Myer : Modern Slavery Statement 2023

Modern Slavery Statement 2023

Modern Slavery Statement 2023

Contents

3 7

Business and	Modern slavery
supply chain	risks

About Myer	1
Message from CEO	2
Our business and supply chain	3
Risks in our operations and supply chain	7
Our actions and response	11

11 15

Actions and	Measuring
response	effectiveness

Measuring effectiveness	15
Our 2024 priorities	16
Consultation	16
Mandatory reporting requirement	16

About this Statement

Myer Holdings Limited (ABN 14 119 085 602) is listed on the Australian Stock Exchange (ASX: MYR), registered at Level 7, 1000 La Trobe Street Docklands Victoria 3008. This modern slavery statement (statement) is made under the Commonwealth Modern Slavery Act 2018 (Cth) and covers all entities within Myer Holdings Limited including Myer Pty Limited, sass & bide Pty Limited and Marcs David Lawrence Pty Limited for the period 31 July 2022 to 29 July 2023 (the reporting period or FY23).

References to "Myer, we, our or us" in this Statement refers to Myer Holdings Limited.

Any forward looking statements are based on current knowledge and assumptions that may exist and affect the Myer business and its operations in the future. Myer does not give any assurances that the assumptions will prove to be correct as these statements may be affected by a range of variables which may alter the actual results, performance or achievements to be materially different from the relevant statements. Readers are cautioned not to place undue reliance on forward-looking statements. Except as required by applicable laws and regulations, Myer does not undertake to publicly update, review or revise any of the forward looking statements or to advise of any change in assumptions on which any statement is based. Forward looking statements do not represent guarantees or predictions of future performance and equally past performance cannot be relied on as a guide to future performance

Acknowledgement of Country

In the spirit of reconciliation, Myer acknowledges the Traditional Custodians of country throughout Australia and their connections to land, sea, and community. We pay our respects to their Elders past and present and extend that respect to all Aboriginals and Torres Strait Islander people.

1  -Modern Slavery Statement 2023

About Myer

Myer is an iconic Australian brand synonymous with style, fashion and community engagement spanning over 100 years. Our values inform the behaviours and decisions of our team members and the way we do business. They underpin our unwavering commitment to ethical and socially responsible business practices that considers the impact to people and communities in our operations and supply chain.

Myer operates department stores across Australia under Myer Pty Ltd, and also owns well known Australian fashion labels, Sass

• Bide Pty Ltd and Marcs David Lawrence Pty Ltd. Collectively, we offer a diverse range of merchandise across womenswear, menswear, childrenswear, beauty homewares, electrical goods, toys and general merchandise.

Myer is committed to continuous progress to ensure we conduct our business in an ethical, social, and sustainable manner throughout out our operations and supply chain. This commitment extends to identifying, assessing, and addressing modern slavery risks. This is our fourth modern slavery statement, and we are proud to have continued to make progress on our commitment.

We have a longstanding history of fostering ongoing relationships with suppliers to ensure that we work together to address the challenges associated with safeguarding human rights. We are committed to supporting the rights and wellbeing of workers throughout our operations and supply chain and promoting awareness of modern slavery risks.

Throughout the year, we continued to develop our key areas of focus, which are increasing transparency, stakeholder engagement and engaging in meaningful collaborative efforts. We have updated and published a full listing of all our direct suppliers, which is available on the sustainability page of myer.com.au. We have improved our traceability by continuing tracing efforts beyond final production factories, achieving partial visibility of our inputs and processing facilities.

During the year, Myer continued its focus on strengthening its ethical sourcing program, alongside a continued emphasis on improving and implementing mitigation processes for identified modern slavery risks. The complexity of supply chains remains a key obstacle of our objective to improve traceability and map beyond our final production suppliers, to component manufacturers, processing facilities and raw material suppliers.

We continued to provide bespoke ethical sourcing training to our high risk team members to build capability and understanding of our ethical souring policy and modern slavery risks and completed our wage gap analysis to understand the disparity between wages paid and living wages. Our next step is to commence discussions with our suppliers to work towards closing the gap.

This statement has been prepared to meet the requirements of the Modern Slavery Act 2018 (Cth) and reflects the continued modern slavery due diligence efforts conducted on a group level, across Myer Pty Ltd and our subsidiaries, Sass & Bide Pty Ltd and Marcs David Lawrence Pty Ltd.

This statement was reviewed and approved by the Myer Holdings Limited board on 25 January 2024.

250	10,000+	60
Total stores and online	Australian based team	Overseas based
	members	team members

4.2m 253 40,457

Active customers1

Directly sourced suppliers

Shareholders

1 MYER one active customers

2  -Modern Slavery Statement 2023

Message from CEO

Our vision is to continue to build trust and shareholder value through strengthened partnerships with our suppliers aimed at driving positive change in improving the working conditions and promoting the human rights of workers in our operations and supply chain.

This is our fourth modern slavery statement, and we continue to make progress. We are pleased to have continued to deliver on our commitment to improve our business practices to ensure that we remain ethical, sustainable, and socially responsible in the way we work.

Our commitment to respect human rights and freedoms of every individual has remained constant. The respect for human rights remains our key focus and priority in delivering a sustainable and socially responsible business.

Priorities include

• Reviewing the effectiveness of our grievance mechanisms in line with the United National Guiding Principles on Business and Human Rights (UNGPs)
• Conducting a deep dive into potential modern slavery and broader human rights risks in our cotton supply chain
• Expanding our modern slavery training program to our suppliers and high risk sectors
• Wage gap analysis to understand disparity in wages paid
• Exploring opportunities to deepen our engagement with our suppliers through capacity building and other outreach

Our ethical sourcing program continues to mature and develop, with continued focus on program governance in monitoring and ensuring remediation of high risk audit findings. A review of buying practices was completed to ensure that it aligns and supports our commitment to source responsibly.

We continue to conduct third party audits of our private label merchandise factories. Through these audits, we ensure that fair wages, safe working conditions, and appropriate labour practices are maintained.

Building on our existing program, we have focused on improved transparency and continue to work on a number of initiatives to strengthen the business in the areas of sustainability, living wages, equal opportunity, and worker empowerment. A dedicated sustainability page outlining our efforts and our private brand factory listing outlining the name, location, type of goods produced and the number of workers that assist us

in manufacturing of Myer owned brands has been published. We have conducted an analysis to understand the wage gap between current worker wages and a living wage for where we manufacture with the view to work with our suppliers to assist them towards paying a living wage.

Myer believes that the issue of modern slavery is complex and pervasiveness and requires a collaborative approach. We will continue to work with our valued suppliers and industry peers and non-government agencies to address the challenges associated with safeguarding human rights.

Despite our progress, we know there is still a lot of work to be done. We will continue to take steps to improve, monitor our approach, encourage transparency, and build on team member knowledge to address risks of modern slavery.

John King

Chief Executive Officer and Managing Director

3  -Modern Slavery Statement 2023

Our business and supply chain

Myer recognises that social sustainability is important to our customers, shareholders, suppliers and team members. We continue to progress our sustainability strategy taking into account business activities and impacts as well as stakeholder concerns and interests.

Myer recognises its obligation to uphold global human rights standards, ethical business practices, and worker safety. Our sustainability strategy focusses on positive change and addressing the impacts, concerns, and interests resulting from our business activities.

Our retail store network comprises of 56 Myer department stores, 39 sass & bide stores1, 80 Marcs1 and 68 David Lawrence stores2 primarily across Australia, excluding the Northern Territory. Sass & bide has retail stores located overseas in New Zealand. Each brand also operates its own ecommerce platform. Our retail network is supported by our Support Office team located in Docklands, Victoria. We have a small sourcing office in Hong Kong that employs 49 employees across locations in China, Hong Kong and a small number in India and Bangladesh for quality control and assurance activities.

Queensland

12 9 16 13

Western Australia

6 5 9 8

South Australia

3 2 5 4

New South Wales

19 11 25 24

														Australian Capital Territory
		Victoria
														2		1		4	4
LEGEND	12		9		19	13
	Myer Pty Ltd
	Tasmania			New Zealand
	Sass & bide
	Marcs	2		0		2	2			0		2		0		0
	David Lawrence

Our approach to modern slavery is company wide, with cross departmental accountability for the implementation and embedding of ethical business practices and initiatives. At the core of our modern slavery risk management is our commitment to ethical business conduct and prioritising practices that continue to uphold worker safety and rights. Our process encompasses the continuous identification and assessment of risks, measures to address identified risks and a transparent disclosure of actions taken. Internal training capacity building for team members in buying and procurement is fundamental to the identification and management of potential presence of modern slavery and related risks. We have adopted responsible sourcing principles which address risks identified and implemented procedures and monitoring to ensure compliance. Due diligence and remediation plans and procedures to address and manage issues of modern slavery have been developed.

1. comprises of standalone and department stores
2. in department store formats

4  -Modern Slavery Statement 2023

Governance

A governance structure is in place to oversee the management of business risks including modern slavery risks. The Myer code of conduct defines the expectations of all team members including company executives. The code requires awareness of, and compliance with, laws and regulations relevant to Myer's operations, including occupational health and safety and employment practices. Myer's Ethical Sourcing Program sets out the minimum standards for responsible and sustainable business practices. All team members, suppliers and business partners must adhere and uphold principles of accountability and ethical business conduct, as set out in our Ethical Sourcing Policy.

The Myer Board is accountable for and approves the Myer Ethical Sourcing Policy and framework, and through the Audit, Finance and Risk Committee of the Board, reviews and monitors effectiveness of ethical sourcing risk processes, activities, and initiatives. The Myer Board is also responsible for the activities undertaken to identify, assess, and address modern slavery risks, including our reporting obligations under the Modern Slavery Act.

Myer's governance framework is underpinned by various policies and procedures. The Chief Executive Officer together with the Executive Management team are directly responsible tor for the execution of the policies and procedures in their area of responsibility. The Assurance team, reporting to the Chief Financial Officer, is responsible for the development, implementation, and management of the broader Ethical Sourcing Program, including modern slavery initiatives and sharing information of modern slavery and broader human rights knowledge across our operations and supply chain.

MYER BOARD

Accountable for endorsing and overseeing the performance and operations, including setting the values and monitoring of compliance with Myer's code of conduct and ethical standards. Myer's Ethical Sourcing Program encompasses the businesses approach to addressing the challenges of modern slavery. Approves our annual Modern Slavery Statement

	BOARD COMMITTEES
Audit, Finance and Risk Committee	Human Resources and	Nomination Committee
Risk management and financial	Remuneration Committee	Nomination criteria's, succession,
reporting, includes reviewing Modern	Remuneration framework and people	and Board appointments
Slavery Statement and recommending	and culture initiatives and schemes
to Board for approval

Policies and Procedures

(includes Code of Conduct, Ethical Sourcing Framework, Risk Management Framework, Whistleblower)

EXECUTIVE MANAGEMENT TEAM REPORTING TO CHIEF EXECUTIVE OFFICER

Deliver strategic direction and objectives as approved by the Board. Responsible for the implementation of the

Ethical Sourcing Program and managing modern slavery risks across the business

BUSINESS AND FUNCTIONAL UNITS

Responsible for adhering to principles of ethical business conduct and compliance to Myer's Ethical Sourcing Program

ASSURANCE TEAM

Oversees and responsible for the design, development and management of the Ethical Sourcing Program with the business

including modern slavery initiatives, social sustainability programs, training and the company's whistleblower program

5 - Modern Slavery Statement 2023

Policies

Myer has a suite of policies and procedures that support its Ethical Sourcing Program to effectively manage modern slavery and broader human rights risks which team members, suppliers and business partners must adhere. Myer is dedicated to adhering to the laws and regulations of the countries where our business is present. Our policies strictly prohibit activities related to modern slavery, and focusses on not only the risks to the business but also preventing and addressing risks to workers and respect for a safe working condition for all.

Key policies that support our Ethical Sourcing Program

POLICY, CONTROL DOCUMENT OR MECHANISM	DESCRIPTION
Code of Business Conduct	Outlines the standards of behaviour and ethical conduct expected of team members
Ethical Sourcing Policy	Principles and framework for the supply of goods and services to the business, and the
	need to implement processes that acknowledge and respect worker rights
Whistleblower Policy	Mechanism for the confidential reporting of unethical or illegal business conduct such
	as modern slavery and the process and management of contacts received
Risk Management Policy	Statement of the management of risks, including social sustainability risks
Discrimination & Equal Opportunity Policy	Guidance on responsibilities and expectations of workplace behaviours
D&EO Complaints and Grievance Procedure	Outlines the process for resolution of workplace behaviour concerns or issues
Supplier Code of Conduct	Sets the minimum expectations of suppliers and factories in ensuring compliance with
	our Ethical Sourcing Policy, health and safety, labour rights
Child and Forced Labour Remediation Policy	Process for the management and remediation of identified child or forced labour

6  -Modern Slavery Statement 2023

Our supply chain

Our supply chain network is extensive, interconnected, and complex with a global supplier network. We do not own or operate any factories that goods are manufactured, and as such we partner with suppliers that share our values towards modern slavery and the need to protect workers and improve transparency of operations. Our sourcing of products and services encompasses multiple suppliers and tiers of the supply chain. We have direct relationships with suppliers that provide final goods for sale for which have a stringent assessment process for onboarding and continued relationships, however these suppliers will generally source services and materials from sub suppliers or secondary suppliers such as inputs and processing facilities such as ginning and spinning mills, raw material suppliers such as cotton farms etc. We continue to collaborate with our direct suppliers to obtain transparency of their supplier network to ensure our ethical sourcing requirements are being met and to identify possible risk areas and exposures.

Our supply chain can be categorised as merchandise (goods for resale) and non-merchandise(non-trade). We source an extensive range of goods for resale, including goods for suppliers who manufacture for Myer private brands as well as goods manufactured for National and Brand Partner suppliers who operate separate proprietary entities with a trademark not owned by Myer.

SUPPLIER TYPE	DESCRIPTION
Private brand supplier	Myer owned brands manufactured under a Myer owned trademark
(direct supplier)

National Brand supplier Third party branded suppliers with local and/or international proprietary rights for resale by Myer where trademark is not owned by Myer

Brand Partner supplier	Third party licensed suppliers selling branded product owned by the licensed business, operating a store-
	in-store business within Myer stores
Non-Merchandise	Goods and services not for resale to customers, engaged to support our operations such as packaging
suppliers	materials, stationery, transportation, marketing, visual merchandise equipment, security, cleaning and
	professional services

Whilst we do not own or control National Brand and Brand Partner suppliers, they are contractually obligated to follow Myer protocol including modern slavery and may be required to report under Modern Slavery Legislation. To increase our visibility of our supply chain, reviews of the management processes of key suppliers both merchandise and non-merchandise through their Modern Slavery Statement is undertaken to assist in identifying possible areas of risks that may have not been recognised and actions taken by the supplier to manage identified risks.

7  -Modern Slavery Statement 2023

Risks in our operations and supply chain

Modern slavery is a severe violation of human rights and describes situations where coercion, threats or deception are used to exploit victims and undermine their right to freedom. Modern slavey takes many forms and includes slavery by 'ownership' and offences such as forced labour, child labour, servitude, debt bondage, deceptive recruitment, forced begging, and human trafficking.

Myer's modern slavery program utilises a risk based and cross-departmental model. Our operations and supply chains are complex and having visibility over the working conditions beyond our direct suppliers continues to be a challenge. Consequently, we recognise that there is a potential exposure to human rights risks. To better understand our risk, we continue to monitor our risk profile through a combination of ongoing assessments including third party audits and advice, supplier questionnaire, grievances raised, industry trends, media reports and collaboration with our suppliers. Our buying, ethical sourcing and procurement teams work closely to monitor new and existing suppliers to ensure any risk exposures are managed.

Ongoing risk assessments allow us to better understand areas of focus and priorities. These assessments consider a number of indicators and the relevant changes both internally and externally, accounting for the nature of the relationship with the supplier and its network, the type and spend of goods or services, the geographic location, the level of human rights protection and vulnerability, and the ongoing monitoring of reputable media reports. They review not only possible modern slavery risks but also general human rights issues and assess the adequacy of controls. In the reporting period, we did not have instances of modern slavery reported within our operations or supply chain.

Identified risks

Our risk assessment identified four key potential slavery types that may exist in our operations and supply chain, and are areas of focus.

• Forced labour - where a person is forced or coerced to work against their will and restricted in movement under threat or punishment and for no or very little pay. There is a risk that forced labour could exist in our extended supply chain in inputs production such as fabric mills, and raw materials
• Child labour - where a child is exploited for personal or commercial gain and exposed and required to work in hazardous conditions or the work is harmful to the child's physical and mental development. There is a risk that child labour could exist in our extended supply chain in inputs production such as fabric mills, and raw materials
• Bonded labour - where a person is required to pay debts (such as from recruitment fees) to their employer or recruiter. Workers are often bound to the employer until the debt has been paid and in most instances such debts are extremely difficult to pay off. There is a risk that bonded labour could exist where subcontracting occurs or in areas where low skilled or migrant workers are employed. Migrant workers are at higher risk of exploitation due to lack of knowledge of local laws, reluctance to raise concerns or questions for fear of losing their job or facing deportation and possible better condition compared to their home country or area
• Deceptive recruitment - where a person is enticed to work using false or deceptive practices about the details and working condition of a job and is later left in a vulnerable position once employment has commenced. There is a risk that deceptive recruitment could occur where third parties use to recruit workers, particularly vulnerable workers such as migrant workers, undocumented workers, or workers from areas with high unemployment or poverty

We have a strict zero tolerance policy towards any form of modern slavery. All subcontracting must be pre-approved by Myer following review and acceptance of a third-party audit.

Cotton

The demand for cotton across the world makes the industry extremely vulnerable to human rights abuses and exploitation. There are well known reports of forced and child labour in the harvest stages of production.

Cotton is one of Myer's primary raw materials, and as such we are aware of the potential exposure to modern slavery and as such have put processes in place to understand the origins of the cotton. We prohibit the sourcing of cotton from locations where there are known or reported human rights abuses such as Turkmenistan, Uzbekistan and Xinjiang.

8  -Modern Slavery Statement 2023

Our modern slavery questionnaire validates this prohibition, and directly calls out these regions to identify if our suppliers or any of their suppliers, including contractors, employ workers from these regions or countries. We are also exploring other avenues to gain a greater understanding of the complex cotton supply chains that exist, to improve our understanding and further validate the sourcing location of cotton used in Myer products.

Supply chain risks

Our risk assessment identified risk areas that modern slavery may exist across operations and supply chains:

Manufacturing	Factory workers may be forced to work with little or no pay particularly for excessive overtime
	and unable to leave the premises. Workers may not understand their rights, do not have
	written agreements or work in poor conditions impacting their health. Workers are often
	subject to excessive working hours and exploitative working conditions. Women and girls are
	overrepresented in garment manufacturing factories and are often subject to exploitation and
	compensated poorly. Migrant workers are at higher risk of being subject to discrimination, lower
	wages, risk of being subject to bonded labour and retention of identity documents
Inputs production	Forced labour in fabric mills, component manufacturers, dyeing plants etc could be present as
	visibility into workers conditions is less transparent as there is no direct relationship. Reports of
	input and textile suppliers subcontracting production of textiles to home-based workers occurs
	to meet turnaround times and save on costs. Home based workers are mostly females who lack
	formal contracts making them vulnerable to mistreatment. Sumangali scheme is a common
	practice in India where women and girls are paid a lump-sum amount at the end of their
	contract and risk losing their accumulated income
Raw Materials	Forced labour and child labour could be present in the production or harvesting of raw
	materials such as cotton, timber, and minerals. The production of raw materials such as cotton,
	wool and leather have been linked with forced labour and child labour. Countries such as
	China, Turkmenistan and Uzbekistan have been reported to have state-imposed forced labour
	to produce cotton
Non-Merchandise	In operations such as cleaning, transportation, security services there is a higher proportion
Services	of migrant workers. There is a risk that workers may not understand their rights and have
	their identity documents or passports confiscated and be subject to forced or exploited
	labour through deceptive recruitment or debt bondage. Migrant workers engaged may not
	understand their rights and have their identity documents or passports confiscated and be
	subject to forced or exploited labour through deceptive recruitment or debt bondage