slavery awareness training;
7. shared its expectations of supply chain and contractor behaviour to eliminate modern slavery with all relevant suppliers; and
8. sought voluntary responses from entities beyond its Tier 1 supply chain, in particular cleaning, security and building services

contractors managed by its property management partners.

3. Overview of Region

3.1 Region's structure

Region comprises two registered managed investment schemes: Region Management Trust (ARSN 160 612 626) and Region Retail Trust (ARSN 160 612 788). The units in each Trust are stapled to form the stapled listed vehicle, Region Group. Region Group is listed on the Australian Securities Exchange (ASX) under the code "RGN". Region Group is internally managed, which allows alignment of management interests with the interests of unitholders. Region RE is the responsible entity of Region Management Trust and Region Retail Trust. Region RE is a wholly owned subsidiary of Region Management Trust.

3.2 Region's operations

1. Since listed on the ASX in 2012, Region has completed a number of acquisitions and divestments and, at 30 June 2022, owned 91 convenience-based shopping centres in Australia with a total value of $4,460.9m. At 30 June 2022, Region had a combined total of 92 Woolworths Group Limited and Coles Group Limited anchor tenants. Major anchor tenants accounted for 47% of Region's gross rent for the year ended 30 June 2022, with specialty tenants accounting for 53%.
2. Region's operations include the acquisition, management, leasing, development and disposal of retail shopping centres undertaken by an in-house team of asset, facilities, finance analyst, property, sustainability and legal professionals.
3. Region employed 86 people as at 30 June 2022, all of whom are based in Australia.

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3.3 Region's supply chain

Region relies on a large number of suppliers to execute its business activities. It quantifies the direct engagement of 31 suppliers with an annual spend of $16,342,800.00 excluding GST for the year ended 30 June 2022. Region's supply chain comprises products and services generally grouped into the following categories:

1. Property Operations - external service providers providing a range of operational services including external property management and facilities management services, tenancy delivery, property financial reporting, sustainability, cleaning, security and office equipment.
2. Corporate - external service providers providing a range of professional services including unit registry services, banking and financial services, information technology, payroll, property valuation, travel, recruitment, audit, compliance, sustainability, custodial services and specialist advice such as legal and tax.
3. Property development - external service providers providing a range of services including development management, design and construction.

4. Risks of modern slavery in Region's operations and supply chain

4.1 Operational risks

1. Region has assessed the risk that may result in it causing, contributing to or being directly linked to modern slavery. It has assessed the risk in its direct operations as low, and no instances of modern slavery have been identified. Region has a small workforce of 86

people operating exclusively in Australia. There is no direct exposure to modern slavery key risk areas.

1. Region acknowledges the following risks in relation to the management of its employees:
2. 1. deficient employee grievance mechanisms could reduce Region's opportunity to identify and remediate modern slavery risks; and
   2. inadequate modern slavery training could reduce the effectiveness of Region's policies and grievance mechanisms to manage the risk of exploitation.

4.2 Supply chain risks

1. Region considers that there will be people in its supply chain who are at higher risk of modern slavery than its direct workforce.
2. In FY22, Region completed a risk assessment of its critical and key suppliers and invited other participants in its supply chain to complete its Modern Slavery Questionnaire or alternatively provide evidence of their own Modern Slavery Statements. Drawing on guidance published by the AS ISO 20400 Sustainable Procurement Standard, suppliers were assessed against four drivers of risk:
3. 1. Location of product or service which included the consideration of the right of freedom of association, health and safety procedures, occurrence of discrimination and average living conditions.
   2. Industry sector which included the consideration of recruitment practices and the termination of employment, employment profile (reliance on low-

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skilled and/or migrant workers), living wage and existence of grievance mechanisms.

1. 1. Supplier relationship which included the consideration of the duration of the relationship, the level of oversight and the value of the contract.
   2. Existing information which included the consideration of suppliers having an ethics/whistleblower policy, existence of a code of conduct, non- compliances with policies and other factors that are indicators of modern slavery, and media or non- governmental organisation reports indicating possible problems with labour standards.
2. As part of that risk assessment, Region grouped the selected suppliers into industry sectors, and then allocated a modern slavery risk (either low or significant) by reference to the industries listed in the Social Responsibility Alliance's Global Slavery and Trafficking Risk Template which are known to have significant risk of human trafficking.
3. Suppliers identified as having a potentially significant modern slavery risk were primarily in the cleaning, security and facilities management industry sectors.