Modern Slavery Statement 2020 - Fonterra

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Modern Slavery Statement 2020 - Fonterra
Modern Slavery Statement
                    2020

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Modern Slavery Statement 2020 - Fonterra
Contents
Introduction                                      2
Fonterra structure, operations and supply chain   3
Reporting Entities
Our Supply Chain

Understanding our modern slavery risks            5
Key areas of risk
Impact of Covid-19 on modern slavery risks

Actions to treat and address risk                 8
Policy Framework
Governance and Risk Management
Risk mitigation activities

Assessing the effectiveness of our actions        11
Consultation and looking ahead                    12
Appendix                                          13

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Modern Slavery Statement 2020 - Fonterra
FONTERRA MODERN SLAVERY STATEMENT 2020   —   Introduction   |   Fonterra structure, operations and supply chain    |   Understanding our modern slavery risks   |   Actions to treat and address risk | Assessing the effectiveness of our actions | Consultation and looking ahead   |   Appendix

                                               At Fonterra, people matter - in our workforce, in
                                               our supply chain, and in the communities in which
                                               we operate. We believe that everyone has value
                                               and the right to be treated with respect and dignity,
                                               regardless of background or circumstances.

                                                                                                                  O    ur approach to addressing Modern Slavery is
                                                                                                                       part of our commitment to human rights.
                                                                                                                                                                               environments, good working conditions, ensuring
                                                                                                                                                                               the right to freedom of association and collective
                                                                                                                                                                               bargaining, prohibiting forced labour and child
                                                                                                                                                                                                                                          provided for workers. Furthermore, this statement
                                                                                                                                                                                                                                          also outlines how Fonterra is assessing and
                                                                                                                                                                                                                                          addressing modern slavery risks within its supply
                                                                                                                  We recognise our responsibility to respect human
                                                                                                                  rights and our ability to contribute to positive             labour (including modern slavery), and prohibiting         chains, including the efforts with supply partners
                                                                                                                  human rights outcomes. To achieve this, we are               bribery and corruption.                                    to mitigate this risk.
                                                                                                                  always working to foster a culture which supports                We also consider the potential impact of our              This statement was approved by the Fonterra
                                                                                                                  internationally recognised human rights and seeks            operations on local communities, and we require            Board of Directors on 16 March 2021.
                                                                                                                  to avoid complicity in human rights abuse.                   our supply chain to uphold human rights in their
                                                                                                                  In line with the UN Guiding Principles on Business           operations through our Supplier Sustainability
                                                                                                                  and Human Rights, Fonterra’s commitments are                 Code of Practice.
                                                                                                                  based on the International Bill of Human Rights                  The following statement sets out the actions
                                                                                                                  and the principles concerning fundamental rights             taken by Fonterra to address modern slavery and            Peter McBride, Chair
                                                                                                                  set out in the International Labour Organization             risks in our business and supply chain for the
                                                                                                                  Declaration on Fundamental Principles and                    financial year ending 31 July 2020.
                                                                                                                  Rights at Work.                                                  In this statement, Fonterra reports on its
                                                                                                                      Our commitments (embodied in our internal                actions to assess and address modern slavery
                                                                                                                  policies and standards) include seeking to provide           risks associated with its operations, including            Miles Hurrell, Chief Executive Officer
                                                                                                                  safe, secure and non-discriminatory working                  its employment practices and the protections

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Modern Slavery Statement 2020 - Fonterra
FONTERRA MODERN SLAVERY STATEMENT 2020           —     Introduction   |   Fonterra structure, operations and supply chain    |   Understanding our modern slavery risks   |   Actions to treat and address risk   |   Assessing the effectiveness of our actions | Consultation and looking ahead   |   Appendix

Fonterra Structure,
Operations and
Supply Chain
F   onterra is a global dairy nutrition Co-operative
    owned by approximately 10,000 farmers.
We’re a world-leading dairy exporter – shaping
                                                          branded dairy products sold direct to consumers,
                                                          such as milk, milk powders, yoghurt, butter and
                                                          cheese. Our three global consumer brands are
the industry in quality and innovation. We share          Anchor™, Anlene™ and Anmum™.
the goodness of dairy nutrition with the world               The milk we collect from our farmers is
through our brands, farming and processing                made into the many Fonterra dairy foods that
operations across four continents. We are one             generations of Australians have grown up with and
of the top six dairy companies in the world by            love, including Perfect Italiano, Mainland, Western               Reporting Entities:
turnover, the leading exporter of dairy products          Star, Australian Dairies and Bega.                                This 2020 Modern Slavery Statement
and are responsible for more than a third of                 These exist alongside our Farm Source brand                    covers Fonterra Co-operative Group
international dairy trade.                                which works to make farming easier by lowering                    Limited and its subsidiaries, including the
We make high-quality dairy ingredients,                   on-farm costs through the power of collective                     following Australian reporting entities:
foodservice and consumer dairy products, which            purchasing and by providing on-farm support
                                                                                                                               • Fonterra Brands (Australia) Pty Limited
are sold in more than 130 countries. Our range of         and advice.
                                                             We have more than 20,000 employees across                        • Fonterra Australia Pty Limited
dairy ingredients are sold under our NZMP™ brand
and can be found in prominent food and nutrition          28 markets, including manufacturing operations in                   • New Zealand Milk (Australasia)
brands around the world.                                  New Zealand, Australia, Indonesia, Malaysia, Chile                    Pty Limited
   Under our Anchor™ Food Professionals brand             and Brazil. Our operations encompass significant
                                                          research, development and application expertise,                  Further details of Fonterra’s subsidiaries are
we create high quality, fit-for-purpose products
                                                          customer and consumer insight and is enabled                      outlined in the 2020 Annual Report which
and solutions for foodservice professionals in over
                                                          by several supporting functions including human                   is available at Fonterra.com.
50 countries.
   We also manufacture, market and distribute our         resource, sales and marketing teams.
own consumer products. These products include

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Modern Slavery Statement 2020 - Fonterra
FONTERRA MODERN SLAVERY STATEMENT 2020           —    Introduction   |   Fonterra structure, operations and supply chain   |   Understanding our modern slavery risks   |   Actions to treat and address risk   |   Assessing the effectiveness of our actions | Consultation and looking ahead   |   Appendix

                                                                           Rest of AMENA*                              China                                       Rest of Asia Pacific                                                          United States
                                                                            REVENUE ($ MILLION)                        REVENUE ($ MILLION)                         REVENUE ($ MILLION)                                                            REVENUE ($ MILLION)
                                                                            3,322 FY19: 3,215                          5,198 FY19: 4,352                           5,881 FY19: 5,590                                                              949 FY19: 931
                                                                            EMPLOYEES (FTE):                           EMPLOYEES (FTE):                            EMPLOYEES (FTE):                                                               EMPLOYEES (FTE):
                                                                            522 FY19: 520                              1,625 FY19: 1,727                           2,066 FY19: 2,170                                                              86 FY19: 87
                                                                            MANUFACTURING SITES                        MANUFACTURING SITES                         MANUFACTURING SITES                                                            MANUFACTURING SITES
                                                                            3                                          0                                           4                                                                              0
                                                                            RAW MILK COLLECTED                         RAW MILK COLLECTED                          RAW MILK COLLECTED                                                             RAW MILK COLLECTED
                                                                            (MILLION LITRES)                           (MILLION LITRES)                            (MILLION LITRES)                                                               (MILLION LITRES)
                                                                            0                                          298 FY19: 279                               11 FY19: 13                                                                    0
Our Supply Chain                                                           * AMENA - Represents ingredients,
                                                                              foodservice and consumer
                                                                              businesses in Africa, Middle East,
As a global organisation our supply chain sources                             Europe, North Asia and Americas
                                                                              (including Latin America)
raw milk from over 10,000 farms primarily in
New Zealand, with some raw milk collection in
five other countries (Australia, Sri Lanka, Chile,
                                                                                                                                                                                                                                                   Total
Brazil and China). We also source packaging and                                                                                                                                                                                                     REVENUE ($ MILLION)
ingredients from suppliers globally. Our global                                                                                                                                                                                                     20,2821 FY19: 19,255
supply chain stretches from farms to our Fonterra                                                                                                                                                                                                   EMPLOYEES (FTE):
manufacturing facilities, as well as third-party
manufacturing sites across the globe enabling the
                                                                                                                                                                                                                                                    20,278 FY19: 20,685
delivery of products to customers and consumers                                                                                                                                                                                                     MANUFACTURING SITES
in more than 130 countries.                                                                                                                                                                                                                         47 FY19: 48
    We make a significant socio-economic                                                                                                                                                                                                            RAW MILK COLLECTED
contribution to the regions where we operate and                                                                                                                                                                                                    (MILLION LITRES)
from where we source. Our supply chain includes
suppliers who are involved in primary production
                                                                                                                                                                                                                                                    19,130 FY19: 19,547
(predominantly agriculture), processing and
distribution of raw materials, and these suppliers
recruit and employ workers associated with
undertaking these activities. We also rely on a                                       Australia                                                                                                  New Zealand                                     Latin America
number of other indirect goods and services in our                                     REVENUE ($ MILLION)                                                                                        REVENUE ($ MILLION)                             REVENUE ($ MILLION)
day to day operations, for example cleaning and
security services.
                                                                                       1,670 FY19: 1,776                                                                                          1,658 FY19: 1,676                               1,604 FY19: 1,715
    We want to ensure that our procurement                                             EMPLOYEES (FTE):                                                                                           EMPLOYEES (FTE):                                EMPLOYEES (FTE):
and other spending contributes to improving                                            1,276 FY19: 1,381                                                                                          11,757 FY19: 11,732                             2,946 FY19: 3,068
livelihoods. The range of products, sourcing                                           MANUFACTURING SITES                                                                                        MANUFACTURING SITES                             MANUFACTURING SITES
locations, markets and regulations associated with
these purchases can present risks and we apply a
                                                                                       6 FY19: 7                                                                                                  29                                              5
systematic approach to risk assessment that helps                                      RAW MILK COLLECTED                                                                                         RAW MILK COLLECTED                              RAW MILK COLLECTED
                                                                                       (MILLION LITRES)                                                                                           (MILLION LITRES)                                (MILLION LITRES)
to identify and mitigate these risks, including the
risk of modern slavery.                                                                1,383 FY19: 1,583                                                                                          16,901 FY19: 17,162                             537 FY19: 510
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Modern Slavery Statement 2020 - Fonterra
FONTERRA MODERN SLAVERY STATEMENT 2020   —   Introduction   |   Fonterra structure, operations and supply chain   |   Understanding our modern slavery risks   |   Actions to treat and address risk   |   Assessing the effectiveness of our actions | Consultation and looking ahead   |   Appendix

                                                                                                                          Understanding our
                                                                                                                          modern slavery risks
                                                                                                                                                                                                                                                   Possible forms of modern
                                                                                                                                                                                                                                                   slavery identified:
                                                                                                                                                                                                                                                     • Forced/Bonded labour
                                                                                                                                                                                                                                                     • Exploitation of migrant workers
                                                                                                                                                                               F   onterra has been undertaking a Human Rights
                                                                                                                                                                                   Due Diligence process for several years and
                                                                                                                                                                               in 2020 expanded this assessment to better
                                                                                                                                                                                                                                                     • Deceptive recruitment
                                                                                                                                                                                                                                                     • Excessive working hours
                                                                                                                                                                               understand our more salient modern slavery risks.
                                                                                                                                                                                                                                                     • Underpayment of wages
                                                                                                                                                                               We have mapped our key sources of risk against
                                                                                                                                                                               Fonterra’s operational and sourcing footprint
                                                                                                                                                                               as follows:
                                                                                                                                                                               Operational Footprint:                                         These sources of risk in our operational footprint
                                                                                                                                                                                 • Staff locations                                            have been identified primarily from the
                                                                                                                                                                                                                                              following indicators:
                                                                                                                                                                                  • Property locations
                                                                                                                                                                                                                                                 • World Bank World Governance Indicators
                                                                                                                                                                                  • Milk collection locations
                                                                                                                                                                                                                                                • Global Slavery Index (Walk Free Foundation)
                                                                                                                                                                                  • Manufacturing and own farm sites
                                                                                                                                                                                                                                                • US Department of Labour List of Goods
                                                                                                                                                                                  • Third Party Manufacturing                                     Produced by Forced Labour or Child Labour
                                                                                                                                                                                  • Merchandising                                                • Various academic and NGO reports
                                                                                                                                                                               Sourcing Footprint:                                                 (including Amnesty International, Oxfam,
                                                                                                                                                                                 • Locations of all ingredients’ vendors                           University of Auckland, International Labour
                                                                                                                                                                                                                                                   Organisation (ILO))
                                                                                                                                                                                  • Locations of top 400 vendors globally by                  In addition, we have anonymously surveyed
                                                                                                                                                                                    spend (75% of procurement spend)                          significant portions of our employee population to
                                                                                                                                                                                  • Locations of top 200 Farm Source store goods              garner their feedback on the likelihood of human
                                                                                                                                                                                    vendors by spend                                          rights risks in our value chain.

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FONTERRA MODERN SLAVERY STATEMENT 2020            —   Introduction   |   Fonterra structure, operations and supply chain    |   Understanding our modern slavery risks   |   Actions to treat and address risk   |   Assessing the effectiveness of our actions | Consultation and looking ahead   |   Appendix

                                                                                                                           Key areas of potential risk
                                                                                                                           Based on our initial assessment we have identified            consequences are specified in the Terms of Supply             failed to meet the minimum standards established
                                                                                                                           key areas of key areas of potential risk within               and include increased on-farm audit frequency,                by the Trafficking Victims Protection Act (TVPA)
Assessment of potential modern slavery risks                                                                               our operational and sourcing footprint that we                undertaking corrective actions, financial penalties,          and showed some efforts to correct this behaviour.
across Fonterra’s operational and sourcing activities                                                                      will continue to understand and report on in                  placement under performance management and                    However, trafficking in Malaysia is significantly
                                                                                                                           future statements.                                            suspension of milk collection.                                increasing without proportional actions being
                                                                                                                                                                                             Farmers who are being investigated, or subject            taken to rectify the situation.
                        Modern Slavery Risk or                                                                             On-farm workers                                               to an enforcement action by any regulator are                     Approximately 30% of PKE imports into
Fonterra footprint      Indictors of Modern Slavery           Activities                                                                                                                 required to immediately report this situation                 New Zealand are procured and distributed by
                                                                                                                           All workers have rights as employees, and it is a
Operational             •   Forced/Bonded labour            • Outsourced / contingent workforces                          crime for employers to exploit these. In Australia            to Fonterra.                                                  Agrifeeds, a joint venture between Fonterra
                        •   Exploitation of migrant workers    (cleaning and merchandising)                                and New Zealand where the majority of our milk                    Our Co-operative Difference programme                     and Wilmar International. Our 50% share in
                                                            • On Farm labour, particularly                                collection occurs these rights include holidays,              encourages farm business owners to take the Dairy             the Agrifeeds joint venture was sold to Wilmar
                        •   Bullying and Harassment
                                                               migrant workers                                             leave, work breaks, wages, freely chosen work and             NZ Workplace 360 assessment. This assessment                  International in November 2020. We have been a
                        •   Underpayment of wages                                                                                                                                        helps to identify strengths and weaknesses in                 member of the Roundtable for Sustainable Palm
                                                            • Third Party Manufacturing, and milk supply                  written employment agreements.
                        •   Excessive working hours                                                                            Within the area of modern slavery, some                   a work environment, shows opportunities for                   Oil (RSPO) since 2010, and since 2015, all of our
                                                               to Third Party Manufacturing
                                                                                                                           risks for on-farm workers include bullying                    improvement and helps monitor progress.                       palm oil purchases have been certified by the
Sourcing                •   Forced/Bonded labour            • Sourcing of garments                                        or harassment, insufficient pay (less than                                                                                  RSPO. In 2016, we launched our Palm Product
                        •   Deceptive recruitment           • Magnesium and phosphate sourcing                            minimum wage), withholding of any form of
                                                                                                                                                                                         Worker exploitation in the Palm Oil                           Standard that requires all palm product vendors
                        •   Exploitation of migrant workers • Sourcing of ingredients / packaging /                       leave or information about these entitlements,                industry (and PKE sourcing)                                   within our supply chain to publicly commit to No
                                                               finished goods from higher risk countries                   and overworking.                                                                                                            Deforestation, No Peat, No Exploitation (NDPE)
                        •   Excessive working hours                                                                                                                                      Palm products are one of the highest-profile raw
                                                               (including sugar and cocoa)                                     All farmers supplying milk to Fonterra are                                                                              and have processes to meet these commitments.
                        •   Underpayment of wages                                                                                                                                        materials in our supply chain. The production of              This standard is currently under review and we
                                                            • Palm oil and Palm Kernel Expeller                           required to comply with the Fonterra Farmers'                 palm products is often linked to unsustainable
                                                                                                                           Terms of Supply (Terms of Supply), including                                                                                expect to publish the new version in 2021. All
                                                               (PKE) sourcing                                                                                                            practices, including deforestation, habitat
                                                                                                                           compliance with the law. This requirement                                                                                   Wilmar-owned palm oil mills have achieved 100%
                                                            • Outsourced / contingent workforces                                                                                        destruction and poor human rights practices. More             traceability to plantation level, and approximately
                                                                                                                           establishes sufficient control of the conditions              specifically, the palm oil industry has been linked
                                                               (cleaning and merchandising)                                                                                                                                                            15% of their third-party supplying mills are
                                                                                                                           under which the raw milk is supplied to Fonterra.             to major human rights violations including the use
                                                                                                                           Failure to comply with the Terms of Supply has a                                                                            traceable to plantation level.
                                                                                                                                                                                         of forced labour. The 2020 Trafficking in Persons
As at 31 July 2020 we have not identified any specific                                                                     range of proportional consequences depending                  report ranked Indonesia and Malaysia as Tier 2
instances of modern slavery across our value chain to date.                                                                on the severity of the non-compliance. These                  and Tier 2 watch list countries, indicating that they

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FONTERRA MODERN SLAVERY STATEMENT 2020   —   Introduction   |   Fonterra structure, operations and supply chain   |   Understanding our modern slavery risks   |   Actions to treat and address risk   |   Assessing the effectiveness of our actions | Consultation and looking ahead   |   Appendix

                                                                                                                                                                               Impact of COVID-19 on
                                                                                                                                                                               modern slavery risks
                                                                                                                                                                               COVID-19 has significantly disrupted global                   or undergoing self-isolation. Workers who have
                                                                                                                                                                               supply chains and hence increased the risks of                lost their jobs as a result of the pandemic may
                                                                                                                                                                               exploitation of vulnerable workers. As a result,              become increasingly desperate for work, putting
                                                                                                                                                                               Fonterra has been committed to supporting our                 themselves at heightened risk of exploitation.
                                                                                                                                                                               co-operative and value chain partners to address              Supply chain shortages and reduced international
                                                                                                                                                                               new and changing modern slavery risks linked to               freight capacity have led to rapid increases in
                                                                                                                                                                               the pandemic.                                                 demand for several product categories.
                                                                                                                                                                                   COVID-19 has exacerbated the vulnerability                COVID-19’s impact on our human rights plan:
                                                                                                                                                                               of a large proportion of the global population.                  • Delayed deadline for Modern Slavery
                                                                                                                                                                               Employment is no longer certain, stringent                          Statement for 2020 financial year to
                                                                                                                                                                               measures are required to ensure the safety of                       March 2021
                                                                                                                                                                               staff at work and governmental regulations are
                                                                                                                                                                                                                                                • Many activities planned for February to
                                                                                                                                                                               constantly changing. This new environment may
                                                                                                                                                                                                                                                  July 2020 (the second half of our financial
                                                                                                                                                                               increase the risks of worker exploitation; therefore,
                                                                                                                                                                                                                                                  year) to further identify and assess modern
                                                                                                                                                                               we must assess these risks and prepare to mitigate
                                                                                                                                                                                                                                                  slavery risks (such as in person audit of our
                                                                                                                                                                               them at a global level.
                                                                                                                                                                                                                                                  international supply chain, further consultation
                                                                                                                                                                                   According to the UN, the most vulnerable
                                                                                                                                                                                                                                                  with regional businesses, development of
                                                                                                                                                                               groups are being hit hardest by the pandemic
                                                                                                                                                                                                                                                  specific risk responses) had to be deferred.
                                                                                                                                                                               – these include older persons, persons with
                                                                                                                                                                               disabilities, children, women, migrants and                      • We focused on the wellbeing and safety of our
                                                                                                                                                                               refugees. The restrictions on global travel have                   employees, milk suppliers, and maintaining
                                                                                                                                                                               affected the feasibility of site audit checks                      income for our vendors and supply for our
                                                                                                                                                                               for companies. There is an increased risk that                     customers (including providing ingredients
                                                                                                                                                                               employees may be working overtime to cover                         for medical nutrition products that support
                                                                                                                                                                               capacity gaps due to colleagues taking sick leave                  COVID-19 recovery).

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FONTERRA MODERN SLAVERY STATEMENT 2020   —   Introduction   |   Fonterra structure, operations and supply chain    |   Understanding our modern slavery risks   |   Actions to treat and address risk   |   Assessing the effectiveness of our actions | Consultation and looking ahead   |   Appendix

                                                                                                                  Actions to treat
                                                                                                                  and mitigate risks
                                                                                                                  O    ur approach to modern slavery is Co-
                                                                                                                       operative-wide. We have a robust
                                                                                                                  governance structure that oversees the
                                                                                                                                                                                Key supporting policies are available on Fonterra.com and include:

                                                                                                                                                                                Policy/Code                                                 Purpose
                                                                                                                  management of modern slavery risks across our
                                                                                                                                                                                Fonterra Global ‘The Way We Work’ Code of                   Sets out expected behaviours for our employees
                                                                                                                  own operations and our supply chain. Outlined
                                                                                                                                                                                Business Conduct                                            towards each other, our customers and the
                                                                                                                  below are the global policies, programmes and
                                                                                                                                                                                                                                            wider community.
                                                                                                                  frameworks already in place to mitigate human
                                                                                                                  rights and modern slavery risks for our people,               Fonterra Global Ethical Behaviour Policy                    Sets the ethical expectations of our employees,
                                                                                                                  and those who interact with the Co-operative.                                                                             embedding a culture of integrity, honesty
                                                                                                                                                                                                                                            and transparency.
                                                                                                                                                                                Fonterra Global Health, Safety and Wellbeing Policy Articulates our ambition to achieve zero harm for
                                                                                                                  Policy Framework                                                                                                  our people, including contractors and visitors to
                                                                                                                  Respect for human rights is embedded in our                                                                       our sites.”
                                                                                                                  “Our People” Group Policy, and expectations
                                                                                                                                                                                Fonterra Supplier Sustainability Code of Practice           Sets out our expectations for suppliers to align
                                                                                                                  are articulated throughout our people standards,
                                                                                                                                                                                                                                            with our values and codes of conduct, including
                                                                                                                  and our code of conduct, “The Way We Work”.
                                                                                                                                                                                                                                            upholding human rights, fair working conditions and
                                                                                                                  The Managing Director Co-operative Affairs is
                                                                                                                                                                                                                                            specifically excluding forced labour and child labour
                                                                                                                  responsible for the governance of human rights
                                                                                                                  within our business and our sphere of influence.
                                                                                                                  To ensure clarity on the issue of labour standards
                                                                                                                  and to protect universally recognised human rights,
                                                                                                                  there are several key policies that set out the
                                                                                                                  requirements of those within the organisation and
                                                                                                                  those whom we seek to do business with.

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FONTERRA MODERN SLAVERY STATEMENT 2020              —   Introduction   |   Fonterra structure, operations and supply chain    |   Understanding our modern slavery risks   |   Actions to treat and address risk        |   Assessing the effectiveness of our actions | Consultation and looking ahead                 |    Appendix

International Union of Food                                explains our expectations of our suppliers , and                    • Freedom of association - Suppliers shall
                                                           every supplier who signs our standard terms                           respect the right of employees to be
(IUF) Obligations                                          of purchase must endeavour to align their                             represented by trade unions and other                                                                                                               FONTERRA BOARD

                                                                                                                                                                                             3RD LINE OF DEFENCE
In 2002, Fonterra, the IUF and the NZ Dairy                behaviour and business practices (and those                           bona fide representatives of employees and
Workers’ Union (NZDWU) signed an agreement                 of their subcontractors) with the principles                          engage in constructive negotiations with
to ensure minimum labour standards for all                 contained in the Code . The Code sets out a range                     such representatives with a view to reaching                                                                                Audit & Finance                                       Safety & Risk
                                                                                                                                                                                                                   INTERNAL ASSURANCE
employees of Fonterra and its subsidiaries, in NZ          of expectations across social, economic and                           agreements on employment conditions.                                                                                          Committee                                            Committee
and around the world.                                      environmental areas. Our suppliers must commit
                                                                                                                                                                                                                                                                                          Fonterra
Minimum Labour Standards (ILO Conventions):                to complying with Code requirements, which are
   • Freedom of Association and Protection of the          drawn from the International Labour Organisation                  Governance and                                                                                                                                           Management Team

     Right to Organise Convention, 1948 (No. 87)           (ILO) and Ethical Trading Initiative (ETI). These are             Risk Management
                                                           minimum standards based on the principles of the
  • Right to Organise and Collective Bargaining
                                                           United Nations Universal Declaration of Human
    Convention, 1949 (No. 98)
                                                           Rights. Fonterra expects suppliers/contractors to
                                                                                                                             Fonterra's sustainability governance
  • Workers’ Representatives Convention, 1971              express their preparedness and intent to comply                   The Fonterra Board has ultimate overall

                                                                                                                                                                                             2ND LINE OF DEFENCE
                                                                                                                                                                                                                                                                                                IT
    (No. 135)                                              with the Code and to ask their subsidiaries and                   responsibility for Fonterra’s sustainability                                                                                          Finance                                          Legal

                                                           suppliers to comply as well.                                      performance, including our supplier strategy and
  • Forced Labour Convention, 1930 (No. 29)                                                                                  issues relating to the risk of modern slavery in our                                                                             Supply Chain                                         Health & Safety
                                                               The Sustainability Code of Practice is included                                                                                                                                                                           GROUP RISK
  • Abolition of Forced Labour Convention, 1957            in all new contracts and in the standard template                 operations and supply chain. Responsibility for the
                                                                                                                                                                                                                                                               Environment                                         Milk Supply
    (No. 105)                                              when contracts are up for renewal, ensuring that                  strategy and its integration into our day-to-day
                                                           every supplier regardless of size is required to                  activities is shared across the organisation.                                                                                                   People & Culture        Food Safety
  • Minimum Age Convention, 1973 (No. 138)
                                                           adhere to the Code.
  • Worst Forms of Child Labour Convention,                    The Code explicitly expects suppliers to support              Fonterra’s approach to
    1999 (No. 182)                                         the following ethical standards set out in the Code               Risk Management
  • Equal Remuneration Convention, 1951                    of Practice related to modern slavery:                            Fonterra’s Global Risk Management Policy outlines
    (No. 100)                                                 • Freely chosen employment - Suppliers shall                   our risk principles and accountabilities, setting out

                                                                                                                                                                                             1ST LINE OF DEFENCE
  • Discrimination (Employment and Occupation)                   not make use of forced or bonded labour.                    the requirements for managing and reporting risk                                                                                                              Greater
                                                                                                                                                                                                                                                                  APAC                                               AMENA
    Convention, 1958 (No. 111)                                   Labour should be freely given, and employees                across our global business aligned to the ISO31000                                                                                                             China

                                                                 should be free to leave in accordance with                  Risk Management – Principles & Guidelines 2018.
Supplier Code of Practice                                        established rules.                                          It is designed to embed a co-operative-wide risk
                                                                                                                                                                                                                                                                                         Co-operative
                                                             • Child labour - Suppliers shall not employ                     management capability, establishing a consistent                                                                                     COO                                                 oCFO
We recognise that identifying and addressing                                                                                                                                                                                                                                                Affairs
                                                               children in violation of conventions 138 and                  approach to identifying, assessing, controlling,
modern slavery risks in our supply chain requires
                                                               182 of the International Labour Organization.                 monitoring and reporting on our key risks. These
collaboration with our suppliers. Our supplier
                                                                                                                             include risks that may affect our Co-operative’s
Sustainability Code of Practice (the “Code”)

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FONTERRA MODERN SLAVERY STATEMENT 2020            —     Introduction   |   Fonterra structure, operations and supply chain    |   Understanding our modern slavery risks   |   Actions to treat and address risk   |   Assessing the effectiveness of our actions | Consultation and looking ahead   |   Appendix

ability to achieve its objectives and protect our          Risk mitigation activities                                        We expanded our assessment approach in FY20 to                and our customers independent assessments of                  5. Social procurement
people, shareholders, customers and reputation.                                                                              consider products and geographies most at risk of             our performance. Independent audits against                   In May 2019, Fonterra signed up to be one of 12
Our risk management framework is based on the                                                                                modern slavery, though COVID-19 has impacted                  the Sedex Member Ethical Trade Audit (SMETA)
                                                           1. Human Rights Due Diligence                                                                                                                                                                 founding “buyer members” in New Zealand’s first
three lines of defence model. Fonterra’s first line                                                                          some of the more detailed regional analysis we                for labour practices, environment, health and                 Social Procurement Programme. In conjunction
of defence is our people. Managers and individual          Human Rights ‘due diligence’ is a process to                      were planning. In our non-milk supply chain, we               safety and business practices are undertaken for
                                                           identify and prioritise actual and potential human                                                                                                                                            with regional and local government, Ākina created
business units hold clear risk management                                                                                    have focused in a deeper assessment of human                  the majority of our New Zealand based sites. We               the ‘Fwd:platform’ -a marketplace website that
responsibilities for business risk management,             rights issues in an organisation’s direct and indirect            rights performance with our top 26 suppliers by               have also achieved a gold rating in our annual
                                                           sphere of influence. Fonterra has been undertaking                                                                                                                                            connects buyer members with Ākina certified social
including requirements to ensure compliance                                                                                  value. Within our Australian Farm Source business,            EcoVadis assessment.                                          enterprises that are trading to deliver positive social
with external requirements as well as Fonterra’s           a Human Rights Due Diligence process (following                   we conducted an assessment to understand
                                                           the guidance of the UN Guiding Principles on                                                                                    3. Staff training and development                             and environmental impact. This year, we hosted a
Global Policy standards. Our risk management                                                                                 the likelihood of farm work exploitation risks                                                                              meeting with other like-minded organisations to
and assurance processes support this via our               Business and Human Rights) for several years.                     in Fonterra farm suppliers. The key risks were                Buyers within our procurement teams play a critical
                                                               In 2017, our workforce evaluation across New                                                                                                                                              support increased understanding and identification
group functions, ensuring a consistent best-                                                                                 identified and response plans are being developed.            role in assessing and managing the sustainability
                                                           Zealand, Australia, Brazil and Chile, covering                                                                                                                                                of opportunities across categories.
practice approach to risk management across the                                                                                                                                            performance of our vendors. In FY19 we ran
                                                           approximately three-quarters of our employees,                    2. Independent evaluation and                                 company-specific training on sustainability,
business, aligned with our risk appetite settings.
                                                           identified some concerns about bullying and                       certification of sites
                                                                                                                                                                                                                                                         Reporting and monitoring of
These processes are overseen by the Fonterra                                                                                                                                               including social and environmental issues faced
Management Team alongside a dedicated internal             harassment, long working hours and the potential                  Our manufacturing sites are subject to regular                in our supply chain with 77% of our Group                     grievance mechanisms
audit function, taking a risk-based approach to            for human rights risks in our non-milk supply                     internal and third-party audits. Internal audits              Procurement team in attendance. This specifically             We are committed to providing our teams access to
oversight of key business activities and reporting to      chain. This year we have been responding to                       are conducted by staff independent of the site                included training on human rights risks to assist             effective remedies aligned with our commitment to
the Board via the relevant Board committees.               these concerns within our workforce, and in our                   and are used to identify areas for improvement.               with our preparation to report on Modern Slavery.             the United Nations Guiding Principles on Business
                                                           supply chain.                                                     Third-party audits give regulatory authorities                                                                              and Human Rights.
                                                                                                                                                                                           4. Vendor assessments                                            Fonterra has a ‘The Way We Work Hotline’,
                                                                                                                                                                                           Assessing and managing the risk of environmental              which is an independently administered,
                                                                                                                                                                                           and social issues within our supply chain is a core           confidential service and has been designed
                                                                                                                                                                                           part of responsible procurement. We have assessed             specifically for reporting issues like theft, fraud,
                                                                                                                                                                                           our top 400 non-milk suppliers globally (accounting           corruption, harassment, misconduct or other
                                                                                                                                                                                           for 75% of spend) and we extended the coverage                unethical behaviour. The Hotline is available to
                                                                                                                                                                                           of this assessment to also cover our Farm Source              anyone working for or on behalf of Fonterra, and
                                                                                                                                                                                           Retail business. For Farm Source retail, over 200             can be accessed 24/7 via telephone, website
                                                                                                                                                                                           vendors were assessed for human rights and                    or e-mail, and different language versions
                                                                                                                                                                                           environmental risk, specifically investigating                are available.
                                                                                                                                                                                           country of origin of goods and including the top
                                                                                                                                                                                           45 vendors by spend.

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FONTERRA MODERN SLAVERY STATEMENT 2020           —   Introduction   |   Fonterra structure, operations and supply chain   |   Understanding our modern slavery risks   |   Actions to treat and address risk   |   Assessing the effectiveness of our actions | Consultation and looking ahead   |   Appendix

                                                        Assessing the effectiveness of
                                                        our actions

F    onterra does not currently have any key
     risk indicators specific to modern slavery
as we have only just started assessing the full
risk of modern slavery. We regularly review and
assess the effectiveness of policies, codes and
frameworks as part of our risk management
framework. We will continue to develop and
modify our approach as we formally identify
our risks and implement mitigation measures.
This will include developing metrics that enable
us to track the progress and effectiveness of
our actions over time, as we look to continually        In 2020 we continued to be active members
improve. The impacts of COVID-19 have delayed           of several multi-stakeholder initiatives that are
the development of metrics; however, we are             engaged in the protection and promotion of human
looking to develop these over 2021 and 2022.            rights and the elimination of forced labour. These
Quantifiable metrics might include measuring            include, the Roundtable on Sustainable Palm Oil
access to collective bargaining across our supply       (RSPO) and the International Union of Food (IUF).
chain, and grievance mechanisms in place and            Our membership to these and other organisations
being used.                                             allow us to assess our progress against industry
We understand that raising awareness is                 best practice, work in collaboration across
key in addressing the risk of modern slavery.           industries, and helps to identify areas for
We recognise the need to continue building              further improvement.
capacity among our employees to identify risks
of modern slavery and the actions required to
respond effectively.

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FONTERRA MODERN SLAVERY STATEMENT 2020   —   Introduction   |   Fonterra structure, operations and supply chain   |   Understanding our modern slavery risks   |   Actions to treat and address risk   |   Assessing the effectiveness of our actions | Consultation and looking ahead   |   Appendix

                                                                                                                                                                         Consultation and
                                                                                                                                                                         looking ahead

                                                                                                                                                                         A     ll Fonterra entities operate under a common
                                                                                                                                                                               set of governance policies and programmes.
                                                                                                                                                                         This includes the programmes through which
                                                                                                                                                                                                                                        Fonterra is in the early stages of our Modern
                                                                                                                                                                                                                                        Slavery journey, and we are committed to further
                                                                                                                                                                                                                                        developing and refining our programme as we learn
                                                                                                                                                                         modern slavery risks in both our operations and                more about our risks and are looking to continually
                                                                                                                                                                         supply chains are assessed and addressed by                    improve over time.
                                                                                                                                                                         Fonterra. A process of consultation across Fonterra            Our focus for the next few years will include:
                                                                                                                                                                         and some of our reporting entities was undertaken                • Deeper consultation across the business on
                                                                                                                                                                         during the Human Rights due diligence process                       material risks
                                                                                                                                                                         which contributed to the identification on salient
                                                                                                                                                                         modern slavery risks, and to help with the drafting               • Development of action plans to address
                                                                                                                                                                         of this statement. This included engagement                         salient and material risks
                                                                                                                                                                         with procurement, food safety and quality, third-                 • Implementation of an external grievance
                                                                                                                                                                         party manufacturing and our Farm Source teams.                      mechanism process
                                                                                                                                                                         We will look to expand this as we continue our
                                                                                                                                                                                                                                           • Development of metrics to measure and
                                                                                                                                                                         Modern Slavery journey.
                                                                                                                                                                                                                                             monitor the effectiveness of actions

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FONTERRA MODERN SLAVERY STATEMENT 2020   —   Introduction   |   Fonterra structure, operations and supply chain    |   Understanding our modern slavery risks   |   Actions to treat and address risk |   Assessing the effectiveness of our actions | Consultation and looking ahead |   Appendix

Appendix one

                                                T   his statement was prepared to meet
                                                    our Australian regulatory disclosure
                                                requirements. It complements our existing
                                                sustainability disclosure on the Fonterra
                                                website and in our sustainability and,
                                                annual and interim reports. The table to
                                                the right references where the mandatory                          Mandatory criteria                                         Location of information
                                                criteria are disclosed for the Australian                         Identify the reporting entity                              Reporting entities (page 3)
                                                Modern Slavery Act 2018 and where more                                                                                       Fonterra 2020 Annual Report (page 136)
                                                information is located in our Annual and
                                                Sustainability Reports.                                           Describe the reporting entity’s structure,                 Fonterra structure, operations and supply chain
                                                                                                                  operations and supply chains                               (pages 3 – 4)
                                                                                                                  Describe the risks of modern slavery practices in          Understanding our modern slavery risks (pages 5 – 6)
                                                                                                                  the operations and supply chains of the reporting          Impact of COVID-19 on modern slavery risks (page 7)
                                                                                                                  entity and any entities it owns or controls
                                                                                                                  Describe the actions taken by the reporting                Actions to treat and address risks (pages 8 – 11)
                                                                                                                  entity and any entities it owns or controls to assess      Fonterra 2020 Annual Report (pages 171 – 174)
                                                                                                                  and address these risks, including due diligence           Fonterra 2020 Sustainability Report (pages 54 and
                                                                                                                  and remediation                                            68 – 69)
                                                                                                                  Describe how the reporting entity assesses the             Assessing the effectiveness of our actions (page 11)
                                                                                                                  effectiveness of these actions
                                                                                                                  Describe the process of consultation with any              Consultation and looking ahead (page 12)
                                                                                                                  entities the reporting entity owns or controls

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