The Cotton On Group (‘Group’) takes a zero tolerance approach to any form of modern slavery including servitude, human trafficking and forced labour. We are committed to an ethical and transparent approach to business, ensuring effective systems and controls are in place to safeguard against any form of modern slavery within our business operations or our supply chain.

This statement sets out the steps the Group takes to address the risks of modern slavery and human trafficking in our operations and supply chains, in accordance with the Modern Slavery Act 2015 in the United Kingdom and the Transparency in Supply Chains Act of 2010 in California.

OUR BUSINESS
Established in 1991, the Group is one of Australia’s largest fashion retailers. Our operations consist of over 1,400+ stores in 19 countries and a team of 22,000 people. Our stores are located in Australia, New Zealand, Asia, Africa, Brazil, UK and the USA.
The Group is privately owned and our global support centre is in Geelong, Australia with additional support centres and trading offices located in Melbourne, Australia, Asia, Brazil, New Zealand, South Africa, UK and the USA.
Our operations include eight distribution centres across Australia, New Zealand, United States, South Africa, Singapore, Malaysia, Hong Kong and the United Kingdom. We also distribute products through third parties in Brazil and Thailand. We have joint venture partners located in the Middle East, Philippines, Indonesia and Vietnam.

Over the last 27 years, the Group has grown to seven brands including Cotton On, Cotton On KIDS, Cotton On BODY, Rubi Shoes, factorie, Typo, Supré and its philanthropic arm, the Cotton On Foundation. The Group also owns and operates Southern Cross Shopfitting, employing 70 people in retail store development and construction.

As a global fashion business, we know we have a responsibility to do the right thing, and ensure our supply chain is both ethical and sustainable.
In relation to our supply chain, we source our materials and products from many countries worldwide with the majority of our suppliers located in China and Bangladesh. We’re proud of the great working relationships we have with each of our suppliers and factories, and we continually work closely with them to ensure the environments in which our products are made are safe, fair, sustainable and responsible.

ASSESSMENT
Our Ethical Sourcing Program, including our14 Rules to Trade, was formalised in 2009 and governs the sourcing, manufacturing and supply of our products. As part of this program, all suppliers who manufacture goods for the Group undergo periodic audit assessments, and based on the findings of these audits may be required to undertake corrective actions.

We identify opportunities to maximise our positive impact. We therefore concentrate our efforts on identifying and remediating modern slavery risks related to our operations and the supply chains supplying products for our customers. We recognise that other business relationships may also contribute or be linked to modern slavery risks and endeavor to expand the scope of our program in the future.
Over the last 10 years, we have continued to build our Ethical Sourcing Program through the addition of new resources and initiatives, working closely with suppliers, industry leaders, government and NGOs to ensure our practices are reflective of industry standard.

ACTIONS TAKEN
Through our audit program, corrective action plans and NGO engagement, we have been able to determine the high-risk areas of our supply chain and implement steps to mitigate risk in these areas. For example, we have worked in partnership with a number of suppliers to ensure fair working hours and that any overtime hours are voluntary.

Under our Ethical Sourcing Program, we have implemented stringent policies including the biannual re-signing by each supplier of our 14 Rules to Trade, to ensure suppliers have a clear understanding of the Group’s expectations.

Additionally, to ensure a strong two-way dialogue with our production partners, we hold bi-annual supplier conferences in our sourcing regions. These conferences are an opportunity to talk openly with suppliers on matters relating to ethical sourcing, while providing them with an opportunity to update us on the challenges they face and the steps they are making to bring about positive change.

In addition to these conferences, we hold face-to-face training and education sessions on all areas of human rights with workers and management, undertake audit programs and maintain confidential in-country hotlines for workers to report any misconduct or human rights breaches.

We have a number of internal policies to ensure we are conducting business in an ethical and transparent manner, these include:

o Supplier Agreements: These are signed biannually by our suppliers and outline the expectations for suppliers who work with us. All suppliers including any subcontractors engaged by our suppliers must agree to and abide by our code of conduct.
o Traceability: As we work towards full traceability of our supply chain, it is a requirement that all suppliers disclose the details of their subcontractors as required by the Group.
o Child Labour and Forced Labour Policy: This policy sets out our stance on modern slavery, human trafficking, child labour and forced labour and explains the response and actions in the event that instances are identified.
o Whistleblower Policy: We operate a whistleblower policy so that all team members know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
The Group is also working to trace our full end-to-end supply chain from raw materials to our end products to ensure we have a thorough understanding of our supply chain.

The Group also collaborates with industry wide initiatives such as the Better Cotton Initiative; Action, Collaboration, Transformation (ACT) on Living Wages; Accord on Fire and Building Safety in Bangladesh to inform and support the management of modern slavery risks.

MONITORING AND REMEDIATION
Before engaging with a new supplier, the Group conducts due diligence checks on the supplier. In doing so, the Group maintains an approved supplier list and only these suppliers may be used for any stage of production.

This due diligence checks include a factory assessment and an audit assessment which include a review of working conditions and building safety. In addition to the above, and as outlined in our code of conduct, we require all existing suppliers to confirm to us that:
o There is no inconsistency with the Cotton On Group code of conduct in any area of a supplier’s operations, including subcontractors.
o All employees are paid at least the national minimum wage in line with local labour law/regulations applicable within their country of operation.
o We may terminate the contract at any time should any instances of modern slavery or any other zero tolerance breach of any human rights issues come to light.
We conduct internal training of our buying and sourcing teams to ensure they have a clear understanding of the Group’s expectations for ethical sourcing. In addition, we include training on understanding the signs of modern slavery and what to do if they suspect any form of modern slavery is taking place within our supply chain.

VERIFICATION
We monitor the effectiveness of our Ethical Sourcing Program to ensure that slavery and/or human trafficking is not taking place within our business or supply chain, through:
o Reviewing any reports received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
o Remediation and management reporting of breaches identified by our audit program or confidential hotlines.
o Annual review of our risk assessment process and audit programs to ensure they are relevant and up to date
o Our Group Sustainability Steering committee oversees the ethical sourcing strategy and framework in strict accordance with the businesses values and ethical framework
o Regular training and capacity building for team members, third party auditors and suppliers
o Engagement with stakeholders to maintain a proactive dialogue on our performance
Approval for this statement

This statement was approved on behalf of the Board of Directors on 19 December 2019 by Peter Johnson, CEO.