Human Rights

We make every effort to operate our business in a way that demonstrates our commitment to respecting human rights. We have been a signatory to the UN Global Compact since 2019 and are committed to respecting the following international standards relating to human rights:

• United Nations’ (UN) Universal Declaration of Human Rights
• UN Guiding Principles on Business and Human Rights (UNGPs)
• International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work

We are also committed to respecting the rights of all workers, including vulnerable groups such as women, children and migrant workers, and ensuring our workplaces are free from discrimination.

Our commitments related to human rights are reflected across policies and strategies including our Code of Conduct, Ethical Sourcing Policy, Human Rights Strategy, Modern Slavery Statement and relevant policies such as the Diversity and Inclusion Policy and Whistleblower Policy.

Our Human Rights StrategyHuman Rights Strategy, View PDF, file size 9.3MB (Strategy) provides a framework to prevent harm to people in, or affected by, our operations and value chain, and foster a culture that embraces diversity, inclusion and equality. This includes fair and safe working conditions, responsible purchasing practices and protecting the rights of people across our operations and value chain, especially the most vulnerable.

We have progressively taken steps to implement these measures and understand that the work we do to protect human rights is an ever-evolving process, requiring continuous improvement and innovation. We first launched our Strategy in 2020 and then published a refreshed version in 2024 building on the foundations of the 2020 strategy. The Strategy will be refreshed and formally reviewed again in 2027.

Our refreshed Strategy was developed over an extended period, in partnership with an external consultant with extensive experience in human rights for business. The Strategy incorporated wide engagement with internal and external stakeholders (including team members, suppliers, non-government organisations, union representatives, academics, and representatives from potentially affected stakeholders), as well as detailed assessment and research on best practice.

Our Strategy is underpinned by four strategic ambition areas, with key priorities, targets and action plans to support achieving our goals in our operations and supply chains by the end of FY27. We have a detailed plan and multi-year program which includes key outcomes and measurable targets under each priority. Each outcome area has specific actions assigned which includes timings, the responsible team or individual, and key monitoring and data gathering considerations. We also monitor our Strategy implementation through reflection and periodic review – using learnings to adjust and improve. We report on the implementation of these actions and progress through the Human Rights Steering Committee, and regular reports to the Board and Executive Leadership Team.

Through the development of the refreshed Strategy, we identified our salient human rights issues, with these issues being the areas of our operations and supply chain that could cause the most severe harm to people. Identifying our salient issues supports us to focus on and prioritise key areas for action. The process to identify and assess our salient human rights issues included:

• Mapping our operations and supply chains to identify affected stakeholders and potential impacts on human rights
• Engagement with affected stakeholders to seek their perspectives on key issues and priorities to help inform the salience assessment
• Consideration of emerging global risk factors such as climate change, geopolitical changes and the increased role of technology. Risks to people and human rights were then assessed for scale, scope, and likelihood of potential or actual human rights impact in line with UN Guiding Principles on Business and Human Rights (UNGP) guidance.
• A prioritisation exercise based on attribution, leverage and existing mitigation or risk controls, followed by a positive impact assessment to identify opportunities to advance human rights.

Following this process, eight salient human rights issues were identified across our operations and supply chain including:

* Where we refer to 'appropriate work', the ILO refer to it as ‘decent work’. Decent work’ is defined by the International Labour Organization as work that is productive, safe, dignified and where worker’s rights are protected.

Coles’ process for identifying and managing risk in our operations and supply chain at a Group level is set out in our Group Risk PolicyGroup Risk Policy, View PDF, file size 184KB and Risk Management Standard.

Further information on how we manage and address material risks, is in our Corporate Governance StatementCorporate Governance Statement, View PDF, file size 2.2MB and Annual ReportAnnual Report 2024, View PDF, file size 14.2MB.

Our Human Rights Strategy is integrated within our strategic approach to sustainability, diversity and inclusion, and First Nations (Indigenous) engagement. We will continue to work to integrate it into existing strategies, aligning key work plans and adjusting key policies and procedures. For our operations, we have a number of policies and programs in place to address human rights and monitor our progress – further information on this is outlined in our ‘human rights in our operation’ section. For our supply chain, we continue to monitor and address human rights through our Ethical Sourcing Program (productsEthical Sourcing Program Requirements - Products, View PDF, file size 347KB / servicesEthical Sourcing Program Requirements - Services, View PDF, file size 264KB).

Our Human Rights Strategy and supporting commitments have been endorsed by the Coles Group Board and Executive Leadership Team. The governance structure for management of human rights and ethical sourcing is integrated into the broader governance of our business and is set out below:

We are committed to respecting human rights in the way we do business. We focus on team members, customers, contractors, suppliers and their workers, as well as the wider community. We embed respect for human rights in our thinking and decision-making processes and strive to understand, identify and remedy risks to our people, and those affected by our business. As outlined in our Human Rights Strategy, our vision is to foster a safe, inclusive and respectful workplace, and for our team members to have appropriate work, pay and a workplace where they feel safe to come to work and be themselves.

Below outlines some of the areas we have taken steps, and continue to take steps, to embed human rights across our business including:

• Team member working conditions
• Data privacy
• Team member health and wellbeing

Other actions to address human rights in our operations are described in the:

• Diversity and Inclusion strategy, where the FY24-27 strategy drives our efforts in five focus areas including gender equity, and Indigenous engagement.
• Stretch Reconciliation Action Plan (RAP) which outlines our commitments and actions relating to human rights and First Nations people in Australia.

We monitor human rights and ethical sourcing in our operations relating to in-scope services such as logistics, transport, cleaning, trolley collection and store infrastructure installation services. We do this through our Ethical Sourcing Program – further information is in our supply chain section.

Team member working conditions

We care for our team members and treat them fairly. One of our priorities (and salient issues) in our Human Rights Strategy is providing team members with appropriate work and conditions. In Australia, working conditions are heavily regulated and are governed by the Fair Work Act 2009 (Cth) (Fair Work Act). As a large retailer, most of our workforce are operational team members who work in our stores, distribution centres, provide services to our customers, and conduct warehousing and logistics activities.

Working conditions for these team members are predominately regulated through long standing industrial instruments that have been negotiated with the relevant unions. In FY24, just over 86% of our team members were covered by an enterprise agreement and we estimate that just over 30% of our team members are union members. We respect our team members’ rights to freedom of association and collective bargaining; we continue to work closely with the relevant unions and team members’ representatives.

Wage-related regulations in Australia can be complex to navigate, as there are different terms and conditions that may apply to workers depending on their industry or role. We have processes in place to regularly review, set, monitor and address wage-related aspects to ensure our team members are paid their correct entitlements, including in full and on time. Our enterprise agreements and employment contracts provide for higher wage rates than the national minimum wage or applicable Award minimum rates.

As written in their employment contracts or enterprise agreements, our team members are not required to work more than 40 contracted hours on average per week. Reasonable additional hours can be worked in accordance with the Fair Work Act. A team member can refuse to work additional hours if the request is unreasonable. Operational team members covered by an enterprise agreement or modern award are remunerated for working additional hours (for example, our enterprise agreements provide for payment of overtime at overtime penalty rates and requests to work overtime must be reasonable).

We also have procedures in place to ensure that we comply with legislative requirements regarding the legal age of employment in Australia to ensure there is no employment of individuals under the age of 15, or under the local legal minimum working age or mandatory schooling age, whichever is the higher. Processes are in place to verify these requirements during recruitment.

Data privacy

We believe that privacy is a fundamental human right. We aim to be transparent and respectful regarding the use of personal information of customers, team members, suppliers, and partners. We are committed to the protection of their privacy and ensuring compliance with our obligations under privacy laws. We collect, hold, use and disclose personal information so that we can provide goods and services to our customers, improve and personalise our services for these individuals, and operate our business effectively.

Coles Privacy Policy applies to Coles’ Group Limited and its subsidiaries except as noted in the Privacy Policy. The Privacy Policy provides information about the personal information we collect and handle in respect of customers, members of the public, visitors to our websites, and users of Coles apps, social media, and other digital services.

The Privacy Policy is implemented through our privacy framework, which includes privacy policies, training, compliance resources and privacy impact assessments enabling compliance with our obligations under privacy laws. The framework is supported by a robust governance structure, which includes the Data Governance Council, consisting of senior managers across the functional areas of Technology, Risk & Compliance, Cyber Security, Data and Intelligence, Digital, Customer and Legal within the Group. We have a Privacy Officer, and a Privacy team lead by a Group Privacy Manager and make use of external resources who provide advice on a range of issues, including domestic and global privacy trends.

Team member health and wellbeing

At Coles we believe that protecting human rights and supporting wellbeing go hand-in-hand. We are deeply committed to promoting the wellbeing and mental health of our team members. We understand that a supportive and healthy work environment is essential for both personal growth and organizational success. That’s why we have developed comprehensive initiatives designed to protect, promote, and respond to the mental health needs of our team members, and we strive to create a compassionate, supportive, and respectful work environment where every individual can thrive.

Our Mental Health Framework: Protect, Promote, and Respond

To create a caring workplace where mental health is respected and protected, we introduced a Mental Health Framework, which is centred on three key pillars:

Protect: We work proactively to prevent psychological harm by promoting a work environment where mental health is respected and protected.

Promote: We recognise and enhance the positive aspects of work that contribute to good mental health. We actively encourage positive mental health through workplace programs that promote strategies to improve and drive team member wellbeing.

Respond: We provide workplace programs that aim to build capability to respond and support those experiencing mental ill health or distress ensuring team members have access to the resources they need to recover and thrive.

This framework outlines how Coles manages psychosocial risks and outlines a comprehensive suite of wellbeing initiatives that every team member has access to support their safety and wellbeing.

Employee Assistance Program (EAP)

Our Employee Assistance Program (EAP) supports our commitment to mental health and wellbeing. This program offers free, confidential 24/7 counselling support to all team members and their immediate family members, providing crisis intervention and ongoing support for personal and professional challenges. Beyond immediate support, the EAP also focuses on proactive wellbeing initiatives, offering resources for lifestyle and nutrition, financial wellbeing, and family and managerial support.

The EAP includes specific helplines for diverse needs, such as:

• First Nations helpline
• LGBTIQ helpline
• Domestic and family violence helpline
• Aged care support helpline
• Spiritual and pastoral care
• Sexual harassment helpline
• Youth, student, disability, and carer helplines

To make access easier, we have launched an EAP app, which allows team members to book appointments, access wellbeing education, and listen to podcasts on various mental health topics. This ensures support is always available.

Wellbeing Portal: your resource for health and wellness

Our Wellbeing Portal is a dedicated space for health and wellness resources. This portal contains an extensive collection of tools, videos, tip sheets, and webinars that team members can access 24/7. From managing stress and physical health matters to building resilience, the portal empowers our team members to take control of their health and wellbeing. It also includes our monthly digital/online wellbeing magazine, which features expert insights and practical tips to promote a healthy work-life balance.

Mental health training for leaders

We understand the crucial role leaders play in fostering a mentally healthy workplace and providing support for our team members. That’s why we’ve designed a specialized Mental Health Training program for all leaders. This program equips leaders with the skills to recognize signs of mental distress and provides them with practical strategies to offer appropriate support. By ensuring our leaders are well-prepared to handle mental health challenges, we create a culture where team members feel listened too, understood and supported.

Wellbeing campaigns and initiatives

We are dedicated to encouraging an environment where open conversations about mental health and wellbeing are part of our culture. Our annual Wellness Week and RUOK Day campaigns are two key initiatives that highlight the importance of mental health and wellbeing awareness and the importance of sharing our own vulnerabilities. Whilst we have the right programs in place, the right policies, and provide leaders with the right training, the cultural aspect of making it acceptable to talk about mental health issues and celebrating is what truly changes the culture.

Strategic partnerships for mental health

We are proud of the partnerships we have built to enhance mental health support for our team and the wider community. As a founding member of the Corporate Mental Health Alliance Australia, we collaborate with like-minded businesses to share best practices and drive meaningful change in workplace mental health. Together, we are committed to ensuring mentally healthy workplaces for everyone.

Additionally, we continue our partnership with The Resilience Project, which focuses on fostering gratitude, empathy, and mindfulness. This collaboration provides our team members with access to valuable resources and tools to help them build resilience and enhance their overall wellbeing.

We also support The Resilience Project Schools Program, which aims to provide high-need schools with essential mental health and wellbeing resources. Each year, we help 20 schools integrate The Resilience Project’s teachings into their curriculum, positively impacting the wellbeing of young people and setting them on a path to lifelong mental health.

Ethical Sourcing overview

We acknowledge that protecting human rights in supply chains is a global matter and we understand the important role we have in safeguarding human rights within our complex supply chains. Our primary tool to identify and address human rights risks and impacts in our supply chain is our Ethical Sourcing Program (Program).

Our Program commenced in 2005 and has continued to grow and evolve. In FY24, over 1,900 tier one and two suppliers were captured by the scope of our program, with over 1,200 audits conducted across our supply chain. We define tier one suppliers as those we have a direct contractual relationship with and tier two suppliers as those who provide either products, processes or services to the tier one suppliers to meet their contractual commitments.

Our Ethical Sourcing PolicyEthical Sourcing Policy, View PDF, file size 341KB (Policy), together with our Program Requirements (productsEthical Sourcing Program Requirements - Products, View PDF, file size 347KB / servicesEthical Sourcing Program Requirements - Services, View PDF, file size 264KB) set out our expectations of our suppliers regarding labour rights, human rights, environment, health and safety, and business integrity.

Our Ethical Sourcing Policy is aligned with key internationally recognised frameworks and instruments, including the Universal Declaration of Human Rights, ILO Declaration on Fundamental Principles and Rights at Work, the UN Guiding Principles on Business and Human Rights (UNGPs) and the Ethical Trade Initiative (ETI) Base Code. These policies and requirements are also reviewed annually to ensure we are aligned with best practice.

Suppliers agree to adhere to our Policy as part of their supply contract with us. We monitor supplier compliance with our Policy through our Program. While it is impractical for us to monitor compliance for every supplier within our extended supply chains, our Policy is included in our contracts with our direct suppliers, and we require those suppliers to cascade these requirements to their own suppliers and ensure they are integrated in relevant supplier operations and agreements.

We identify and map our in-scope tier one and two suppliers for Coles Own Brand products, fresh produce (both own brand and proprietary), and selected Goods not for resale (GNFR) products and services. We disclose the country and product categories in our Modern Slavery Statement. Suppliers in scope of our Program for Goods for resale (GFR) and GNFR including services are shown in the diagram below.

1. Fresh produce means unprocessed fruit, vegetables, and flowers, and includes Coles Own Brands as well as proprietary brands.

2. Produce packing includes packing sheds, as well as farms that pack produce on site. In cases where the farm harvests produce then sends it to a packhouse, only the packhouse and supplier of final products are in scope of the program.

3. Packing/manufacturing refers to sites that manufacture or pack Coles Own Brand products into their final retail form.

In FY24, more than 97.5% of fresh produce (excluding floral, nuts, dried fruit, sauces, dressings and packaged salads), by volume, was sourced from suppliers in Australia, and 100% of Coles Own Brand fresh pork, chicken, turkey, duck, beef, lamb, milk and eggs were Australian grown.

Coles also has a limited range of Coles Own Brand apparel sold under the Mix brand, which we source from overseas. We work with apparel suppliers to build relationships throughout the supply chain and monitor performance against our Policy and Program Requirements. We disclose the names and locations of our Own Brand apparel merchandise factories on our website, available hereColes Mix Apparel Sites, View PDF, file size 46KB.

Risk assessment, due diligence and monitoring

Our supply chain is complex, comprising of numerous suppliers and workers who contribute to producing the goods and services we use and sell. In line with our commitment to the UNGPs, we implement human rights due diligence for our supply chains. We take a risk-based approach to managing our supply chain, focusing our resources on areas with a greater likelihood of labour and human rights issues and where we have leverage to affect change. Through our Program, we also work collaboratively with our direct suppliers, and selected suppliers within our extended supply chain, to continuously improve performance and to address any issues when they arise.

We strive to understand where the risk to people is, the root cause and how to prevent the risk from becoming an issue. We use a number of tools to identify, assess and monitor human rights risks and impacts in our supply chains, including:

• our salient human rights assessment
• new supplier screening
• supplier site visits
• independent third-party audits of suppliers
• worker voice feedback
• review of grievance mechanism complaints
• public reporting on key human rights issues
• information from tools such as Supplier Ethical Data Exchange (SEDEX), Fair Farms, SAP Ariba and Dow Jones Risk and Compliance

Suppliers that are in scope of our Program (including suppliers within our extended supply chain) are required to complete risk assessment questionnaires to help us understand their activities and potential ethical sourcing risks. This also includes monitoring of GNFR suppliers providing selected services used in our operations such as logistics, transport, cleaning, trolley collection and store infrastructure installation services. The questionnaires include an assessment of the supplier’s inherent risk based on location, sector, and industry, as well as site-specific questions around workforce composition, working hours, contractual arrangements, and recruitment costs.

Depending on their risk classifications, in scope tier one and two suppliers may be required to undertake a desktop or site audit, administered by Coles or an independent third party. Audits include reviews of relevant documentation, site tours, private and confidential worker interviews, and closing meetings with site management to discuss audit findings and corrective actions. Worker interviews include targeted questions to explore labour risk areas, including modern slavery indicators such as recruitment fees, holding of personal identity and passport documents, accommodation, and deductions of wages and benefits. Audits can be announced, semi announced or unannounced. We use ethical audits to help identify and monitor potential human rights issues in our supply chain; once a risk to people is identified, we work to mitigate, remediate or help prevent it. For example, in-scope suppliers with non-conformances from ethical audits must address and remediate these in line with our Program Requirements, which we monitor and support them in doing.

The Ethical Sourcing team also conduct supplier site visits as part of monitoring and understanding risks, and when we receive grievances via our grievance mechanism channels, we conduct specialised investigations to understand the situation further. We monitor our audit and grievance mechanism data to both help identify and analyse common findings and trends and identify opportunities for action, including training and capacity building, and assess the effectiveness of our Program.

Our risk profile is not static, as risk changes our operating environment evolves, resulting in changes to the risk we face as a business. Due to this, we regularly review risks and the measures to mitigate risks, to support the delivery of our purpose and strategy. We also understand that human rights due diligence is an ongoing process that requires particular attention at different times in our business activities. For example, each time we enter new areas of business, we engage the suppliers to understand what countries or sectors the products, materials, or services are sourced from, as these may have an impact on human rights. Prior to commencing new engagements with suppliers, we conduct due diligence as part of our Own Brand Product Development (OBPD) process for GFR suppliers supplying Own Brand products or as part of our Third-Party Risk Management process for GNFR suppliers. This helps us embed human rights considerations in our business processes and ensure that our expectations for human rights, labour rights, health and safety, and environmental standards are addressed at the earliest stages of the third-party selection process.

We take a range of steps to assess the effectiveness of our response to address human rights, including regularly reviewing our Policy and governance frameworks, monitoring our risk profile and undertaking performance monitoring of our Program. Our Policy and Program Requirements are reviewed regularly in consultation with stakeholders to align with changes in regulations and expectations and reflect best practice. Coles’ Board reviews and approves any changes to the Policy.

Coles understands that our team members and suppliers play a major role in helping us to identify and prevent ethical sourcing and human rights risks in our operations and value chain. To enable our team members and suppliers to support our work we provide relevant training, as increasing their knowledge is an important part of our human rights strategy. Our training program complements broader engagement with other stakeholders including our engagement with suppliers’ workers. We assess the effectiveness of our training through engagement with team members and supplier participants, such as through surveys to identify knowledge gaps.

Suppliers

Investing in suppliers’ capacity building and training is key to driving continuous improvement across our supply chain. We recognise that access to training is an important tool to increase supplier capability, therefore we are committed to working with our suppliers to help them understand the human rights risks and how to meet their obligations set out in our Ethical Sourcing PolicyEthical Sourcing Policy, View PDF, file size 341KB (Policy) and Program Requirements (productsEthical Sourcing Program Requirements - Products, View PDF, file size 347KB / servicesEthical Sourcing Program Requirements - Services, View PDF, file size 264KB).

Each year we run a range of training sessions for our suppliers in Australia and overseas. Training topics are determined by conducting a training needs analysis identifying the risk areas that are impacting our operations and supply chain. Additionally, the Ethical Sourcing team provide one-to-one coaching and guidance to suppliers on the requirements of the Program.

Further information on our training program including past training sessions is available on the Coles Quality Academy, a platform specifically designed for training our suppliers.

Vendor capacity building program

To build the capacity of our suppliers in China who manage the largest volume of tier two sites for Coles outside Australia, we have partnered with a specialist consultancy. The partnership includes conducting a deep dive analysis into their social compliance management program, enabling them to improve their ethical sourcing capabilities and equip them to better manage and address ethical sourcing and human rights risk further down our supply chain. More information on this can be found in our FY23 Modern Slavery Statement2023 Modern Slavery Statement, View PDF, file size 5.0MB.

Team members

We have mandatory training for Board members and selected team members, including the Executive Leadership Team and Senior Management. The training incorporates key areas of human rights including ethical sourcing and modern slavery. We also continued our rollout of our specific training on our Ethical Sourcing Program (Program) to relevant functional team members including procurement, product technologists, category managers, etc.

In 2024 we refreshed our Human Rights Strategy; to support the roll out, we have developed a mandatory Human Rights training module for all team members, including Board members and the Executive Leadership Team, to complete. The purpose of the training is to educate team members on how the strategy will impact their role and ensure we meet our commitments.

Coles also provides targeted training to team members in key roles including disability confidence, workplace behaviour (including bullying, discrimination, harassment, sexual harassment, and victimisation), mental health and wellbeing, and anti-bribery and corruption.

We understand that creating meaningful change to address human rights and modern slavery will take time and to be successful requires a multi-stakeholder approach. We regularly engage with our team members, customers, suppliers, government and non-government organisations to understand the diverse perspectives of our stakeholders and to inform and continuously improve our approach and response to human rights issues.

Working with suppliers

Coles will always treat suppliers fairly and with consideration of individual circumstances. Where we are made aware of issues in our supply chain, we endeavour to work with our suppliers to ensure the issue is remediated for affected parties.

If a supplier is unable or unwilling to comply with the Ethical Sourcing Policy (Policy) and Ethical Sourcing Program (Program) Requirements, or refuses to participate in the Program, Coles reserves the right to exercise its rights under the relevant supply or services agreement which may include suspension of supply or termination of the agreement where compliance with the Policy and Program Requirements is not rectified.

Worker voice

It is important to listen to the voices and perspectives of potentially affected stakeholders. We have trialled independent worker voice platforms since 2021 in different supply chains to gain insights directly and anonymously from workers about their working conditions and wellbeing. This has included SEDEX-led Direct Worker Voice trials at supplier sites in our Australian fresh produce, meat and bakery supply chains, and in some supplier sites overseas. In these trials, surveys are used to collect insights from workers including questions relating to payment of recruitment fees, health and safety, working hours and wages. To help facilitate meaningful engagement, we also provided access to the survey in languages commonly spoken by the workers in the sites and industries we are engaged with.

Coles works with a small number of last mile delivery suppliers to provide groceries and liquor items to our customers. In FY23, we engaged with our last mile delivery suppliers to review driver earnings and conduct engagement with drivers on wages and wellbeing. More recently in FY24, we worked with New Zealand company Ask Your Team, another independent worker voice platform, to trial real-time surveys for workers at supplier sites in Australia and New Zealand relating to wellbeing and engagement on matters such as working hours and conditions, equality and respect, and workplace health and safety.

In our own operations, we regularly seek feedback from team members across the business, including through engagement surveys. The surveys offer team members the opportunity to communicate anonymously with leaders of the business, offer suggestions or ideas, and provide feedback on what’s working well and where the opportunities lie across the business.

Working with unions

Since 2019, Coles and three of the Australian’s largest workers’ unions (the Shop, Distributive and Allied Employees Association (SDA), the Transport Workers Union (TWU) and the Australian Workers Union (AWU)) have partnered in the Ethical Retail Supply Chain Accord (Accord). The Accord was set up to improve and protect the rights of all workers regardless of their visa and employment status. There is a focus on Australian farming activities, with approximately 95% of the fresh produce we sell coming from this sector.

Members of Accord regularly meet to plan worker education events, collaborative projects and any concerns raised impacting workers. The Worker Education events give us the opportunity to include the voices of affected workers so we can understand the human rights risks and impacts in our supply chain. Additionally, in the past six years under the Accord, we have collaboratively worked on several projects, for example: labour hire providers, and accommodation standard.

In addition to the Accord, in December 2020, Coles and the Transport Workers Union (TWU) signed a charter on standards in road transport and the gig economy focusing on safety, driver education and mental health.

For more details on collaboration and stakeholder engagement, please see page 38 and 39 of our 2024 Modern Slavery Statement2024 Modern Slavery Statement, View PDF, file size 14.5MB.

As part of our broader human rights strategy, in line with the United Nations Guiding Principles (UNGP), we are committed to providing an effective and accessible grievance mechanism to receive and manage concerns that may impact individuals within our own operations and supply chain. This is fundamental to ensuring that all people, internal and external to Coles have an avenue to raise their concerns.

Coles respects the rights of individuals and human rights defenders to confidentially and/or anonymously raise complaints or concerns without fear of retaliation. Coles will not tolerate retaliation, intimidation, harassment, discrimination, or victimisation against any individuals, organisations or their representatives who raise concerns, and will act against any parties who engage in any manner of retaliation. Coles is committed to protecting the rights and wellbeing of individuals who raise a grievance through our mechanisms. When a grievance is raised in good faith, the reporter will not face adverse consequences, even if they were mistaken about the concerns. Alongside this commitment, eligible reporters are protected by the law.

Coles provides a channel for individuals, both within our own operations and supply chain, to raise concerns via Coles STOPline or through Coles’ Protected Disclosure Officers. Grievances may also be raised through our other channels including directly to the Ethical Sourcing group email inbox, third-party stakeholders such as unions and non-governmental organisations (NGOs), media or via Coles’ third-party audit program. Beyond our own operations and supply chain, these channels are also available to any affected stakeholders including those external to Coles such as community members where adverse impacts have been caused by, contributed to, or directly linked to Coles.

Coles communicates the available channels through various methods, including via regular supplier training, posters in Coles’ lunchrooms, in-house training with relevant team members, worker education events, unions, through our audit program (auditors are given business cards and posters), the ethical sourcing team site and via policies.

Coles’ Whistleblower PolicyWhistleblower Policy, View PDF, file size 270KB encourages reporting of any suspected unethical, illegal, fraudulent, or undesirable conduct within our own operations and supply chains, including suspected adverse impacts on people, communities, or the environment.

All human rights grievances raised through any of these mechanisms will be addressed and assessed through our Investigation Protocol or Modern Slavey Incident Protocol, dependent of the severity of the grievance raised. Since grievances can vary in complexity, geographical location or severity, our protocols may be adjusted depending on the circumstances. However, where possible, we aim to complete our preliminary review of the grievance and acknowledge the reporter within 14 days. Coles endeavours to conduct a comprehensive investigation without delay and will also share the outcome of the investigation with the party making the complaint.

Using any of Coles’ grievance mechanisms channels does not prevent reporters from accessing other remediation processes. Coles’ is committed to supporting access to state-based judicial or non-judicial mechanisms (it is not required for the reporter to waive their legal rights) and will collaborate to ensure a fair resolution of the grievances raised. If required, we may ask the reporter to maintain confidentiality during the investigation to preserve the veracity of the investigation, however, there is no requirement that they accept confidentiality provisions (for example non-disclosure agreements). We also support the work of and are open to working with the Australian National Contact Point (AusNCP).

Managing grievances

All human rights supply chain grievances are managed and investigated by the Coles Ethical Sourcing Team. When necessary, an independent third-party will be used to investigate. Additionally, the Head and Group Ethical Sourcing Manager are updated on all investigations regularly, the Coles’ Board are updated on a quarterly basis, and all investigations are reported in the Modern Slavery Statement annually.

Since the establishment of the ethical sourcing program, we have investigated over 80 grievances; this excludes the thousands of non-conformances also reviewed and closed annually through our audit program. Additionally, through STOPline, we have received over 700 grievances from our own workers in FY24, these are managed and investigated by our P&C function.

Below is a breakdown of the method used by reporters to raise their human rights grievances in the past financial years:

To enable improved visibility for the Ethical Sourcing team, additional monitoring will be conducted of in-scope sites who are subject to partially unsubstantiated or unsubstantiated investigations. Specifically, relevant site(s) will be added onto a ‘watch list’, that will have enhanced due diligence checks conducted by the Coles’ Business Protection team. Additionally, the Ethical Sourcing team will conduct annual site visits if appropriate.

To better understand the most frequent areas of concerns raised via our grievance mechanisms, all grievances are mapped against the ETI Base Code. The mapping enables us to focus on the areas of concern, assisting us to tailor the type of support required for our suppliers (for example tailored training). This monitoring has enabled us to strengthen our processes to ensure we have the right systems in place to handle all grievances raised, for instance; we have developed a Modern Slavery Incident Protocol (see modern slavery statement for further information) and an Investigation Protocol.

The most frequent areas of concern raised are accommodation standards, excessive deductions, and workplace bullying. A table of all human rights related grievances received from the supply chain, is available hereHuman Rights Complaints, View PDF, file size 85KB.

Suppliers

It is important to Coles that our suppliers share the same commitment as Coles in ensuring that workers, persons acting on their behalf, community members and any other stakeholders in their supply chains have effective and confidential mechanisms to raise grievances in their local language. Therefore, we expect our suppliers to communicate with and put in place policies and management systems to ensure that, their own suppliers and sub-suppliers involved in producing or supplying Coles’ products or services, adhere with these requirements.

We understand the challenges associated with providing effective and accessible grievance mechanisms, particularly due to socio-cultural and language barriers. When suppliers provide their own grievance mechanisms, we expect them to consult potential or actual users on the design, implementation, or performance of their mechanism to ensure effectiveness and accessibility to the individual it is targeted at. To support suppliers’ knowledge on grievance mechanisms, Coles in FY25 held an online webinar providing practical approaches how to implement, embed and review the grievance mechanism they have in place. The training is available here.

Assessing the effectiveness of our grievance channels

We understand the importance of ensuring our grievance mechanisms are effective, in line with the expectations set out in the UNGPs. Effective grievance mechanisms should be: trusted, accessible, communicated, predictable, equitable, transparent, rights compatible, a source of continuous learning and based on engagement.

To ensure we are assessing the effectiveness of our own grievance mechanisms, in FY24 we completed a full review of our grievance tool against the expectations outlined by the UNGPs. The review was done in conjunction with several stakeholders including suppliers, supply chain workers, internal teams, unions, NGOs and industry specialists. This engagement has led to the final design of the Ethical Sourcing STOPline grievance mechanism, which has been adapted and updated based on the observations and analysis of interactions (this included interviews, meetings, roundtable review, trial grievances raised, and training) with different stakeholders as listed above.

The following changes were made following the review and interactions:

• We aligned to one third-party grievance mechanism (STOPline) for all individuals, including those in our own operations, our supply chain, and the community
• We developed a visual poster with more pictures than words, to aid in advertising the grievance mechanism for workers in our operations and supply chain that have limited English
• We developed a specific QR code for workers in our operations and supply chain to raise their grievances, offering multiple languages in a simplified form
• We developed an Investigation Protocol, so there is a documented process to follow to ensure adequate steps are being taken for each grievance raised

In addition to the changes above, in FY22 Coles invested in an experienced investigator to strengthen the process of how grievances are managed which included consistent follow-up with reporters to provide progress updates on the cases.

Grievance channels

In Coles, grievances can be received through various channels, below we describe the most utilised channels:

Coles STOPline

Coles STOPline is a confidential service run by an independent third-party that all stakeholders within Coles’ own operations and supply chain, including team members, suppliers, workers, contractors, and community members can use to raise concerns or make complaints. It can be accessed in multiple languages with translation available on request and a language setting within the Mobile App or via the QR code.

As part of the above review, we developed a separate process flow chart to help demonstrate how complaints raised via STOPline are received and handled by Coles. Importantly, the flow chart explains how the reporter is informed throughout the process, which allows them the opportunity to withdraw the complaint if they wish to do so and to challenge the process or outcome if they are not satisfied.

Audits

Ethical audits assess modern slavery risks in a range of ways, including through document reviews, site tours and private and confidential worker interviews. Worker interviews in particular provide an opportunity for individuals to raise their concerns in a confidential manner.

Direct to the Ethical Sourcing Team

Individuals can directly contact the Ethical Sourcing Team to raise any grievances related to human rights or labour conditions. Contact details are provided here on our website and throughout our supply chain communications.

Protected Disclosures

A number of persons are able to receive protected disclosures under our Whistleblower Policy. This includes nominated Protected Disclosure Officers and officers such as a director or secretary, or senior managers of the Coles Group. Their contact details can be found in the Coles Whistleblower Policy.

Third party organisations

Grievances are also submitted to Coles through trusted third parties, including unions, and NGOs. These parties play a vital role as they are ‘on the ground’ advocates for workers. We ensure all grievances raised via third party follow the same process.

Remediation

Where a legitimate concern or issue is raised through one of our grievance mechanisms or identified as a result of a Coles or third-party audit, we will seek to work with our suppliers, government and worker representative bodies or other non-profit organisation to ensure appropriate remedy is provided.

When applicable, a corrective action plan with a timeline and monitoring plan is assigned to the applicable party, including the person responsible, to ensure all issues identified are remediated. In some cases, a third-party may be used for support with monitoring the implementation of corrective action plans.

In all instances, we will seek to place the affected person’s needs first and appropriate remedy will be determined on a case-by-case basis. Our Ethical Sourcing Remediation RequirementsEthical Sourcing Remediation Requirements, View PDF, file size 246KB provide information on remediation methodology and potential remediation actions that may be undertaken.

If no outcome is forthcoming within a reasonable time period and the investigation has been thorough and all options have been exhausted, Coles reserves the right to exercise its rights under the relevant supply or services agreement which may include suspension of orders or termination of the agreement where compliance with the Policy and Program Requirements is not rectified. This is done in conjunction with several stakeholders including, the reporter, the Head and Group Ethical Sourcing Manager and any relevant business units.

We focus on a number of different areas in our supply chain and engage with different suppliers and stakeholders to increase our understanding of human rights issues and collaborate to address them.

Worker education

Coles recognises the importance of engaging directly with workers in our supply chain as listening to their experiences helps us strengthen our program. Under the Accord and in partnership with other relevant stakeholders, we have held several Worker Education events in key Australian produce growing regions including Mildura, Renmark, Coffs Harbour, Preston Beach and Grafton.

The Worker Education events are designed to provide workers information on their labour rights, including topics on: freedom of association, working hours, superannuation, wages & piece rates, and accommodation. They also provide workers with an opportunity to speak up and tell their stories, whilst providing direct access to resources and channels to raise their grievances. Workers are provided with fact sheets at the end of the event outlining their entitlements for their easy reference.

Accommodation

Seasonal workers play a key role in the Australian horticulture industry. We understand that availability and quality of accommodation for seasonal workers is challenging and reports by workers have highlighted concern around exploitation of workers in this area, including the risk of modern slavery. For example, workers can have few options and little input over their accommodation due to housing shortages, the seasonal nature of horticulture work, arrangements between industry stakeholders and differing visa conditions; all of these factors can leave workers disempowered and vulnerable to exploitation.

Building on a reportHorticulture Worker Accommodation, View PDF, file size 892KB we commissioned in 2022 together with our Ethical Retail Supply Chain Accord (Accord) partners, which included field research and underscored the need for further action in this area, we are working to create a minimum standard for worker accommodation for workers in Australian supply chains. In 2024, we partnered with Be Slavery Free, a civil society organisation specialising in human rights and addressing modern slavery to progress this work.

We know that stakeholder engagement is key to delivering an industry standard and incorporating the views of affected stakeholders is important to us. Stakeholder engagement was undertaken with workers, accommodation providers, industry representatives, government bodies, retailers, and audit firms to support the development of the accommodation standard. Once complete, the aim is that the standard can be used by relevant stakeholders in the Australian market to ensure workers are housed in accommodation that is clean, safe, fair and suitable for use. We are continuing to work with key stakeholders in this area and plan to publish the accommodation standard in 2025.

Living wage

According to the International Labour Organisation (ILO), a living wage is a ‘wage level that is necessary to afford a decent standard of living for workers and their families, accounting for country circumstances and calculated for the work performed during the normal hours of work’. Whilst there has been a positive long-term global trend in average wages, many workers worldwide, especially in developing countries, continue to earn very low wages and live in poverty.

Living wage is one of our salient human rights issues and promoting a living wage is an essential aspect of decent work to ensure all workers, families and communities can live in dignity. Workers at higher risk of being impacted include migrant and contracted workers in our extended supply chains overseas. Working with an external sustainability advisory group, in FY25 we initiated a pilot living wage gap analysis in selected supplier sites in a high-risk sourcing country. From this we plan to develop a living wage framework by end of FY27 including an income adequacy assessment for high-risk countries. We are also focusing on undertaking an analysis of living wage in key supply chains to identify gaps and opportunities to address systemic underpayment.

Responsible purchasing

We seek to ensure fair and sustainable relationships with our suppliers. We deeply value our supplier relationships and work hard to interact in a fair, honest, and transparent manner. Policies related to supplier engagements and payment terms are available on our supplier portals. This includes our Cost Price Alteration Policy which guides the process for suppliers to request an amendment in trading terms due to increased business costs, and the way we assess cost price alteration requests; and our Payment Policy and Procedure which outlines our process for paying suppliers on time and in line with agreed timeframes.

We recognise the impact that purchasing practices can have in shaping workers’ conditions and pay, and the importance of accounting for production and labour costs, providing appropriate payment terms, accurate volume forecasting and adequate lead times.

Working with an external sustainability advisory group, we are commencing a detailed assessment of our purchasing practices for selected supply chains to inform our work on living wage. The assessment will draw from the Ethical Trade Initiative Common Framework for responsible purchasing practices in the food sector and include consultation with internal buying and procurement teams as well as suppliers. Following this, we plan to introduce a Responsible Purchasing Policy which will outline team member responsibilities and reference considerations when purchasing products or services from tier one suppliers.

Responsible recruitment

We understand that the recruitment and supply of temporary, contract and seasonal labour is an area of risk within our supply chain. Our Ethical Sourcing Policy embeds the Employer Pays Principle ‘No worker should pay for a job – the cost of recruitment should be borne by the employer’ and requires suppliers to take steps to recruit responsibly including paying for the full cost of recruitment for each worker.

Where recruitment fees or costs are identified and have been paid by workers in our supply chain, we will work with suppliers to determine appropriate remediation requirements, which may include repaying workers. Our process for remediation is outlined in our Ethical Sourcing Policy and Forced/Bonded Labour Remediation Requirements.

We monitor our in-scope suppliers’ audit findings through our Ethical Sourcing Program, including any findings related to recruitment fees. Through review of documentation and interviews with a sample of workers, audits include an assessment of whether management systems are in place to support responsible recruitment and whether or not workers have paid recruitment fees.

In FY23, ethical audits of several of our suppliers’ sites in Thailand and Malaysia identified potential concerns relating to recruitment fees. We subsequently commissioned independent third-party investigations across these sites to verify and understand these concerns. Two different investigation methods were used by these third parties. The first method involved a substantial number of worker interviews, as well as engagement with the suppliers’ management. The second method involved a higher-level assessment, which included a worker survey and supplementary worker interviews. These methods provided us with a deeper understanding of the challenges around recruitment fees and we then engaged suppliers regarding the findings to work through a remediation pathway. For example, one supplier was able to repay workers and close out the recruitment fee finding in their next audit.

To help prevent the charging of recruitment fees in our supply chains, we partnered with a specialist consultancy to hold a capability building webinar with relevant suppliers. This included information on responsible recruitment standards, employer pays principle, effective management systems, pre-departure training and best practice remediation strategies for identified issues relating to recruitment fees. You can read more on our work in this area in our Modern Slavery Statements.

Labour hire

Third-party labour hire organisations provide an essential service to Coles’ suppliers; however, they can also introduce human rights and workplace compliance risks into these supply chains. In Australia, state-based labour hire licensing schemes can assist suppliers to minimise their recruitment and staffing industry risk. Coles has developed Third-Party Labour Hire Provider GuidanceThird-Party Labour Hire Provider Guidance, View PDF, file size 247KB for our suppliers. This tool is available for all Coles’ suppliers and outlines practical advice for managing labour hire, including detailing what good and best practice looks like, to support suppliers on their continuous improvement journey.

The use of labour hire intermediaries often occurs at tier three, or below, of our supply chain, which can limit our visibility of the providers involved. In FY22, we introduced labour hire reporting requirements for all in-scope Australian fresh produce suppliers which includes a questionnaire on the processes suppliers have in place to monitor their labour hire providers, as well as details on their business name, business number and labour hire license number if relevant. We require our suppliers to establish these monitoring processes under our Ethical Sourcing Program to assist in providing oversight over labour hire provider practices. The information collected through the questionnaire has also enabled us to commence mapping labour hire providers used in our extended supply chain, to further assess potential human rights risks. To further increase our oversight on labour hire in the fresh produce sector, we plan to collect additional information on labour hire providers used and associated monitoring systems for our sites audited under the Coles funded Third-Party Audit Program (3PAP).