TRANSPARENCY IN THE SUPPLY CHAIN & MODERN SLAVERY STATEMENTS

1. Policy Statement

1.1 Modern slavery is a violation of fundamental human rights. It can also be a criminal offence. R.M.Williams is committed to reducing the risks of modern slavery in its business operations and supply chains, and to managing incidents where they might occur. This commitment is important to R.M.Williams, as well as its stakeholders, customers and employees both in Australia and internationally.

1.2 'Modern slavery' is a broad term that refers to any situation of exploitation where a person cannot refuse or leave work because of threats, violence, coercion, abuse of power or deception. It also includes conduct that would constitute an offence under existing human trafficking, slavery and slavery-like offence provisions in the Criminal Code Act 1995 (Cth). It includes forms of conduct such as forced labour, debt bondage, human trafficking and child slavery.

1.3 We have zero tolerance of slavery, and we expect the same commitments from all organisations that we do business with.

2. Application

2.1 This Policy applies to: (a) our employees, individual contractors and officers (together, Personnel) at all levels; (b) our contractors, suppliers and other business partners (together, Suppliers); and (c) each business unit of R.M.Williams, which must adopt appropriate policies and procedures to ensure that it is identifying, addressing and mitigating the risks of modern slavery in its operations and supply chains.

3. Responsibility and reporting

3.1 R.M.Williams' board of directors is responsible for putting into place actions to address risks of modern slavery in its operations and supply chains.

3.2 Our Modern Slavery Committee has the primary responsibility of investigating potential and actual incidents of modern slavery in our operations and supply chains, including breaches of this Policy. The Modern Slavery Committee reports and/or refers matters to our board of directors.

3.3 Our Human Resources and Procurement teams are jointly responsible for conducting modern slavery risk mapping and risk assessments of our operations and Suppliers.

3.4 Our legal team has responsibility for ensuring this Policy complies with our legal and ethical obligations.

3.5 R.M.Williams' management are responsible for ensuring that those who report to them understand and comply with this Policy.

3.6 Every individual to whom this Policy applies has a responsibility to prevent, detect and report potential, suspected or actual incidents of modern slavery in R.M.Williams' operations or supply chain to the Director, Human Resources.

4. Compliance

4.1 All Personnel and Suppliers must read, understand and comply with this Policy.

4.2 At all times whilst part of R.M.Williams' operations and supply chain, you must avoid any activity that would be, or could give the impression of: (a) an incident of modern slavery, whether you caused the incident, contributed to the incident or are directly linked to the incident; and/or (b) a breach of this Policy.

4.3 To the extent that it is practicable, R.M.Williams includes contractual provisions in agreements with its Suppliers to confirm that: (a) the Supplier must meet and comply with standards equivalent to R.M.Williams' commitment under this Policy (or, if applicable, take verifiable steps towards compliance) and generally act in a way that is consistent with its values; (b) the Supplier must hold its own contractors, suppliers, representatives and business partners to the same standard; (c) R.M.Williams may require the Supplier to remediate any breach of that standard; (d) R.M.Williams has the right to terminate if the Supplier is in breach of that standard, fails to work towards full compliance with that standard, or fails to take remediation action required by R.M.Williams.

5. Non-compliance

5.1 If any of our Personnel or Suppliers believe, or have a reasonable suspicion, that there has been a breach of this Policy, or that there may be a breach in the future, they must notify the Director, Human Resources in accordance with the procedure in Part 3. If you are unsure as to whether a particular incident constitutes a form of modern slavery, or if you have any concerns about any issue of modern slavery in R.M.Williams' operations or supply chain, you should notify us.

5.2 We will not subject you to any repercussions for genuinely submitting a notification to us in accordance with this Policy.

6. Remediation

6.1 If R.M.Williams determines that there has been a breach of this Policy by a Supplier, we will endeavour to have that Supplier identify and correct that breach. If it is apparent that an individual has suffered harm as a result of such issue, we will seek to ensure that they are 'made good' by that Supplier.

6.2 In the event that we caused or contributed to the risk, we will take action to prevent that risk and remedy any actual impact as appropriate.

7. Breach

7.1 We may terminate our relationship with any Supplier if: (a) the Supplier breaches this Policy, including by failing to comply with a remediation requirement; or (b) an entity working on behalf of a Supplier engages in an act of modern slavery with the Supplier's knowledge.

7.2 Breaches of this Policy by any of our Personnel may lead to disciplinary action in accordance with the RM Williams Code of Conduct. Serious breaches may result in immediate dismissal.

8. Policy Amendment

8.1 This Policy cannot be amended without approval of R.M.Williams' board of directors. The R.M.Williams board of directors is responsible for overseeing the company's ethical sourcing and modern slavery commitments and will review this Policy regularly to ensure it continues to evolve and reflect community expectations and ensure that R.M.Williams is complying with all its legal obligations.

 

SUPPLY CHAIN

Integrity is fundamental to the R.M.Williams Company. Integrity means being Honest and Truthful to our Company, our employees, supply partners and customers. R.M.Williams is committed to the highest standard of business conduct in our relationship with each other our customers and suppliers.

This requires that we conduct our business in accordance with the applicable laws and regulations whilst always maintaining the focus on our honesty and strong moral principles. R.M.Williams is committed to upholding the Australian Modern Slavery Act. whilst undertaking annual Factory Audits which are conducted by an International Recognized Auditing Company on our behalf to ensure that not only R.M.Williams, but all our suppliers abide by the laws and regulations of each country they conduct business in, as well as this they must agree to regular inspections by the appropriate R.M.Williams employee representatives.

All R.M.Williams suppliers are required to sign the following, The Suppliers Code of Conduct, and The R.M.Williams Suppliers Agreement stipulating the terms and conditions required to be a supplier. Using these key principles helps each of us in this endeavour by providing a statement outlining the fundamental principles, key policies and procedures that govern the conduct of our business. The way we deal with our customers and suppliers builds long-term trust and ultimately determines our success. We will endeavour to deal fairly with Companies, Customers and Suppliers. We will never take unfair advantage of others through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any other unfair dealing practices. For a list of our Suppliers who have followed the above and have been approved as official suppliers to R.M.Williams click here.