Human Rights

We want our stakeholders to know that we make every effort to operate our business and source our products ethically, sustainably and responsibly.

We commit to respecting the principles of the United Nations’ (UN) Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights and the International Labour Organisation’s Declaration on Fundamental Principles. As a signatory to the UN Global Compact, we are committed to upholding its 10 principles related to Human Rights, Labour, Environment and Anti-corruption.

Our approach to managing human rights continues to evolve. In February 2020, the Coles Group Board endorsed an updated Human Rights Strategy , that also encompasses our approach to ethical sourcing.

The following sections provide information on:

• Coles’ Human Rights Strategy
• Human rights and our team members
• Human rights and ethical sourcing in our supply chains

Case Study

In March 2020, the Coles Group Board endorsed an updated company-wide  Human Rights Strategy .

The Strategy was developed with support from independent human rights experts. It followed a review of business and stakeholder needs, a review of existing policies as well as team member interviews and group workshops.

As part of the strategy development, we identified and categorised our key (salient) human rights risks under six themes:

• Labour rights
• Right to health and safety
• Right to equality and freedom from discrimination
• Indigenous rights
• Cultural rights
• Right to dignity and justice

These risks will be reviewed and updated periodically in consultation with stakeholders including team members, suppliers, supply chain workers, customers, community and key stakeholders.

Our Strategy focuses on systems and processes to prevent, mitigate and remedy actual or potential adverse human rights impacts under the areas of compliance, work culture, people and technology, governance, remediation and stakeholder engagement.

Beyond compliance

Trusted to go beyond compliance to prevent harm in our value chain.

• Enhanced systems and controls, expanded across all business units of Coles Group and our broader supply chain and partners.
• Extended and revised ethical sourcing program across all of Coles Group.
• Assessment of human rights risks across Coles value chain.

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Work culture

A work culture of protecting people from harm and harassment.

• Harm identified with worker participation.
• Collaborative initiatives with unions.
• Formalised training, guidance and monitoring for our team members and suppliers.
• Increased resources to build supplier capability on labour standards, human rights, health, safety and environment.

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People and technology

Put people at the centre of technology and innovation opportunities.

• Integrated human rights and social impact assessments.
• ‘Human rights by design’ in all tech initiatives.
• Use of advanced technology to strengthen safety systems.

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Governance

Regular review of salient human rights risks, strategy and commitments.

• Defined accountabilities.
• Timely and transparent reporting.
• Enhanced monitoring.
• Cross functional Human Rights Steering Committee.
• Risk based program.

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Remediation

Review coverage and effectiveness of existing grievance mechanisms.

• Consult with affected stakeholders.
• Capability building within our teams to strengthen ability to identify and address human rights impacts.

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Stakeholder Engagement

Transparency as a key program attribute including public reporting of substantiated human rights impacts.

• Collaboration with unions, NGO’s, government and suppliers, including on grievance management principles and industry initiatives.
• Active participation in industry reporting benchmarks.

Key elements of Coles’ Human Rights Strategy

Governance

Our Human Rights Strategy and supporting commitments have been endorsed by the Coles Group Board and Executive Leadership Team.

Governance of human rights and implementation of our Strategy is overseen by a Human Rights Steering Committee, chaired by our Chief Legal and Safety Officer.

The Committee, which meets regularly, consists of representatives with responsibility for implementing our Human Rights Strategy from across the Coles Group. These representatives include members from our ethical sourcing, procurement, legal, corporate affairs, merchandise and operations teams.

The Coles Group Board and Executive Leadership team receive regular updates on the status of our Human Rights Strategy including our Ethical Sourcing Program, which forms part of the Strategy and is a key focus area.

Selected senior management, including the Executive Leadership Team, must complete mandatory training incorporating key areas of human rights including anti-bribery and corruption, anti-discrimination, bullying and harassment, diversity and inclusion, and health and safety.

Responsibilities and accountabilities for human rights and ethical sourcing at Coles

Working with our stakeholders

We regularly engage with our team members, customers, suppliers, government and non-government organisations to effectively address current and emerging human rights issues and collectively identify any improvement opportunities.

In 2020, we completed an ethical sourcing stakeholder mapping exercise using the International Association for Public Participation (IAP2) framework which groups stakeholders according to their need to be informed, consulted, involved, collaborated or empowered. Key stakeholders identified included suppliers, customers, non-government organisations, investors, unions and government agencies.

Coles is one of Australia’s largest retailers employing more than 114,000 team members.

We are committed to fostering a culture that respects human rights and we want all team members to be able to recognise and escalate potential human rights issues.

Our commitment is reinforced in our Code of Conduct and our Better Together diversity and inclusion program which highlight the importance of providing an inclusive environment reflective of the diverse communities in which we live and work.

Training is provided to all team members on our obligations to conduct business ethically and in compliance with fair-trading laws. We also provide targeted training programs 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.

As part of our focus on wellbeing during the COVID-19 pandemic, we worked with The Resilience Project to create a series of videos to support team members’ mental health as well as fact sheets covering topics such as maintaining emotional fitness and relaxation techniques. During COVD-19, 94% of our office-based team members told us they felt confident and enabled in working remotely.

Mind Your Health

We understand the value and importance of creating a culture where mental wellbeing is proactively discussed and monitored, and we encourage all team members to take an active role in ensuring our workplace is safe, positive and supportive.

The Mind Your Health program, launched in 2015, continues to grow and the program is centred around three key focus areas, I am seen, I am heard and I matter. The program also focusses on the five wellbeing pillars: Be mindful, Stay connected, Be active, Keep learning and Give back. It provides a range of resources to support all team members.

Employee Assistance Program

Through our partnership with Converge International, we support team members and their families with a free and confidential Employee Assistance Program (EAP). 

In addition to the general helpline, providing team member, manager, nutrition and lifestyle, financial,  legal, conflict and family assistance, there are also four specific helplines: Aboriginal and Torres Strait Islander helpline, LGBTIQ helpline, domestic and family violence helpline and eldercare helpline.

In times of acute need, such as during the 2020 Australian Bushfire crisis and the 2020 COVID-19 Pandemic, Coles extended access to the EAP to our suppliers.

Training

Due to the overwhelming positive feedback, Coles has continued their partnership with The Resilience Project. This partnership allows all team members to contribute to the Gratitude, Empathy and Mindfulness (GEM) movement at Coles by participating in campaigns throughout the year and most importantly supporting team members to lead happy and healthy lives. Coles also sponsored the development of TRP@home which allows team members and customers to access a range of wellbeing resources. 

We are also committed to providing mental health training to leaders every two years to equip them with the skills to respond appropriately in a mental health crisis.

Our online Learning Hub for our team members hosts four Mind Your Health online tutorials that provide leaders and team members with the knowledge and skills to have open conversations about mental health and wellbeing as well as tips and strategies on how to create a mentally healthy team and self. These will be updated throughout the course of 2021.

Partnerships

Coles is one of 12 founding members of the Corporate Mental Health Alliance in Australia. The Alliance’s vision is to share best practice in creating a mentally healthy workplace and driving community improvements.

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 your 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. This may occur, for example, when a customer uses their payment card, makes a purchase online or requests customer service.

Coles Privacy Policy applies to all Coles’ companies and divisions and provides information about the personal information we collect and handle about you as our customers, members of the public, visitors to our websites, and users of Coles apps, social media, and other digital services. 

The 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 Coles Privacy Council, consisting of senior managers across the functional areas of Technology, Risk & Compliance, Digital Security, Data Governance, Customer Experience, and Legal within the Group. We have a Privacy Officer and a Privacy Compliance Manager, who can be contacted at  complianceprivacy@coles.com.au . We also make use of external resources who provide advice on a range of issues, including domestic and global privacy trends.

Ethical sourcing overview

We acknowledge that protecting human rights in supply chains is a global issue and we understand the important role we have in safeguarding human rights within our complex supply chains.

We are committed to protecting and upholding fundamental human rights as set out in the Universal Declaration of Human Rights. We do so by conducting our business with due care, acting in accordance with relevant laws and regulations, and creating a culture of respect and inclusivity.

While our approach to ethical sourcing continues to evolve, we remain committed to working with our stakeholders to identify, understand and remedy negative human rights impacts across our business.

In February 2020, we launched an updated Human Rights Strategy of which a key component is our Ethical Sourcing Program.

Our Ethical Sourcing Program commenced in 2005 and has continued to evolve.

2005

Published Ethical Sourcing Code for high risk suppliers.

2009

Introduction of auditing for our Own Brand products from high risk countries.

2011

Commenced social audit program; audited 85 international own brand suppliers.

2012

Introduction of a supplier self-assessment process, including for suppliers operating in low-risk regions.

2014

Launched internal Ethical Sourcing Training.

2015

Launched Ethical Sourcing Policy and Supplier Requirements for all Coles Own Brand and Fresh produce suppliers. Signed the Australian Business Pledge Against Forced Labour - an industry led initiative to end forced labour.

2016

Became the first major Australian supermarket to adopt SEDEX to enable suppliers to easily share ethical sourcing performance. Established the Wages and Conditions hotline for farm and factory workers.

2017

Continued roll out of SEDEX to supermarket own-brand and fresh produce suppliers.

2018

Supplier and Grower roadshow in Brisbane and Bowen.

2019

Signed the United National Global Compact on human rights, labour, environment and anti-corruption. Developed Coles Ethical Retail Supply Chain Accord in partnership with the Shop, Distributive and Allied Employees Association (SDA), the Transport Workers Union (TWU) and the Australian Workers Union (AWU).

2020 and beyond

1. Launching a new Ethical Sourcing Policy and Supplier Requirements for all suppliers.
2. Sunraysia farm worker education session in partnership with the United Workers Union and Woolworths.
3. expanding the existing program to include Own-Brand and Exclusive Liquor suppliers and selected Goods-Not-For-Resale.
4. Expanding the internal Ethical Sourcing team, including an in-house APSCA certified auditor.
5. Developing a new risk assessment methodology to assist in better identifying human and labour rights issues within our supply chain.
6. Launching a new modern slavery/ethical sourcing training for frontline internal teams and the broader organisation.
7. Supporting suppliers through the delivery of in person ethical sourcing training.
8. Continued engagement with industry groups and NGO's to share best practice and work towards collaborative solutions.

Ethical Sourcing Program

Our Ethical Sourcing Program is aimed at ensuring suppliers within our supply chains conduct business with integrity, and that they uphold, protect and respect the human and labour rights of their workers, and provide a safe and healthy workplace.

Our expectations of suppliers are detailed in our Ethical Sourcing Policy and Ethical Sourcing Program Requirements , which draw on international standards and best practice guidance. These include the Ethical Trade Initiative (ETI) base code and the International Labour Organisation (ILO) Declaration on Fundamental Principles and Rights at Work. Suppliers agree to adhere to our Ethical Sourcing Policy as part of their supply contract with us.

Our Ethical Sourcing Policy outlines our commitment to ensuring the goods and services we procure are ethically and responsibly sourced. Our Ethical Sourcing Program Requirements contain more comprehensive information in areas such as labour rights, safe working conditions, environment and business integrity. Suppliers are notified of changes to our Policy and Program Requirements through our supplier portals.

We take a risk-based approach to managing our suppliers within our Ethical Sourcing Program. Suppliers undergo a risk assessment which informs how we manage and monitor their compliance with our Program. It allows us to focus our resources where there is a greater risk of labour or human rights violations, and where we have leverage to facilitate change in our supply chain.

This means that, while every one of our suppliers is subject to our Ethical Sourcing Policy and Ethical Sourcing Program Requirements, we will have different requirements for each supplier depending on their risk, as determined by us.

Selected suppliers (including suppliers within our extended supply chain) are required to provide information on a regular basis about ethical sourcing performance, through an online supplier portal such as the Supplier Ethical Data Exchange (SEDEX) or Fair Farms. They may:

• Undertake a desktop or on-site audit, administered by us;
• Undertake a desktop or on-site audit, administered by an independent third party, at the supplier’s expense, to monitor compliance with our policy and requirements;
• Participate in training and development programs.

The Policy and Program Requirements are reviewed annually in consultation with stakeholders to align with changes in regulations and reflect best practice.

While it is impractical for us to monitor compliance for every supplier within our extended supply chains, it is our expectation that our direct suppliers will cascade these or similar requirements to their own suppliers.

Our supply chain

Our supply chain is complex, comprising thousands of suppliers and workers who contribute to producing the goods and services we use and sell.

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 Coles has leverage to affect change.

Ethical sourcing program scope FY21

Coles Brand

Coles Brand is the portfolio of food, drink and non-food product brands owned by Coles. The following table illustrates the countries from which we source Coles Brand products, by product type.

Table of countries where Coles Brand products are sourced

Coles Own Brand sourcing (Data as at 8 April 2021)

Apparel suppliers

In selected Coles supermarkets, we sell our Coles Brand apparel range – Mix. We work with apparel suppliers to build strong relationships throughout the supply chain and monitor performance against our Ethical Sourcing Policy and Ethical Sourcing Program Requirements. The names and locations of the factories producing the Mix clothing range are available here.

Our commitments

Coles is a signatory to the United Nations Global Compact (UNGC) and a member of the UNGC Network Australia’s Modern Slavery Community of Practice. We are committed to the UNGC’s 10 Principles and the UN Women’s Empowerment Principles.

In 2015, Coles signed the Australian Business Pledge Against Forced Labour, an industry-led initiative to end forced labour.

Working with suppliers

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. Coles will always treat suppliers fairly and with consideration of individual circumstances. However, we cannot and will not accept unaddressed human rights or environmental abuses in our supply chain.

If a supplier is unable or unwilling to comply with the Policy and 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.

The Policy and Requirements are reviewed regularly in consultation with stakeholders to align with changes in regulations and reflect best practice. Through these engagements, we seek feedback on how well the Policy and Requirements work in practice. To provide feedback regarding Coles’ Ethical Sourcing Program Policy or Supplier Requirements, please contact the Coles Ethical Sourcing team at EthicalSourcing@coles.com.au

Our Whistleblower Policy encourages reporting of any suspected unethical, illegal, fraudulent or undesirable conduct within our supply chains, including suspected adverse impacts on people, communities or the environment.

Coles respects the rights of individuals and human rights defenders to confidentially and/or anonymously raise complaints or concerns without fear of retaliation. Coles does not tolerate threats, intimidation, harassment, discrimination, victimisation or attacks against individuals or human rights defenders.

We provide a number of channels for people to make complaints or raise concerns including the Coles Wages and Conditions Hotline and Coles STOPline as well as access to Coles’ Protected Disclosure Officers.

All concerns raised through any of these mechanisms are assessed to determine if and how they should be investigated. We will always seek to resolve concerns as quickly as possible, noting that concerns vary in complexity and timeframes for resolution will vary. Where remedy is necessary, this may be facilitated by us directly or in collaboration with third parties.

If appropriate, we will provide feedback to complainants regarding the investigation’s progress and/or outcome (subject to considerations of the privacy of those against whom allegations are made).

We commit to not obstructing access to other remedies, including judicial or non-judicial remedies. We also support the work of and are open to working with the Australian National Contact Point (AusNCP).

A table of human rights related complaints received against Coles' suppliers is available here.

Coles Wages and Conditions Hotline

Workers within Coles’ supply chains in Australia and other countries, including farms, factories and service providers, can access the Coles Wages and Conditions Hotline by phone or email.

In Australia, employees who work for a Coles supplier can call 1300 532 515 between 8am and 8pm, seven days a week to understand more about their conditions of employment or to report unfair labour practices.

For workers in the international supply chain and those where English is not a first language, we have an email facility at wageline@coles.com.au where workers can provide their telephone number, preferred language and a brief description of their concern so that any issues can be addressed by Coles or the relevant authority. 

Complaints received through the hotline or email are directed to our dedicated Ethical Sourcing Team. All complaints received are investigated and, if required, may be escalated for further investigation by an independent third-party.

Details on how to contact Coles are available in Korean, Chinese Mandarin, Bislama, Tongan, Samoan, Tetum, Vietnamese, French, Spanish, and Malay.

Coles STOPline

Coles STOPline is a confidential telephone service run by an independent third party that all stakeholders can use to raise concerns or make complaints. It can be accessed overseas and in multiple languages, with translation available on request through an Australian Government translation service and language setting within the Mobile App.

Coles Protected Disclosure Officers

A matter can be confidentially and/ or anonymously reported directly to a Coles Protected Disclosure Officer. Their contact details can be found in the Coles Whilstleblower Policy .

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-for-profit organisations to ensure appropriate remedy is provided.

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 Remediation Requirements provides information on our remediation methodology, potential remediation actions that may be undertaken and case studies.