Governance

The Coles Group Board is responsible for approving Coles’ Human Rights Strategy, Ethical Sourcing Policy and other policies relevant to human rights. The Board receives regular reports from senior management on the status of the targets and priorities of the Human Rights Strategy, our Ethical Sourcing Program and other programs that support Coles’ approach to managing human rights.

Ethical sourcing is also a quarterly item on Board meeting agendas. The Ethical Sourcing Board report includes information on grievance-related matters and investigations, social compliance audits and non-conformances, key human rights risks, stakeholder engagement and worker education events, Ethical Sourcing Program performance, Modern Slavery reporting and implementation of the Human Rights Strategy.

Audit and Risk Committee

The Audit and Risk Committee is responsible for overseeing Coles’ Risk Management Standard and internal risk controls. This includes oversight of ethical sourcing performance, including through review of Key Risk Indicators, the effectiveness of our ethical sourcing risk-management systems and processes, including in relation to modern slavery and processes relating to whistleblower complaints. Ethical sourcing risks are managed as a priority in accordance with our Risk Management Standard.

Executive Leadership Team

Coles’ Executive Leadership Team oversees group-wide identification and response to sustainability risks and opportunities, including human rights and modern slavery.

Chief People Officer

The Chief People Officer oversees the People and Culture function, which includes diversity and inclusion, Indigenous Affairs, and the Ethical Sourcing team. The teams are collectively responsible for key areas of Coles’ Human Rights Strategy, including the overall administration of the Ethical Sourcing Program and Human Rights Strategy.

Chief Legal & Safety Officer

The Chief Legal & Safety Officer oversees areas relating to legal, risk, compliance, employee relations, and health, safety and wellbeing.

Chief Financial Officer

The Chief Financial Officer oversees the Coles Procurement function and is responsible for most procurement activity to source goods and services not for resale.

Chief Commercial & Sustainability Officer

The Chief Commercial & Sustainability Officer oversees the procurement of goods for resale in Coles Supermarkets, including sourcing of Coles Brand goods.

Chief Executive - Liquor

The Chief Executive – Liquor oversees the procurement of goods for resale in Liquor including sourcing of Liquor Coles Brand goods.

Sustainability Steering Committee

The Sustainability Steering Committee oversees group-wide identification and response to sustainability risks and opportunities, including human rights and modern slavery.

Human Rights Steering Committee

The Human Rights Steering Committee is a cross-functional management committee chaired by the Chief Legal & Safety Officer. It includes representatives from across Coles Group including Ethical Sourcing, Risk and Compliance, Procurement, Indigenous Affairs, People and Culture, Sustainability, and Commercial functions. The Committee guides Coles’ approach to managing human rights issues and assessing human rights risk across our operations and supply chain. It also monitors and reports on the implementation of our Human Rights Strategy and related commitments.

Modern Slavery Working Group

The Modern Slavery Working Group is a subcommittee of the Human Rights Steering Committee. It includes team members from key functions across the business and supports modern slavery risk management across Coles’ operations and supply chain.

Diversity and Inclusion Council

The Diversity and Inclusion Council is a cross-functional management committee sponsored by the Chief People Officer. It supports the delivery of Coles’ diversity and inclusion commitments, including those related to the Human Rights Strategy.

Reconciliation Action Plan (RAP) Council

The RAP Council provides strategic oversight of the RAP and other Indigenous Affairs matters. This includes continued efforts to understand and apply the United Nations Declaration on the Rights of Indigenous Peoples and its principles within Coles’ business through the RAP and the Human Rights Strategy.

The Council is made up of Executive Leadership Team members with responsibility for delivering RAP objectives and is co-chaired by Coles’ Head of Indigenous Affairs and General Manager RAP Champion, the State General Manager WA/SA/NT. Membership also includes senior leaders across the business, as well as senior First Nations team members and two external Aboriginal and Torres Strait Islander advisors. This helps ensure Coles’ approach is guided by the voices, perspectives and lived experience of First Nations peoples.

General Manager - P&C Advisory, Ethical Sourcing & Special Projects

The General Manager - P&C Advisory, Ethical Sourcing & Special Projects has oversight of the Ethical Sourcing team and Human Rights Strategy and reports to the Chief People Officer. The role also provides advisory and employee relations support across People and Culture matters.

Ethical Sourcing team

The Ethical Sourcing team is responsible for the day-to-day management and implementation of the Human Rights Strategy and Ethical Sourcing Program. The team works in partnership with functional business units to execute actions.

Management of the Ethical Sourcing Program includes assessing supplier risk, engaging businesses based on risk, assessing performance through self-assessment questionnaires and third-party ethical audits identifying potential human rights risks, investigating allegations of human rights abuses and supporting remediation in line with Coles’ Ethical Sourcing Policy and Program Requirements.

Management of the Human Rights Strategy includes coordinating the Human Rights Steering Committee, monitoring progress against actions and targets, and supporting implementation of relevant work across the business.

The Ethical Sourcing Program is managed by a team of approximately twelve, with additional contracted resources supporting execution of the Program across sites located in Asia and Australia.

Functional business teams

Everyone at Coles has a role to play in respecting human rights and supporting ethical sourcing. Functional business teams are responsible for embedding human rights and ethical sourcing commitments into relevant day-to-day activities and decision making.

Commercial, procurement and supplier-facing teams

Category teams, procurement teams, contract owners, contract managers and product technologists have the direct relationship with suppliers and are responsible for supporting the day-to-day execution of the Ethical Sourcing Program. The teams are regularly updated on the status of the Ethical Sourcing Program and human rights commitments. Ethical Sourcing Program performance information including Key Risk Indicators, is also included in training and guidance to help team members understand their responsibilities and the impact of their actions.

People and Culture team

Dedicated teams in our People and Culture are responsible for ensuring systems and controls exist to manage and protect human rights in Coles’ own operations. Key activities include payroll governance and compliance, remediation, diversity and inclusion, remuneration and reward and partnering with operational teams. The Culture and Inclusion team is also responsible for implementing key areas in the Human Rights Strategy.

Indigenous Affairs team

The Indigenous Affairs team coordinates delivery and progress against Coles Stretch RAP and broader Indigenous Affairs initiatives. The team oversees governance and reporting requirements under the RAP and partner with the business to deliver programs and initiatives relating to Indigenous workforce participation, Indigenous leadership, supplier engagement, cultural knowledge, learning and understanding.

Employee Relations team

The Employee Relations team supports commitments of our Human Rights Strategy relating to appropriate work conditions for our team members. The team manages industrial relations matters and employment related compliance matters that impact Coles’ workforce. This includes managing relationships with relevant unions, negotiating enterprise agreements and providing strategic industrial relations advice and supporting compliance with workplace laws relating to team member rights, pay and entitlements.