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Bespoke interventions to address modern slavery risks

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Whilst our Responsible Sourcing Program includes ongoing due diligence of in-scope suppliers, we recognise that modern slavery risks are also present in lower supply chain tiers. These risks - including risks based on geographies or commodities - require tailored interventions to seek to better manage these risks. For these situations, we develop bespoke interventions to address modern slavery risks.

In order to respond to the dynamic nature of human rights risks, we regularly review our interventions to make sure they remain effective. Our approach may take a variety of forms, examples of which include:

  • Category specific due diligence where we have identified material risks particularly due to greater inherent risks and limited visibility over working conditions (e.g. beyond our direct supplier relationships at lower supply chain tiers such as tier 2 and 3). We have established targeted workstreams to address specific modern slavery risks in Seafood, Commodities and Cotton.

  • Guidance frameworks where we have identified locations or sectors where human rights risks may be particularly severe, making remediating issues harder to influence. Examples of such frameworks include:

    • an extreme-risk due diligence framework which uses bespoke technology and tools to conduct screenings to identify network connections and extreme-risk exposure through trade or company ownership; and

    • a guidance framework for meaningful engagement with impacted stakeholders which involves engaging with affected stakeholders to learn from their experiences and inform our ongoing strategies.

  • Responsible recruitment initiatives in high-risk regions (e.g. Thailand and Malaysia) and implementing Responsible Purchasing Practices with the aim of embedding responsible business throughout key areas in which we can have the biggest impact on working conditions.

  • Worker voice activities to gather sentiment, concerns and grievances directly from workers as we recognise that audits are not a silver bullet and benefit from the addition of compensating controls.

  • Programs to enhance supply chain transparency beyond tier one in inherently higher risk categories across our trade and non-trade supply chain.

(1) Egg ingredient processing aids or where egg is less than 1% of total formulation, unless where used as a characterising ingredient, are not currently included in the scope.

 

Supporting our New Zealand suppliers


During the COVID pandemic, border closures and lockdowns severely impacted the New Zealand hospitality and cruise ship industries which accounted for a significant proportion of the country's egg demand. This downturn hindered the egg industry's ability to invest in transitioning to cage-free systems. To counteract this, Woolworths New Zealand partnered with a major supplier to establish a long term contract. This gave the supplier the confidence to further invest in cage-free farming systems, and provided Woolworths New Zealand with a secure egg supply and continued progression towards our whole shell cage-free egg ambition, achieved by the end of 2025.