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.

Our approach to managing human rights reflects the principles of the United Nations’ (UN) Universal Declaration of Human Rights and the UN Guiding Principles on Business and Human Rights. We seek to uphold the fundamental rights at work as set out in the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work.

As a signatory to the UN Global Compact, we are committed to upholding its 10 principles including its Labour principles.

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.

---

---

---

---

---

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, is focussed around five 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, lifestyle, 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

We have partnered with The Resilience Project to provide our Store Support Centre leaders and store leaders with face- to-face training and online support around developing mental health strategies, building resilience and supporting wellbeing.

We are also committed to providing mental health first aid training to leaders 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.

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 and partners. We are committed to the protection of their privacy and ensuring compliance with our obligations under privacy laws. Occasionally we will collect personal information in relation to our customers’ interactions and transactions with us. This may occur, for example, when a customer uses their flybuys card, makes a purchase online or requests customer service.

Coles Privacy Policy applies to all Coles’ companies and divisions and provides detailed information about the collection, use, sharing and protection of Coles’ customer information.

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 from 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.

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 Supplier 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 Supplier 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 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 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 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.

All Coles Supermarkets and Coles Express suppliers of Own Brand products and fresh produce, including indirect suppliers who contribute to packing/manufacturing product to its final retail form, are required to participate in our program.

Our Program is being expanded to include suppliers of Own Brand liquor, suppliers of liquor exclusive to Coles and selected suppliers of goods-not-for-resale. Further suppliers within our supply chain will be included as our program progresses.

Ethical sourcing program scope FY21¹

¹ Leverage refers Coles’ ability to influence change where required and is determined by factors such as ownership, spend, length of relationship and exclusivity.

Own Brand

Coles Own 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 Own Brand products, by product type.

Download Coles Own Brand sourcing

Coles Own Brand sourcing (Data as at 9 September 2020)

Apparel suppliers

In selected Coles supermarkets, we sell our Own 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 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

As ethical sourcing continues to evolve, we encourage our suppliers to raise any challenges that may arise in meeting our requirements. Where issues are identified, we will deal with suppliers fairly and in good faith, and consider individual, unique or unusual circumstances. However, we cannot and will not accept unaddressed human rights abuses in our supply chain.

If a supplier is unwilling to work with us to address compliance issues under our Ethical Sourcing Policy and Ethical Sourcing Supplier Requirements, or refuses to participate in the program, we reserve the right to exercise any termination rights available and/or otherwise cease engagement with that supplier.

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.

We respect the rights of people to confidentially and/or anonymously raise complaints or concerns without fear of retaliation, intimidation, harassment, discrimination or victimisation.

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.

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

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