PUBLIC INTEREST ASSESSMENT - Department of Racing, Gaming and Liquor
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DOC 4 ALDI FOODS PTY LIMITED applicant for the conditional grant of a liquor store licence ALDI WARWICK GROVE Warwick Grove Shopping Centre, corner Beach Road and Erindale Road, Warwick PUBLIC INTEREST ASSESSMENT Prepared by Lavan on behalf of ALDI Foods Pty Limited Ref: Jessica Patterson jessica.patterson@lavan.com.au T: (08) 9288 6946 www.lavan.com.au © Lavan 2019
Public Interest Assessment
ALDI Warwick Grove
Table of Contents
1 Introduction 2
2 Overview of proposal 3
Consultation 7
Community demand 8
3 Applicant’s details and background 10
ALDI supermarkets 16
ALDI pricing and promotion 18
4 ALDI liquor model 20
The premises 21
Stock range 23
ALDI Exclusive Products 24
Low risk features of the proposal 27
5 Locality 28
Nature and character of local community 30
Warwick Grove Shopping Centre 32
6 Section 5 34
7 Harm or ill-health – section 38(4)(a) 34
“At risk” groups and sub-communities 34
Social health indicators 39
Minimising harm and ill-health 42
8 Impact on amenity, quiet and good order – section 38(4)(b) 49
Outlet density 50
9 Offence, annoyance, disturbance or inconvenience – section 38(4)(c) 57
10 Tourism, community or cultural matters – s38(4)(ca) 58
11 Other matters 60
Patronage 60
Security and crime prevention 61
12 Conclusion 64
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1 Introduction
1.1 ALDI Foods Pty Limited (ACN 086 210 139) recently opened an ALDI supermarket at
the Warwick Grove Shopping Centre on 12 December 2018. The company seeks the
conditional grant of a liquor store licence to operate from a small space within the
store.
1.2 This detailed Public Interest Assessment (PIA) supports the application and
addresses all relevant aspects of the public interest in accordance with both the
Liquor Control Act 1988 (WA) (Act) and the licensing authority’s Public Interest
Assessment policy1 (PIA Policy).
1.3 Pursuant to the PIA Policy, the standard Locality for Warwick is a 2km radius area
surrounding the proposed site (Locality).
1.4 This PIA is part of the Applicant’s Case and should be read in conjunction with the
other parts, all of which is itemised in the document titled Index of Material Before the
Director and Applicant’s Case. Where this PIA cites particular documents with “DOC”
followed by a number (eg ‘(DOC 1)’), it references material in the Applicant’s Case by
way of its listing in the tables contained within the Index.2
1.5 In particular, referred to throughout this PIA are two detailed reports prepared by
experts that the applicant engaged in respect of this application (DOCS 12 and 13).
1.5.1 Patterson Research Group3 (PRG) surveyed people living in the Locality to
assess their attitudes toward the ALDI liquor proposal. This research was
done in November 2018 through a series of expertly prepared questions
that were put to a representative sample of residents.
1.5.2 Deep End Services4 (DES) provides expert in-depth analysis of the Locality.
This includes the demographics of residents, relevant planning policies and
strategies, trade catchment of the ALDI Warwick Grove store and the
density of licensed premises.
1.6 The findings in the reports prepared by these two experts supplement the applicant’s
own research and submissions. Collectively, they provide a significant volume of
evidence to support the Applicant’s Case for the grant of the ALDI Warwick Grove
licence.
1
Last amended 3 October 2018
2
Supporting material referred to in this document not produced by or for the applicant has been obtained from public sources
under licence. Where relevant, personal information within the supporting material has been blacked out for privacy reasons.
Full copies of the some of the source material accompany this PIA and are listed in the Index. Other material not so listed in
the Index can be made available in full if required and has only been left out of the Index to lessen the burden of paper on the
licensing authority.
3
https://www.marketresearch.com.au/about_us/overview.phtml
4
http://deependservices.com.au/index.php/about-us/
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2 Overview of proposal
2.1 This application is made by a highly sophisticated and experienced packaged liquor
operator, which has extensive supermarket and liquor retailing experience within
Western Australia, Australia and overseas.
2.2 ALDI has been operating in Australia since 2001 when the first ALDI store opened in
Sydney. There are now over 580 stores throughout Australia, including around 520
stores in the eastern states. Around 330 of those stores in the eastern states include
a liquor component. The company is in the midst of a $700 million expansion into
other states in Australia, with approximately 70 stores to open in Western Australia
and up to 50 stores in South Australia.
2.3 ALDI opened its first four supermarkets in Western Australia on 8 June 2016. By the
end of 2016, ALDI had opened 19 stores in total and served approximately 3.2 million
WA shoppers.5 There are currently 41 stores operating throughout this State, with
several more expected to open this year.
2.4 ALDI is one of the largest and most popular
retailers in the world. Some customers are
such passionate and dedicated fans of
ALDI’s wide range of household and
consumable products that they have
developed their own name, “ALDIholics”.
There is a customer-driven Facebook page
named ALDIholics, with its own logo depicted
to the right,6 devoted to information for ALDI
lovers.
2.5 Further in terms of social media, ALDI boasts around 26,000 followers on Twitter and
around 620,000 “likes” on its Australian Facebook page, as shown in the following
screenshots.7 These media are the modern day voice of the public and significant
representations of community sentiment.
5
http://www.perthnow.com.au/news/western-australia/aldi-to-open-14-more-stores-in-wa-in-2017/news-
story/0de29965fcd9712852ab9b2919908286
6
https://www.facebook.com/ALDIholics/
7
https://www.facebook.com/ALDI.Australia/ and https://www.facebook.com/ALDI.Australia/app/116943498446376/ (as at 8
January 2019)
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ALDI Warwick Grove
2.6 The emergence of the ALDI retailing concept into Western Australia, following the
company’s significant popularity in the eastern states, continues to be exciting and
highly anticipated from the general public’s perspective.
2.7 The proposal is for a small liquor section of only approximately 37m2 (including the
licensed checkout and checkout aisle) within the new ALDI Warwick Grove
supermarket. A carefully selected and exclusive range of unrefrigerated liquor is
proposed to be available in a discrete and clearly designated licensed area within the
supermarket.
2.8 This liquor model is virtually the same for all ALDI licences in Western Australia and
entirely unique to ALDI. Its various features are referred to throughout this PIA, make
for a bespoke manner of trade. The boutique type of liquor service is designed
specifically to complement and accompany the diverse and attractive ALDI
supermarket services and facilities. This creates a true one-stop-shopping8
convenience for customers, which is a key feature of the ALDI offering.
2.9 The ALDI liquor service was first made available in WA at the end of August 2017 in
five of its supermarkets. Currently a total of 29 ALDI supermarkets have been
approved to sell liquor in WA.
8
This is addressed in detail in the applicant’s accompanying Legal Submissions (DOC 11).
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2.10 The ALDI liquor offering is described as follows by ALDI Australia’s Wine and
Sparkling Buyer, Mr Jason Bowyer:9
Like our grocery offer, ALDI’s liquor range is focused, ensuring that we offer great value
and exceptional quality. Since establishing in WA more than a year ago, customers
have spoken loudly about their desire for us to bring our popular liquor offering to the
West.
ALDI partners with a number of high calibre international and Australian wine suppliers,
who each share our passion for quality. We have built strong relationships with these
suppliers, who are committed to ensuring that our wine products offer great value at their
respective price points.
2.11 In recognition of the launch of the ALDI liquor service in
WA, renowned wine expert Ray Jordan was invited to
sample six of the wines in ALDI’s WA stores. Mr Jordan
remarked that one of the wines in particular, being a $7
bottle of One Road South Australian Heathcoate Shiraz
2015 (pictured to the right), was “damn good”.10 That
Shiraz has also won several other awards, including
Double Gold & Best Value Shiraz of the Year at the 2017
Melbourne International Wine Competition. This Shiraz is
just one example of ALDI’s many other high quality, value-
for-money, award winning liquor products.
2.12 The debut of the ALDI liquor service in WA was widely embraced by the public. The
announcement on the ALDI Australia Facebook page11 (pictured in the following
screenshot on the left) received a swarm of favourable reactions. Many of the
comments revolved around members of the public wanting the liquor service at their
local ALDI supermarkets. Some examples are provided in the following
screenshots.12 There is clearly a significant demand for the ALDI liquor service
throughout WA.
9
https://www.aldi.com.au/fileadmin/fm-dam/Products/Groceries/Liquor/WA_Launch/ALDI_Media_Release_-
_WA_Liquor_Launch_1_.pdf
10
http://www.perthnow.com.au/news/western-australia/aldi-will-start-selling-alcohol-in-perth-stores-from-today/news-
story/c59014afc215ba475dd1265a0e89eb4c
11
https://www.facebook.com/ALDI.Australia/posts/1716136855110475 (accessed 27 February 2018)
12
Personal details have been blacked out for privacy reasons. A fully copy of the post can be provided to the licensing
authority if required.
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2.13 The layout of the ALDI Warwick Grove supermarket is pictured below. It shows the
proposed liquor display/browse area outlined in the bold red line. This is clearly a tiny
proportion of the overall supermarket footprint.
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2.14 Pictured below is a 3D aerial image the area proposed to be licensed in respect of the
liquor display/browse and checkout area.
2.15 This display/browse space will take the shape of a square and the displays
themselves will form a basic ‘U’ shape. This design enables convenience and a high
level of surveillance of the area. The display/browse area will also comfortably
accommodate shoppers with their trolleys for added convenience.
2.16 The checkout closest to the liquor display/browse area is proposed to be licensed for
the purposes of the liquor transactions. Staff operating at this checkout will also be
able to monitor all patron activity in the licensed area.
2.17 The small size and layout of the liquor browse/display area clearly confirms the main
role of the liquor store as a complementary service to the supermarket and will help
ensure the area is well-controlled and supervised.
2.18 Additional details of the ALDI liquor offering are provided further on in this PIA.
Consultation
2.19 As part of its thorough preparation of this application, the diligent applicant consulted
extensively with relevant authorities and the local community. In doing so, the
proposed liquor service has been explained and feedback sought.
2.20 The following consultation has been undertaken:
2.20.1 A representative from the applicant company met with officers of the
Racing, Gaming & Liquor arm of the Department of Local Government,
Sport and Cultural Industries (as it is now known) and notified the
Department in July 2015 that applications for liquor store licences would
soon be lodged. The applicant has subsequently liaised with the
Department in respect of modifications.
2.20.2 Representatives from the applicant company, together with its legal advisor,
met with Police officers in the Liquor Enforcement Unit on 31 July 2015.
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2.20.3 Representatives from the applicant company, together with its legal advisor,
met with the Executive Director Public Health on 31 July 2015.
2.20.4 An information and promotion flyer was distributed to households within the
Locality. A copy of that flyer is included in the Applicant’s Case (Pages 31 and
32 of DOC 12).
2.21 As referred to in the next section and also throughout this PIA, the applicant also
consulted extensively with the community through the market survey conducted by
PRG. The findings from the survey (DOC 12) show demand for the liquor service and
overwhelming support for the ALDI proposal.
Community demand
2.22 The market research was conducted before ALDI Warwick Grove had opened to the
public. At that time, the following finding was made by PRG:13
The survey found a sense of anticipation about the prospect of an ALDI store being
introduced to “a nearby shopping precinct”. Virtually all (95%) respondents indicated that
they were aware that ALDI stores were being established in WA, 92% were at least “quite
likely” to shop in the ALDI store, should it be created in a nearby shopping precinct, and a
further 5% would at least try shopping there, creating an estimated 97% who would at
least try the ALDI store when it opened in Warwick Grove Shopping Centre.
2.23 Indeed, ALDI store openings are often met with enthusiasm from the public. It is not
unusual for long queues to form outside of ALDI supermarkets prior to opening for the
first time.14 It has been observed at other ALDI store openings that “[b]efore long the
aisles became a hive of activity with customers inspecting the range of unfamiliar
brands and comparing prices”15. Pictured below is the queue outside the ALDI Halls
Head store on the day it first opened.
13
PRG report (DOC 12) at page 5
14
See for example, http://www.mandurahmail.com.au/story/3970386/halls-head-aldi-opens-its-doors/
15
http://www.mandurahmail.com.au/story/3970386/halls-head-aldi-opens-its-doors/
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2.24 Specifically as to the liquor proposal, “over eight in ten (81%) respondents who ever
buy packaged alcohol indicated that if shopping in an ALDI store which contained a
liquor section, they would purchase their take-away liquor requirements in that store.
This proportion was heightened to 87% amongst respondents who buy packaged
alcohol at least once a month”16. Furthermore, 82% of respondents who are
packaged liquor buyers liked the notion of being able to purchase groceries and liquor
in the one store (see the following graph).17 This is reflective of the level of demand
for the unique ALDI liquor service and the many benefits that would stem from it.
2.25 The following extracts from the PRG report (DOC 12) show that the ALDI concept
certainly has the potential to change and enhance the shopping behaviours of the
local community:18
The packaged alcohol purchasing pattern for this locality shows that currently the pattern of
buying packaged liquor in a “walk in and browse” outlet on a special shopping trip is the most
common form of shopping for packaged liquor.
60% report doing “all or most” of their packaged liquor purchasing on a special trip to a “walk
in and browse” store, whilst just 26% do “all or most” in connection with their grocery
shopping.
However, a further 21% report buying their packaged liquor requirements in connection with
their grocery shopping on about half their liquor shopping occasions (creating a net of 47%
who do so on at least half their grocery shopping behaviours). It appears that this locality
has an emerging behaviour pattern of purchasing alcohol in conjunction with typical
grocery shopping; although currently the more traditional “walk in and browse” shopping
option remains the most common form of alcohol purchase method.
It seems that the prospect of having a packaged liquor section within the ALDI supermarket
would be seen as an attractive prospect. Consider that the survey revealed:
16
PRG report (DOC 12) at page 5
17
At page 7
18
At pages 5 and 18
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ALDI Warwick Grove
• 97% of adults reported that they would at least try out the new ALDI store when it
opened.
• 80% of packaged alcohol buyers reported that the provision of a packaged liquor
section within a grocery supermarket would be more convenient for the purchase of
their packaged liquor requirements.
• 81% of alcohol buyers (87% of regular buyers) report that should the proposed ALDI
Warwick Grove Shopping Centre store have a liquor section, they would be likely to
also purchase their packaged liquor requirements if shopping for groceries there.
2.26 The local community members are entitled to enjoy the full range of ALDI’s offering,
including its liquor service. The ALDI retailing concept is enormously popular with
shoppers all around Australia and in other countries.
2.27 Further in terms of ALDI’s popularity within the general community, in response to the
initial refusal of the ALDI Harrisdale liquor store licence application at first instance in
June 2016, a massive 8,637 people took it upon themselves to participate in an
Internet survey conducted by Nine News Perth which asked: “Do you think ALDI
should be banned from selling alcohol because it’s too cheap?” Within just two days
86% of those who participated answered “no”. This represents a staggering 7,428
people. A print out of the survey results and the thousands of personal comments in
support of ALDI in Western Australia is included in the Applicant’s Case (DOC 26).
Relevantly, the survey was conducted without any involvement from the applicant and
was totally unsolicited.
____________________________________________________________________________
3 Applicant’s details and background
3.1 ALDI operates more than 10,000 stores across 18 countries. ALDI has become a
world-leading supermarket operator since it was founded in 1913 in Germany as a
family business. The following provides some detail about the history of the
organisation.19
The first foundation stone was laid in 1913 with the opening of a small food store in the
German town of Essen. It didn't take long for this little 'service store' to become a
popular place to shop.
During the '40s, an expansion program was created and more ALDI stores were
opened. In 1954, a celebration was held for the opening of the 50th store in Germany.
By 1960 ALDI had grown to a network of over 300 stores between the Ruhr Valley and
Aachen. The prosperous family business was then divided into two independent
companies: ALDI Süd - to service the South, and ALDI Nord - for the North.
'Self-service' was still a relatively new retail structure in the '60s and ALDI became the
first company in Germany to adopt this new retail concept. While customers were still
able to take advantage of the same high quality products as before, they could now
purchase them at much more competitive prices.
19
https://corporate.aldi.com.au/en/about-aldi/aldi-history/
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ALDI Warwick Grove
In 1983, ALDI Süd started chilled distribution depots and sold fresh products such as
cheese, yoghurt and sausages. Frozen products came in 1998 and were closely
followed by fresh meat. ALDI, to this day, continues to keep up with the ever-evolving
taste of the modern consumer.
3.2 ALDI’s published mission is to provide the public with “incredibly high quality at
impossibly low prices.”20 This is achieved through a highly sophisticated business
model involving a very focused selection of products and advanced levels of
systemisation and organisation designed for optimum efficiency and product control.
ALDI is dedicated to maintaining consistency in its philosophy of incredibly high
quality at impossibly low prices.
3.3 ALDI is a responsible and sophisticated corporate citizen and operates pursuant to a
sophisticated corporate structure (DOC 14), very high standards and key performance
indicators. Included in the Applicant’s Case is a copy of the ALDI Corporate
Responsibility Policy (DOC 15) and other ALDI published policies in respect of
consumers, resources, suppliers, operations and community (DOC 16). These
policies, together with other information in this PIA, collectively illustrate the
applicant’s very high standards and superior level of corporate responsibility.
3.4 The company has published the following statements in its ALDI Smarter Shopping
brochure (DOC 20):
We are exacting in our pursuit of quality and work closely with all our suppliers to deliver
products that meet stringent international standards for quality, nutrition and taste. Every
single product that appears on ALDI’s shelves has been sampled, tested and signed off
by senior management before it is added to our range.
Once it is in our stores, the rigour does not stop there. Each and every product that
appears on our shelves is tested a number of times throughout the year to ensure it still
meets the strict specifications we set at the very beginning.
3.5 ALDI’s corporate responsibility principles also apply to its partners and suppliers. For
example, the following was reported in September 2017:21
Aldi has asked Australian suppliers to sign up to a range of international ethical sourcing
groups and start auditing their own supply chain and manufacturing systems.
…an Aldi spokesperson said Aldi’s corporate responsibility principles guide Aldi through
its day-to-day actions and it is important it partners closely with its suppliers to achieve
high standards.
“In addition to requiring high social standards throughout the supply chain, we also aim
to: source raw materials responsibly, lessen our impact on the environment, support
Australian businesses and give back to the communities we operate in, and help make
healthy choices affordable for our customers,” Aldi’s spokesperson said.
3.6 Another example of ALDI’s corporate responsibility and environment-friendly policies
is its announcement in October 2017 that it will help support the delivery of the New
South Wales Government’s sustainability initiative, dubbed Return and Earn
20
https://www.aldi.com.au/en/about-aldi/customer-information/
21
http://www.ausfoodnews.com.au/2017/09/11/aldi-tightens-supplier-corporate-social-responsibility-standards.html
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Container Deposit Scheme. The initiative aims to halve the number of bottles and
cans thrown away in parks, beaches and waterways. In a statement, ALDI said it was
“committed” to supporting and “participating in the largest litter reduction initiative in
NSW”22.
3.7 ALDI’s pursuit of excellence and quality in all things is evident in the many accolades
it has won in Australia. The following sub-paragraphs describe some of its awards
just within the past few years.
3.7.1 ALDI was named the 2016 Retailer of the Year by the Australian Retail
Association.23 In awarding ALDI this prestigious title, the Australian Retail
Association noted that a key factor behind the organisation being selected
was its strong track record for creating innovative staff programs, investing
heavily in its staff with above-industry standard pay and staff development
opportunities. ALDI won the award “in recognition of its growth, influence
and market leading policies, which have seen the supermarket chain
significantly challenge the majors in its category and beyond with the
implementation of innovative sales approaches.”24
3.7.2 ALDI was also nominated Roy Morgan Research Supermarket of the Year
2016. This is the fourth time since the customer satisfaction-based awards
were first established in 2011 that ALDI has claimed this title.25
3.7.3 ALDI won several awards in BrandSpark International’s 2017 Best New
Products Awards, “taking out the top prize in 16 different categories,
including household cleaning, skin-care and fabric softener.”26
3.8 ALDI has won awards across its full product range.27
3.9 ALDI’s momentum in achievements has not stopped. Just in the last year alone the
company has continued to be recognised for its popularity and success in the market
place:
3.9.1 In July 2018 it was announced that ALDI was voted as “the most trusted
brand” in Australia in a Roy Morgan Research survey.28 It was reported
that the success of this global retailer in the Australian market “has been
22
https://www.insideretail.com.au/blog/2017/10/10/woolworths-and-aldi-sign-up-to-can-scheme/
23
http://www.smartcompany.com.au/industries/retail/73746-aldi-crowned-australias-retailer-year-embarks-major-expansion-
100-new-stores/
24
DOC 24
25
https://www.aldi.com.au/en/groceries/awards/roy-morgan-supermarket-of-the-year-2016/. Roy Morgan Research is
Australia’s best known and longest established market research company, https://www.roymorgan.com/about
26
http://www.ausfoodnews.com.au/2017/02/20/products-of-the-year-awards-for-2017-announced.html
27
https://www.aldi.com.au/en/groceries/awards/
28
https://www.roymorgan.com/findings/7653-aldi-most-trusted-brand-in-australia-201807060755 (DOC 21)
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built not only on discount prices but also a reputation for reliability and
meeting the needs of consumers”. Roy Morgan Research highlighted that
important drivers of trust “include reliability, customer focus, knowledgeable
staff, ease of contact and previous good experiences with the company, in
addition to other key performance indicators.” This latest accolade of
ALDI’s is a testament to its high level of corporate social responsibility and
dedication to its customers.
3.9.2 In that same month, ALDI rated at the top of Canstar Blue’s customer
satisfaction ratings for supermarkets. That was the fourth year out of five
that ALDI has been nominated for this title.29
3.9.3 In October 2018, ALDI was crowned 2018 Retail Employer of the Year at
the Australian Retailers Association awards. “To be in the running, [ALDI]
had to demonstrate a strong track record across a range of areas, including
staff education, training and development, internal communication,
community support programs and Corporate Social Responsibility”.30 The
Association remarked that “ALDI have proven to be “fierce contenders” with
a strong commitment to diversity, non-discrimination and support to all
29
https://www.canstarblue.com.au/stores-services/supermarkets/. Canstar is Australia and New Zealand’s premier research
and expert ratings agency: http://www.canstarblue.com.au/about-canstar-blue/
30
https://www.aldiunpacked.com.au/Article/October-2018/ALDI-crowned-Retail-Employer-of-the-Year
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employees”31. The Association even considered ALDI to be “pioneers in
the retail sector”32.
3.10 More specifically, ALDI is also an award-winning retail liquor supplier. It was named
Liquor Store of the Year 2017 at the Roy Morgan Research Customer Satisfaction
Awards.33
3.11 These awards by Roy Morgan Research recognise companies across a range of
industries that go the extra mile to please its clients and customers. These awards
are “the benchmark by which customer satisfaction is measured in Australia, New
Zealand and Indonesia. Reliable, accurate and totally objective, the Australian
awards reflect the experiences of some 50,000 consumers, as aggregated in [Roy
Morgan’s] Single Source survey over 12 months”34. There can be no question as to
the credibility of these awards and certainly no doubt that ALDI customers are
immensely satisfied with the liquor service ALDI provides.
3.12 Jason Bowyer gave the following remarks on this achievement:35
At ALDI Australia, we are delighted to win the Roy Morgan Customer Satisfaction Award
for Liquor Store of the Year 2017. We believe that all our products, from our award-
winning $19.99 Monsigny Brut Champagne to our red and white wines, deliver
exceptional value, quality and consistency. It’s great to see our customers across
Australia agree.
Our success is based on the close relationships we have with our suppliers, who all
share our passion for awesome quality. Aldi partners with some of the best producers
and winemakers both in Australia and internationally, which means we can deliver
exceptional quality, value and consistency to our customers. Our partnerships with our
suppliers are focused on a desire to see the customer win with great-tasting wines at
unbeatable prices.
3.13 The title of Liquor Store of the Year 2017 follows many individual product awards that
ALDI has received locally and internationally over the years. “It recognises the
unique value ALDI can offer [its] customers with [its] tightly focused range,
31
https://insidefmcg.com.au/2018/10/19/aldi-awarded-ara-employer-of-the-year/
32
https://insidefmcg.com.au/2018/10/19/aldi-awarded-ara-employer-of-the-year/
33
https://www.aldi.com.au/en/groceries/awards/roy-morgan-liquor-store-of-the-year-2017/
34
http://www.roymorgan.com/findings/7505-roy-morgan-announces-winners-of-the-2017-customer-satisfaction-awards-
201802201125
35
https://www.theshout.com.au/news/aldi-wins-roy-morgan-liquor-store-year/
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unwavering passion for quality and longstanding relationships with local and
international suppliers.”36
3.14 ALDI certainly enjoys many accolades for its exclusive product range (DOC 18). The
following are but a few examples of ALDI’s awards and award-winning products:
3.14.1 In 2014: “The Sydney International Wine Competition found a $6.99
Cabernet Sauvignon from South East Australia and a $9.99 Semillon,
blended specifically for the Aldi discount supermarket chain, to be in its top
100. And Aldi’s $4.99 Spanish Tempranillo snagged a Blue Gold award —
the equivalent of a silver medal.”37
3.14.2 In 2015: “The Sydney International Wine Competition has deemed Aldi’s
discounted wine offerings among the best of the best”.38
3.14.3 In 2016: ALDI’s Prosecco “was voted as the ‘Best Value Buy’ in Winestates
Annual Edition 2016” and “based on the frequency by which it was out of
stock during the summer months, has been a strong performing item for
Aldi”.39
3.14.4 In May 2017: “The $8 Aldi Côtes de Provence Rosé has taken out an
amazing silver medal at the International Wine Challenge – an event
dubbed ‘The Oscars of the wine Industry’, according to The Sun UK. The
award-winning drop was competing against bottles three times its price,
even beating a vintage version of the drop, which retails for over $30”40.
3.14.5 In June 2017: ALDI’s Highland Black Eight-Year-Old Scotch Whiskey
received a Double Gold prize in the Melbourne International Spirits
Competition. This product “beat some rivals valued three times more in
price”.41
3.14.6 In July 2017: ALDI’s Oliver Cromwell London Dry Gin won a gold medal at
the International Spirits and Wine Competition and was named one of the
best gins in the world.
3.14.7 In August and November 2017: ALDI’s $6.99 bottle of One Road South
Australian Heathcoate Shiraz 2015 won the Double Gold award at the 2017
36
https://www.aldiunpacked.com.au/Article/May-2018/Lifting-the-lid-on-ALDI’s-liquor-story
37
http://www.news.com.au/lifestyle/food/drink/six-of-aldis-cheap-wines-judged-among-best-at-sydney-international-wine-
competition/news-story/eb163e6f8d5e9b85a5522a8d1b622d50
38
Australian National Retailer, February 2015 at page 16: http://en.calameo.com/read/0003734959f4c8982c4bc
39
ALSA – IRI State of the Industry Report, March 2017 at page 62 (DOC 31)
40
http://www.elle.com.au/culture/aldi-rose-is-one-of-the-best-wines-in-the-world-13255 and
http://fortune.com/2017/05/30/best-rose-wine-challenge-aldi/
41
http://www.news.com.au/lifestyle/food/drink/35-aldi-whisky-takes-out-top-prize-for-being-a-phenomenal-drop/news-
story/14ca83dce732c7f46232a283eff29110
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ALDI Warwick Grove
Melbourne International Wine Competition and the Gold medal at the Great
Australian Shiraz Challenge.
3.14.8 In October 2018: ALDI’s Blackstone Paddock Limited Release Chardonnay
2017 took home two awards at the 2018 Wine Show of Western Australia.42
This wine retails for just $14.99 and is exclusive to ALDI. Even at its price
point, this Chardonnay “beat a hot field of WA chardonnays that included
other more famous gold medal winners such as Vasse Felix Heytesbury,
Flametree SRS Wallcliffe, Xanadu Stevens Road and Deep Woods Estate
SV in winning the best chardonnay and best white wine of the show”43.
3.15 The various accolades described above, which are but a few examples, “[paint] Aldi in
a positive light and [they reinforce] the fact they’re offering quality products at a value
price.”44
ALDI supermarkets
3.16 ALDI supermarkets generally comprise a total footprint of around 2,000m2. Some are
free-standing stores, while others (including the one at Warwick) are located within
the confines of a shopping centre.
3.17 Consistent with other ALDI stores, the Warwick Grove store comprises the following
different parts or areas, listed in order of size in terms of their approximate portion of
the total area:
3.17.1 Main public retail area (non liquor) – grocery and other supermarket items.
3.17.2 Storage.
3.17.3 Loading dock/delivery area.
3.17.4 Entrance and trolley bay.
3.17.5 Checkouts.
3.17.6 Office and staff facilities.
3.17.7 Liquor display and browse area.
3.18 ALDI stores are bright and pleasant shopping environments. The following images
depict the stylish and clean appearance proposed at the ALDI Warwick Grove store:
42
https://insidefmcg.com.au/2018/10/10/aldis-15-chardonnay-bags-wa-wine-award/
43
https://thewest.com.au/lifestyle/drink/aldi-chardonnay-is-best-white-wine-in-state-ng-b88983629z
44
http://www.smartcompany.com.au/industries/retail/aldi-wins-two-awards-alcohol-whats-unassuming-underdog-right/
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ALDI Warwick Grove
3.19 ALDI operates a generic store modelling concept. The size, layout, colour, product
location and stock range of each ALDI store are almost always the same. Minor
differences may occur from time to time at some stores owing to land formation, town
planning requirements or other unique particulars of the site. For example, the
entrance door may be positioned a few metres away from its usual position at a
particular location.
3.20 The standardisation of store layouts engenders familiarity for customers, enhances
shopping comfort, efficiency and convenience. It also enables customers to rely on
consistency of style, standard and overall offer. Importantly, these are key features of
the applicant’s successful superior efficiency model of operation which benefits
customers enormously and is clearly popular with shoppers.
3.21 ALDI supermarkets contain only around 1,350 core product lines. There are limited
brand options within each different product line. For example, ALDI may offer only
two or three different brands of plain flour, rather than five or more as is commonly
stocked at most supermarkets. This enables ALDI to operate from a smaller and
more user-friendly footprint and with a more exclusive and carefully selected range.
3.22 Many of ALDI’s products are exclusive versions of mainstream big-brand name items
which are manufactured according to ALDI’s strict specifications to ensure quality and
value for money. Expressi Coffee is one of the most popular examples. The
Expressi Coffee capsule machine and coffee capsules were category winners in the
2017 Product of the Year awards.45 ALDI’s Smarter Shopping corporate brochure
(DOC 20) lists some examples and attributes of ALDI’s products.
3.23 ALDI’s liquor range also includes exclusive products that can only be purchased in its
stores. The ALDI liquor offer is explained in further detail later in this PIA.
45
http://www.ausfoodnews.com.au/2017/02/20/products-of-the-year-awards-for-2017-announced.html
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ALDI Warwick Grove
3.24 “The majority of ALDI’s exclusive brands are sourced from Australian suppliers and
we only source products from overseas when we can’t find the product, quality,
efficiency or innovation we seek, here in Australia.”46
3.25 63% of ALDI shoppers surveyed in the eastern states have said that they buy more of
the ALDI exclusive products than well-known branded products.47
3.26 ALDI supermarkets offer a wide range of quality products including fresh food,
packaged food, other consumables and various household and personal items. In
addition, every Wednesday and Saturday “special buys” are promoted by ALDI which
are specialty short-term product lines that are usually non grocery items. Flat screen
televisions, furniture, clothing, appliances, BBQs, tools, gardening equipment,
vacuums and toys are just some examples. These have proven extremely popular in
the eastern states. Some are repeated occasionally, such as ALDI’s now well-known
annual line of ski gear popular in the eastern states which customers queue for each
year.48
3.27 Included in the Applicant’s Case are copies of pages from various “special buys”
catalogues (DOC 29). A very large and diverse range of products can be seen to be on
offer, including the popular clothing line by Colette Dinnigan, Dyson vacuum cleaners
and a six burner BBQ.
ALDI pricing and promotion
3.28 ALDI prides itself on consistently competitive pricing across all of its product lines and
providing customers with exceptional value for money. The company’s ability to
achieve such low prices for quality products stems from its highly sophisticated
business model which focuses on operational efficiency. With reference to a 2015
online article, the following are but a few examples of aspects of ALDI’s operations
which heighten productivity and reduce waste:49
3.28.1 “One of the most visible examples is trolleys. To get one you must insert a
gold coin, which is refunded when you return it. That way Aldi doesn’t have
to pay anyone to hang out in carparks retrieving scattered trolleys.”
3.28.2 Products in ALDI stores are displayed on re-usable crates, designed
specifically for ALDI. The crates fit systematically in the ALDI warehouse,
delivery trucks and supermarkets. For example, ALDI’s multi purpose
beverage trays “can go from the factory to the truck to the supermarket floor
without being unpacked. It can store 1.25L bottles or 2L bottles. You
spend less on shelf stackers if you don’t need to stack shelves.”
46
https://www.aldi.com.au/en/about-aldi/australian-made/
47
http://www.roymorgan.com.au/findings/6242-home-brand-products-have-way-to-go-with-grocery-buyers-201505202311
48
http://www.weekendnotes.com/aldi-snow-gear-sale/
49
http://thenewdaily.com.au/money/finance-news/2015/05/24/secret-aldis-super-low-prices/
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ALDI Warwick Grove
3.28.3 ALDI’s products “have multiple barcodes or enormous barcodes…so the
checkout person needn’t fumble and fuss to scan them.”
3.28.4 ALDI does not provide its customers with free plastic bags for their goods at
the checkout. Customers need to bring their own bags or buy an ALDI one
and then pack their own shopping. This is another dual cost saving and
environmentally friendly policy of the company.
3.29 ALDI’s shelving, storage methods, displays, product placement and other logistical
aspects are designed to coordinate with each other to achieve optimum operational
efficiencies for stocking products and store management. ALDI’s business is highly
systemised and disciplined. As a result ALDI is able to reduce operating costs and
provide better services and facilities for its customers.
3.30 ALDI does not operate by the regular retailing method of rotating discounts each day
or week. Rather, prices are maintained at a consistently low level. This means that
customers know what to expect when shopping at an ALDI store. It also reduces
costs and resources associated with the logistics of managing specials which involves
external promotion, advertising on site, changing ticket prices, reconfiguring product
placement, adjusting till systems and other processes. ALDI does not incur all of
these costs, thereby enhancing its operating efficiency.
3.31 Consistent pricing is also indicative of consistent quality. ALDI does not downgrade
its products through heavy discounting. In this regard in terms of liquor especially,
ALDI’s products very much represent value-for-money. High quality award winning
liquor items are provided at prices accessible to most people. The applicant is driven
by quality.
3.32 ALDI’s policies and practices clearly achieve the goal of managing costs for the
benefit of customers, whilst maintaining quality. ALDI was one of the two best
performers in 2017 for gaining share in the total grocery market, up 0.8% points to
12.1%.50 Indeed “[ALDI’s] influence is growing”51 over the consumer market with its
expansion in Australia.
3.33 The Australian Liquor Stores Association noted in its March 2017 report (DOC 31) that
Australian “shoppers have migrated towards the value messaging of Aldi”.52
3.34 Canstar Blue also made the following statement about ALDI:53
While ALDI doesn’t have the same number of stores as Coles and Woolworths, it’s
fighting back against the duopoly with often lower prices, with its own brands offering
real competition against major brands stacked by other supermarkets. ALDI also
offers something different with its ‘Special Buys’, one-off or seasonal products
ranging from specialty foods to snow gear to luxury skin cream.
50
http://www.roymorgan.com/findings/7537-woolworths-increases-lead-in-$100b-plus-grocery-war-201803230113
51
http://www.ausfoodnews.com.au/2016/10/05/aldi-supermarket-shoppers-are-the-most-satisfied.html
52
Page 14
53
https://www.canstarblue.com.au/stores-services/supermarkets/
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ALDI Warwick Grove
3.35 At the opening of ALDI’s distribution centre in Jandakot in May 2016, former MLA Mr
Joe Francis noted that one of the biggest benefits of ALDI was going to come from
the downward pressure on prices that would be applied to the major supermarkets.54
His statement has clearly been confirmed by the evidence provided above.
3.36 ALDI’s business approach is best explained in its “Good Different” slogan. The
campaign was launched in 2017 and is further described in the following extract:55
Good Different isn’t just a new
tagline for ALDI Australia – it’s
our way of summing up our
philosophy and approach to all
aspects of our business. … After
16 years of establishing
ourselves as a trusted place for
the weekly shop, it’s now time for us to build on this success and tell Australians what
makes us different, and why we will continue to be different.
ALDI Australia is unapologetically different – and that’s a good thing for shoppers. We
are proud of our differences and we stand by them wholeheartedly, as they are what
allows us to bring unbeatable value to our customers, maintain strong relationships with
our suppliers and support our staff every day.
3.37 In many aspects, ALDI is distinctly different from alternative supermarket concepts.
Its range of products and services offer outstanding points of difference that have won
high favour with the public. The business model has huge popularity elsewhere in the
country and is proving just as popular in this State. ALDI attracts its own loyal and
faithful patrons who become regular repeat customers relying on ALDI’s consistency
of product, service and value for money.
__________________________________________________________________________
4 ALDI liquor model
4.1 The ALDI liquor model is designed, in all respects, to complement the supermarket
and to provide adult shoppers with the dual benefit of ALDI’s liquor product range and
convenience of accessing those products whilst doing other household shopping.
4.2 The ALDI liquor section proposed at Warwick has been designed based on the
eastern states model originally, which has been replicated in WA and proven to
operate extremely successfully. The 21m2 display/browse area is a very modest
liquor outlet by usual industry standards, but highly valuable to customers. The
particular liquor stock range itself and also as combined with the supermarket offer,
represents a significant development of liquor retailing in Western Australia.
4.3 This liquor model has been developed based on the ALDI’s many years of extensive
supermarket and packaged liquor retailing experience in Australia and overseas.
54
http://www.watoday.com.au/wa-news/supermarket-giant-aldi-opens-60m-distribution-centre-in-jandakot-20160518-
goxuro.html
55
https://insidefmcg.com.au/2017/05/15/aldis-good-different-campaign/
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ALDI Warwick Grove
ALDI has been operating liquor services within supermarkets in Australia for more
than 15 years. The model has been extensively tried and tested in New South Wales,
Victoria and the Australian Capital Territory. In each jurisdiction it has proven to be
very successful and low risk. The ALDI business model and liquor area design and
layout operate with great success, are very popular with the public and have not
caused any troubling or concerning issues with local governments, police or health
authorities at around 330 locations in Australia.
4.4 The unique proposal, unrivalled in this State and having attracted considerable
custom in other locations, will provide the Warwick community with something
capable of catering superbly for the diversity of modern consumer requirements.
4.5 The Warwick Grove liquor service will operate during the same hours as the
supermarket, subject to permitted trading hours under the Act,56 which the applicant
seeks approval for. If the supermarket were to operate outside of the approved
licensed trading hours, the liquor display/browse area would be clearly closed off to
customers.
4.6 There are many aspects to the ALDI liquor model which differ from virtually all other
packaged liquor outlets. The following key unique aspects of this model, which will
apply at Warwick Grove should the application be approved, are highlighted:
4.6.1 The combination of the ALDI Warwick Grove liquor service with the ALDI
supermarket, which will result in a one-stop-ALDI shopping convenience.
4.6.2 One transaction convenience.
4.6.3 ALDI exclusive product range.
4.6.4 The small size and location within the supermarket.
4.6.5 The absence of refrigeration.
4.6.6 The absence of external presence of the liquor store.
4.6.7 The particular level of surveillance of the browse/display area which can be
seen and monitored by staff at all times in its entirety.
4.6.8 The combined beneficial effects of the features listed above which are
supplemented by the overall manner of trade and harm minimisation
features identified.
The premises
4.7 The following pictures of the ALDI Joondalup liquor section show the sectioned-off
licensed area, which is proposed to be almost the same at Warwick.57
56
Namely 8am to 10pm Monday to Saturday, with variations for ANZAC Day, Good Friday, Christmas Day and some
Sundays as approved by the licensing authority
57
The faces of customers have been blanked out to protect privacy. Full images can be provided to the licensing authority if
required.
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ALDI Warwick Grove
Liquor area
Liquor area
4.8 The image on the right is indicative of how the
proposed display area will appear from within.
It will be uncluttered and uncomplicated,
easily accessed, light and bright.
4.9 It is obvious from these images that the
position, layout and small size of the liquor
display/browse section enable very clear and
uninterrupted visibility of and and supervision
into this area. This aspect assists with
security, surveillance, management and
control by staff.
4.10 Thoroughly trained and suitably qualified staff members over the age of 18 will be
positioned at the nearby licensed checkout at all times, where they will be able to see
directly into the liquor area, unobstructed. Such constant and close surveillance is
rarely achievable at most other usual liquor stores due to their size, location of aisles
and walk-in cool rooms. Further details of the applicant’s well developed risk
management measures, which include a heavy emphasis on staff training, are set out
elsewhere in this PIA.
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ALDI Warwick Grove
4.11 The liquor area will be entirely landlocked within the
ALDI supermarket. It will have no access from
outside of the ALDI supermarket, nor will it be visible
from outside the ALDI supermarket. The licensed
area will also have no external access or façade.
Some signage external to the licensed premises may
be displayed which is modest and states simply that
there is “liquor available in store” the ALDI store, but
such signage will not contain references to particular
liquor products or prices of liquor products. An
example of the kind of external signage that may be
displayed is shown.
4.12 There will be no cool room or other refrigeration in the liquor area. All products will be
stocked and sold at room temperature. This unique feature further confirms the
intention that the liquor service is genuinely designed to complement the supermarket
and provide a one-stop-ALDI shop. Importantly also, the absence of refrigerated
liquor significantly reduces the risks associated with liquor sold and supplied from the
ALDI store. The lack of refrigeration will dissuade customers from buying on impulse
with a view to consuming the liquor close by or in some other irresponsible manner.
4.13 In addition to the liquor display/browse area and the adjacent checkout, the
supermarket office is also proposed to be licensed solely for the purpose of storing
licensing-related documents including the approved plans, harm minimisation policy
documents and incident register. The applicant also intends to store liquor in the
back-of-house storage area of the ALDI Warwick Grove supermarket and also at the
applicant’s distribution centre situated within the Jandakot Airport commercial
precinct. No sale or supply will take place from the storage facilities.
Stock range
4.14 The ALDI range of liquor products comprises a reasonable election of wines, beers,
spirits, ciders and liqueurs. The in-store range will contain a carefully selected value
for money range of approximately 95 items, many of which are award-winning.
Included in the Applicant’s Case is ALDI’s core stock range of 2018 as well as its
impressive list of awards won in respect of its liquor products (DOC 18).
4.15 The range will vary from time to time as new products become available, in response
to customer requirements and when occasional specialty items are offered.
Generally, the ALDI liquor service will include the following:
4.15.1 60 different wines – red, white, sparkling and fortified.
4.15.2 16 different beers – full, medium and light strength.
4.15.3 15 different spirits – bourbon, brandy, gin, scotch, vodka and liqueurs.
4.15.4 4 different ciders.
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ALDI Warwick Grove
4.16 ALDI’s award winning and “food-friendly” wines represent excellent value for money
for consumers and ensure that “affordable wines can still deliver the goods”.58
4.17 Included in the Applicant’s Case is a copy of pages of an ALDI catalogue showing
liquor items (DOC 30). It is a relatively modest, yet stylish and elegant advertisement
depicting quality products, including some mainstream items and some products
exclusive to ALDI. The advertisement contains product information for each item,
clearly demonstrating the quality and value-for-money propositions regarding the
ALDI range and the fact the range is indeed carefully selected and responsibly
promoted.
4.18 Within the liquor range available in any given week is a selection of new and different
liquor items which change from week to week, similar to the “special buys” offer
referred to earlier on the PIA. Approximately eight different products per week are
made available to customers until the stocks are depleted and then new ones are
brought in for customers so the product selection remains fresh and vibrant.
4.19 The applicant’s product range also includes Western Australian produced wines.
ALDI has partnered with various wine makers from the Margaret River region to
develop a selection of exclusive ALDI Margaret River region products (DOC 19). Those
items include the following by way of example:
4.19.1 Miles from Nowhere Margaret River Semillon Sauvignon Blanc 2013
4.19.2 A.C. Byrne & Co Margaret River Chardonnay 2013
4.19.3 Vinatero Margaret River Chardonnay 2012
4.19.4 Blackstone Paddock Premium Margaret River Cabernet Sauvignon 2010
4.19.5 Robert Oatley Margaret River Cabernet Sauvignon 2011
4.19.6 A.C. Byrne & Co Margaret River Shiraz 2012
4.20 ALDI’s liquor range is determined following a rigorous process of elimination trialling
and testing of products and thereafter identifying those that offer the very best value
for money which necessitates excellent quality. The optimum range is provided to
customers. Therefore, a smaller quantity of products than may be found at most
other liquor stores is stocked. The ALDI range is much more discerning and refined
than most other liquor outlets. This ensures, as referred to previously, value for
money and great convenience.
ALDI Exclusive Products
4.21 One of the most unique aspects of the ALDI liquor offering is the fact that it includes
an exclusive range of products (DOC 18), made-to-order for ALDI stores that are not
available at any other packaged liquor outlet.
58
http://www.foodwinetravel.com.au/wine/wine-features/aldi-wine/
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ALDI Warwick Grove
4.22 The majority of ALDI’s range is unique and exclusive to ALDI. Shoppers simply
cannot access those items at any other outlet.
4.23 Many of these ALDI exclusive products have been awarded medals at prestigious
competitions where they are judged against much more expensive products. For
example, at the 2016 Sydney International Wine Competition, the following three
ALDI exclusive products (pictured below) won the competition’s highest award, the
coveted Blue-Gold Medal:59
South Point Estate 2015 Rose Tudor Central Victorian 2014 Blackstone Paddock “The Player”
($4.99) Shiraz ($12.99) Barossa 2014 Shiraz ($14.99)
4.24 As a result of ALDI’s success at the event, the founder of the Sydney International
Wine Competition, Mr Warren Mason, was full of praise for Jason Bowyer, remarking
that he was “…probably better than anyone in terms of thinking of his market, given
he’s able to offer wines at $10 a bottle or less” and adding that “he has obviously got
his technique and approach right.”60
4.25 In order to become an ALDI exclusive product, the producer needs to enter into an
agreement with ALDI whereby it is agreed that particular brand of product will not be
distributed or provided to any other retailer. This means that ALDI exclusive products
cannot be obtained anywhere other than at an ALDI store.
4.26 The ALDI exclusive products differ significantly from the Woolworths and Coles
private-label liquor ranges. Woolworths and Coles generally purchase wineries,
where possible, and these products then become what are known as private-label
wines. The issue with this approach, in terms of the proper development of the liquor
industry, has been well explained by David Prestipino in his article ‘Winestein
Uncorked: ‘Local’ WA wines actually owned by Woolworths, Coles’ where he
describes the duopoly’s approach as follows:61
59
https://www.top100wines.com/currentyear/award_categories.asp
60
http://www.news.com.au/lifestyle/food/drink/supermarket-chain-aldi-has-come-up-trumps-with-its-cheap-wines-a-winner-at-
sydney-international/news-story/a85c3072573f72e202198eda928835ae (DOC 22)
61
http://www.watoday.com.au/entertainment/your-perth/winestein-uncorked-local-wines-actually-owned-by-woolworths-coles-
20151211-gllhjo.html (DOC 23)
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