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Retail Holdings Pty Ltd MS Statement 2020

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getting to know us
Retail Holdings Pty Ltd (ABN 71 093 246 032) is the legal entity of the Sussan                        Retail Holdings Pty Ltd, known as the Sussan      We take our responsibility to manufacture
Group, a privately owned company established in Australia over 80 years                               Group has it’s main operations which include      our products ethically very seriously. Over the
ago and incorporates the businesses of Sussan Corporation (Aust) Pty Ltd                              its head office and satellite office locations;   last year, we have continued our journey of
                                                                                                      together with over 3,000 passionate team          learning where we are constantly assessing,
(ABN 79 772 682 378), Sportsgirl Pty Ltd (ABN 77 090 049 415) and Suzanne                             members we directly employ across Australia       reviewing and improving our processes
Grae Corporation Pty Ltd (ABN 11 580 943 436).                                                        in various functions including offices,           to deliver more ethical and sustainable
                                                                                                      distribution, e-com and our retail outlets. Our   products to our customers.
                                                                                                      Distribution model has its main hub located in
                                                                                                      Sydney and a support e-com DC located in          We’re proud of the employment
As a leading Australian fashion retailer, we provide quality garments and                                                                               opportunities sourcing our products
                                                                                                      Melbourne.
accessories through over 460 retail outlets within Australia and through our                                                                            provides, while recognising the realities of
                                                                                                      Our supply chain uses a sourcing model
on-line e-com platforms. Our Head Office is located in Melbourne, Victoria                                                                              manufacturing in these countries. However
                                                                                                      where approx. 90% of our products are             we do believe sourcing our products in these
and a satellite office located in Sydney, NSW.                                                        manufactured in China, through a mixture of       locations can lead to improvements in both
                                                                                                      a direct sourcing model and trading agents.       the lifestyle of the people employed by
                                                                                                      This year, we commenced expanding our             factories that produce our products, and the
This Modern Slavery Statement has been prepared as a joint statement by Retail Holdings Pty           sourcing network with production orders
Ltd after consolidation with its subsidiary companies Sussan Corporation (Aust) Pty Ltd, Sportsgirl                                                     overall economy of those countries.
                                                                                                      now placed in new sourcing markets such as
Pty Ltd and Suzanne Grae Corporation Pty Ltd                                                          Bangladesh, India and Vietnam.
identifying potential risks
Over the last year, we have       manufacturing processes          supplier or sub-contractor
worked on implementing a          and we recognise the             involved. As a result, we
pathway to full traceability of   increased risk this poses as     rely on our suppliers to
our entire supply chain across    we have no direct day to         enforce our Ethical Code
all stages of production, to      day management of the            of Conduct expectations
ensure we better understand       sub-contractor factories used    on their own supply chains
the risk of modern slavery        across our supply chain.         (sub-contractors) across all
within it. This included going                                     areas of production for Retail
                                  Suppliers also source
beyond Tier 1 in our sourcing                                      Holdings Pty Ltd products.
                                  our fabrics and product
strategy and developing a
                                  components on behalf of          Through our supply
deeper understanding of
                                  Retail Holdings Pty Ltd. Our     chain and network of
our supply chain. The risk of
                                  research shows the risk of       manufacturing factories
modern slavery can only be        modern slavery increases
fully understood when we                                           and facilities globally; we
                                  as we trace deeper into our
know our end to end supply                                         have undertaken social
                                  supply chain and as such,
chain and the different types                                      compliance audits and
                                  the risk of contributing to
of relationships and risks                                         education programs with
                                  potential cases of modern
that exist within our sourcing                                     our suppliers to ensure
                                  slavery also increases.
model at each level of                                             they understand that our
production.                       Internally, we are educating     expectations are carried
                                  our team members on how          through the suppliers entire
We recognise the Retail           their actions can contribute     supply chain for any factory
Holdings Pty Ltd sourcing         to the risk of modern slavery.   or facility involved in the
model may directly cause          We are looking at areas          manufacture of any stage of
a risk of Modern Slavery          including unrealistic delivery   our products.
through our contractual           timelines, late orders,
engagement with Suppliers         shortened critical path and      Regardless of the type
who manufacture and               changes to orders during         of relationship with our
supply products to us (on our     production, all of which are     suppliers and sub-contractors
behalf). We do not own or         actions we can control.          where we may cause,
have any financial interest in    These may contribute to the      contribute or are linked to
any supplier or factory used      risk of modern slavery where     any risk of modern slavery;
for the manufacture of our        workers may be forced            we recognise we must
products.                         to work an excessive and         provide ongoing leadership,
                                  unsafe number of hours as a      protection and support
As part of our sourcing
                                  result of our decisions.         to workers to protect their
model, we acknowledge
suppliers may subcontract         We require our supplier          rights. As such, we have
various parts of the              partners to source our raw       implemented a number of
production process through        materials. In these cases, we    strong governance practices
Retail Holdings Pty Ltd           do not have a direct link or     and expectations to mitigate
approved sub-contractors          relationship with the sub-       the modern slavery risk to
which may cause an                contractor which may also        factory workers which we
increased risk of modern          increase the risk that we are    expect suppliers and sub-
slavery. Sub-contracting          directly linked to potential     contractors across our entire
across supply chains is           cases of modern slavery          global supply chain will
a necessary function to           through the actions of the       adhere to at all times.
our steps
At the core of what we do, ensuring we           if a case of modern slavery is identified. At    We extend our expectations to protect             We value all team members in our business
have the right tools to support our factory      all times, our primary concern will be that of   workers who provide various services to our       and are committed to ensure our team
workers, Supply chain partners and internal      protecting the worker/s affected.                business through our contractor partners. We      members are always protected and
team members; has been paramount to us                                                            seek to align our business with internationally   supported at all times.
                                                 During the last year, we have undertaken a
providing clear and concise governance                                                            recognised service providers and operators
                                                 review of our entire supply chain and assessed                                                     Over the next year, we will continue to work
expectations to our suppliers and their sub-                                                      where possible who have Modern Slavery
                                                 suppliers on a number of attributes. We                                                            with both external and internal stakeholders
contractors.                                                                                      governance programs in place.
                                                 commenced building our Supplier Scorecard                                                          to grow our knowledge and further reduce
Over the last year, we have worked on            which will be used to measure suppliers across   Where we work with smaller based domestic         our risk by making more informed sourcing
creating and updating our suite of supply        a number of metrics on their performance         contractors, we have an expectation that          decisions. This approach aligns to our Group
chain governance documents including our         and ultimately, these scores will drive          they also implement measures that protect         Responsible Sourcing Policy which assists to
Group:                                           production orders with higher rated suppliers    their workers who may work in different           educate and guide our team on expected
                                                 receiving increased orders.                      areas of our business. As we move into the        purchasing behaviours.
• Ethical Code of Conduct
                                                                                                  next year, a focus for the Group will be to
                                                 We also implemented an audit incentive
• Supplier Sourcing Policies                                                                      review and implement stronger governance
                                                 for suppliers who receive higher social
                                                                                                  requirements within all Contractor and Service
• Supplier Agreement                             compliance scores in their factory audits.
                                                                                                  Providers to the Group.
                                                 Factories who receive higher scores are
• Factory Social Compliance Audit Mutual         rewarded with longer audit frequency
  Recognition Program                            timelines, meaning the reaudit window is
In addition, we have worked with external        extended. This allows us to focus more on
resources to guide us on our journey to          factories that require our attention and
improve, by assisting us to better understand    support to address corrective actions in a
all aspects of social compliance. We held        timely manner.
team member and supplier information/            Protecting our Head Office, Distribution and
education sessions and worked to implement       Retail team members from any element of
better governance controls across our supply     Modern Slavery which may arise through their
chain.                                           employment is also a key requirement of the
We conducted a thorough Modern Slavery           way we do business.
risk Assessment on our business using an         As a Group, we have implemented a range
external party. This gave us an independent      of Policies and Procedures which govern both
review on how we work with our suppliers         our internal team members and the Group’s
today while assisting to identify potential      behaviour to protect our team members from
risks to us through our Modern Slavery           any type of Modern Slavery while holding
Risk Assessment. This assessment will be         ourselves to the same expectations we have
conducted annually so we can measure our         of those in our supply chain.
improvement in preventing modern slavery in
our supply chain.                                All Group team members are encouraged
                                                 to raise any concern they have through our
We also implemented our Group Modern             Whistle-blower program to ensure grievances,
Slavery Policy across our supply chain. It       problems or complaints are resolved
details our expectations on suppliers and        confidentially and in a timely manner. If a
sub-contractors in relation to the eradication   team member raises an issue, every report
of all types of modern slavery and more          made by the team member is investigated
importantly, details the remediation steps       and if required, an external investigator may
we as a business will take with our suppliers    be appointed.
ensuring we’re on track
Assessing the effectiveness       factories. However, as soon      inspections or just a visit to
of our governance and             as factories were re-opened,     see how things are going,
supply chain controls on our      we immediately resumed           we are proud of the time we
operations and sourcing           our social compliance audit      spend visiting our factories
program, helps us measure         program and also worked          and speaking to the suppliers
and ensure the actions            with our suppliers to catch up   and factory workers face
we are taking are actually        on missed or overdue factory     to face. Sadly, during the
protecting workers against        audits.                          last year, COVID-19 has
any type of modern slavery                                         prevented overseas travel so
                                  Listening to workers is
while providing us the                                             we have been finding other
                                  important to us so during
opportunity to identify further                                    new ways to communicate
                                  these audits, worker
improvements.                                                      with our suppliers more
                                  interviews were conducted
                                                                   efficiently. We look forward
During the last year we           in private on an individual
                                                                   to once again being able to
have worked to review our         and small group basis.
                                                                   travel to our sourcing markets
existing sourcing program,        Workers identities were
                                                                   in the future.
while implementing new            protected and these
controls and measures that        responses were included          Ultimately, the best indicator
ensure our strengthened           in our audit reports and         of how our controls are
expectations are understood       reviewed internally for every    working to reduce the risk
by all those involved in          audit report completed.          of modern slavery is the
the manufacture of our            Where required, follow           actual number of modern
products. While the last year     up discussions were held         slavery cases identified.
was significantly impacted        with suppliers to ensure our     Our expectation on our
by COVID-19 which involved        expectations were adhered        supply chain is that any
temporary factory closures,       to at all times. We also         identified potential case of
we continued to focus             require factories to ensure      modern slavery is reported
on ensuring workers were          workers have a system            to the Group Ethical
treated fairly and were not
subjected to any form of
                                  to voice their concerns.
                                  We support freedom of
                                                                   Sourcing Manager and our
                                                                   remediation plan put into
                                                                                                     a group approach
modern slavery.                   association in all aspects and   place immediately. Our
                                  have an expectation that         remediation process then          During the last year, our approach to social   Conduct, Sourcing Policies, Responsible
Most factories in our
                                  all factories have a Workers     requires an independent           compliance and sourcing has been to align      Sourcing Policy, Supplier Agreement and
sourcing markets globally
                                  Representation Committee         investigation to be carried       the entire business to a Group approach        our factory audit program) and have
were at some point forced
                                  in addition to another worker    out in every case to ensure       for sourcing. We have engaged with the         commenced rewriting our supplier sourcing
to close during COVID-19
                                  grievance mechanism (such        the worker is always              greater business, discussing with each Brand
by government authorities                                                                                                                           documents such as production manuals and
                                  as a hotline, suggestion box,    protected.                        team and realigning our business to ensure
and during those times, we                                                                                                                          operating procedures.
                                  committee, open door policy                                        our approach was a unified one, with each
worked with our suppliers                                          We are committed to
                                  etc)                                                               Brand following the same guidelines and        To further assist our business operations
to ensure factory workers                                          protecting workers and
                                                                                                     expectations across our supply chain.          and supply chain, we also worked with
continued to be paid their        Visiting our suppliers and       have developed strong
monthly wages in line with        factories in the sourcing        governance requirements           We introduced a Group Sourcing team            experienced external resources to educate
the local government              markets has always been          on suppliers to ensure we         to help grow and strengthen our internal       and assist our whole team to implement the
requirements. Factory             important to us. Whether         achieve this expectation          sourcing function which involved aligning      steps we need to take towards building a
audits were suspended             it’s production discussions,     across all levels of production   each brand to our suite of Group social        world class supply chain. Ensuring we operate
as auditors could not visit       social compliance, quality       in our supply chain.              compliance documents (Ethical Code of          this way is our Group Approach.
our covid approach
The COVID-19 Pandemic has presented               continued to maintain open daily and weekly
unprecedented times across the world as we        conversations with our Suppliers, working
all navigate the challenges we are presented      pro-actively to support our mutual ongoing
with on a daily basis. We recognised that the     success. Some discussions and decisions have
COVID-19 Pandemic also increased our risk         been difficult for us all, but we continue to be
of modern slavery across our supply chain         open and transparent with our suppliers as we
so needed to ensure we played our part in         work through the challenges that arise daily.
protecting workers. We know our response
will not be perfect but we will continue to do    Further information on our COVID-19
our best to ensure our business operates in a     Response and our Group Ethical Sourcing            Approval
COVID-19 safe and friendly way to support         program can be found here:
our entire team including our suppliers and                                                          This Modern Slavery Statement has been approved after consultation with Sussan Corporation
factory workers globally.                         Sussan                                             (Aust) Pty Ltd, Sportsgirl Pty Ltd and Suzanne Grae Corporation Pty Ltd.
                                                  sussan.com.au/ethical-code-of-conduct
Supporting our suppliers and their workers has                                                       The Statement has been approved by Naomi Milgrom AC, Sole Director, Executive Chair and
been important to us. Our Suppliers are more                                                         Chief Executive Officer on 1st March, 2021.
                                                  Sportsgirl
than just our suppliers, we believe they’re our   sportsgirl.com.au/ethical-code-of-conduct
partners, some of which have supplied to
us for over 20 years. To ensure we managed        Suzannegrae
our existing and future orders to meet            suzannegrae.com.au/ethical-code-of-conduct
demand through this COVID-19 period, we
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