MODERN SLAVERY POLICY

PURPOSE OF THE POLICY

Freedom Furniture Australia Pty Ltd and each of its subsidiaries in Australia and New Zealand (Freedom, we, us, our) is committed to ensuring compliance with the Modern Slavery Act 2018 (Cth) (Modern Slavery Law) and to ensure that we do not engage in or support modern slavery.

Freedom’s philosophy is to respect and promote human rights and, as part of this, is committed to addressing modern slavery risks in our operations and supply chains.

The purpose of this Policy is to set out our overarching standards, company values and our expectations of team members and business partners in relation to modern slavery and human rights issues.

WHAT IS MODERN SLAVERY?

The term "modern slavery" describes situations in which coercion, threats or deception are used to exploit victims and undermine their freedom.

Modern slavery takes many forms including slavery, servitude, forced labour, debt bondage, deceptive recruiting for labour or services, the worst forms of child labour (where children are exploited through slavery like practices or exposed to hazardous work) and forced marriage.

SCOPE OF THE POLICY

This Policy applies to all persons working for or on behalf of Freedom, including employees, directors, officers, agents, contractors and consultants, insofar as they carry out work in connection with, or otherwise hold responsibilities in relation to, Freedom’s obligations under the Modern Slavery Law (referred to in this Policy as Team Members).
 
This Policy also applies to all of those who have, or seek to have, a business relationship with Freedom including suppliers, service providers and franchisees (referred to in this Policy as Business Partners).

All persons to whom this Policy applies must familiarise themselves and comply with its terms.

OVERARCHING STANDARDS

We respect internationally recognised human rights and expect the same from our Team Members and Business Partners, wherever they are operating.

Our philosophy and company values are informed by the International Bill of Human Rights (which includes the Universal Declaration of Human Rights and the International Labour Organisation's Declaration on Fundamental Principles and Rights at Work) and the UN Guiding Principles on Business and Human Rights.

We are striving to have transparent operations and supply chains and to conduct our business in a way which reflects the above.

OUR APPROACH AND COMMITMENTS

We are committed to taking steps to address the risks of modern slavery in our operations and supply chains.

In line with our philosophy and company values, we are committed to:

• conducting risk assessments to determine which parts of our operations and supply chains are at most risk from modern slavery so that efforts can be focused on those areas;
• meaningfully engaging with our suppliers when conducting due diligence and addressing modern slavery risks;
• addressing any modern slavery issues which occur in our operations or supply chains;
• complying with all applicable laws relating to modern slavery; and
• conducting audits of our suppliers (including site visits) to evaluate local conditions and to verify their compliance with all applicable laws.

RESPONSIBILITY

We are committed to giving our Team Members the appropriate systems and support to enable them to assist Freedom to meet its obligations under the Modern Slavery Law, as required by a Team Member’s role and responsibilities.

Team Members are required to treat all people with whom they deal with dignity and respect, and to remain vigilant to risks of modern slavery which may occur in all aspects of our operations and supply chains.

Team Members must:

• read, understand, and comply with this Policy;
• read, understand, and comply with compliance material that forms part of the Responsible Sourcing Framework;
• complete any mandatory Modern Slavery Law training appropriate to their role;
• seek advice from Legal in connection with any queries or issues connected with Freedom's obligations or compliance with the Modern Slavery Law; and
• immediately report any suspected issues relating to compliance with the Modern Slavery Law.

In addition to the above, Blue Rock Sourcing Solution Limited, in its capacity as Freedom’s off-shore quality assurance/quality compliance partner, must fulfil its contractual obligations with respect to assisting Freedom’s compliance with Modern Slavery Laws.

Management must:

• ensure Freedom’s policies and procedures comply with the Modern Slavery Law;
• provide training (as appropriate to a Team Member’s role) and resources to support compliance;
• respond appropriately if any modern slavery issue or risk is reported to them;
• ensure that any person who believes they are a victim of modern slavery in our operations or supply chains has the ability to make a complaint and have that grievance addressed and, if appropriate, remediated; and
• ensure that Team Members are provided with a copy of this Policy and are aware of their responsibilities under it.

EXPECTATIONS OF BUSINESS PARTNERS

We expect our Business Partners to:

• act in ways which are consistent with our philosophy, company values and these expectations;
• establish appropriate systems to ensure that they act in a way which is consistent with this Policy;
• adopt a similar policy to this Policy, including provisions for the identification and eradication of modern slavery risks in their operations and supply chains;
• identify, assess and immediately disclose to us any actual or potential occurrence of modern slavery or any breach of a human right with which the Business Partner may be involved or associated (either through its own operations or as a result of its business relationships); and
• in the event that any such actual or potential occurrence of modern slavery or breach of a human right is identified, take steps to rectify or mitigate it and immediately notify us of the steps taken.

REPORTING OR RAISING A QUERY OR CONCERN

Anyone who has a query or concern about Freedom and modern slavery compliance is encouraged to raise their concern (anonymously, if desired) via our SpeakUp! channel at https://freedom.stoplinereport.com/, or for our Team Members via our digital workplace platform.

CONSEQUENCES OF NON-COMPLIANCE

Any non-compliance with this Policy by Team Members will lead to disciplinary action up to and including termination of employment or engagement.

Any actual or suspected non-compliance with this Policy by a Business Partner must be notified to us immediately. We require all Business Partners to cooperate in any investigation or related processes which we may initiate.
 
Any substantiated non-compliance with this Policy by a Business Partner or an entity in one of its supply chains may result in corrective action and the suspension or termination of the contractual relationship.

In all cases we reserve the right to inform relevant authorities.

COMMUNICATION

The existence of this Policy and its contents will be communicated to Team Members and Business Partners. This Policy will be made available on our digital workplace platform and Freedom website.

UPDATES TO THIS POLICY

The Policy will be reviewed every two years, or when there is a legislative or regulatory change. Amendments will be made with Board approval.

GOVERNANCE

This Policy has been approved by the Board of Greenlit Brands Pty Limited.