While our operations and supply chains are complex, our aim is to ensure that human rights are understood, respected and upheld. We expect our business partners to adhere to ethical business conduct consistent with our own, and we are committed to working with them to fulfil this common goal, and proactively address human rights risks.
Our Responsible Sourcing Program provides the governance for how we manage social compliance of our own brand and fresh products. Our Responsible Sourcing Program is anchored by two main documents:
Human Rights Policy that applies to all direct suppliers; and
Responsible Sourcing Standards that apply to all direct suppliers, other than suppliers of branded goods and services.
These are supported by our Responsible Sourcing Program Guidelines (for suppliers in our Trade supply chain).
Trade
Trade products span an array of categories, including apparel, long life food, fresh food and general merchandise. During onboarding, suppliers are segmented into four risk categories with corresponding due diligence requirements. This segmentation will determine the activities suppliers are required to complete in order to verify compliance with the Standards. These include, but are not limited to:
Attending training and education sessions
Completing a supplier self-assessment questionnaire (SAQ)
Submitting an audit under our third-party social compliance ‘Mutual Recognition’ scheme
Agreeing to and implementing a corrective action plan
Demonstrating continuous improvement
Announced and unannounced factory or site visits.
The third party audit for moderate, priority and specialised risk-segmented suppliers includes checks on key forced labour indicators. All audits are graded against four possible outcomes – zero tolerance (ZT), critical, moderate, and minor – and forced labour indicators, among others, are considered a ZT issue. Moderate or minor non-conformances (NCs) are addressed during the audit cycle as part of the scheme follow-up, while our team prioritises ZT and critical NCs for follow up.
Non-Trade
Human rights risks are dynamic, and we continue to review our program to make sure our interventions remain fit for purpose. We source products, equipment and services from a number of non-trade suppliers. Examples of non-trade products include those that may feature a Woolworths Group brand, such as shopping baskets, trolleys or uniforms. It also includes products that are not branded such as packaging materials, IT equipment and construction materials.
The majority of non-trade services operate in facilities that are owned and operated by the Group across Australia and New Zealand including our retail stores, DCs and CFCs. Examples of non-trade services include cleaning, trolley collection, security services, warehousing and logistics.
In F23 the Group identified an opportunity for a programmatic uplift to our Responsible Sourcing Program to provide a consistent approach to managing labour rights risk across our trade and non‑trade supply chain.
In F24, we developed a risk segmentation approach for non‑trade suppliers to determine which suppliers will be in scope of the Responsible Sourcing Program, and how to further risk‑segment in‑scope suppliers. The Human Rights team partnered with third party human rights experts LRQA to identify inherently extreme and high risk non‑trade categories based on our F23 forced labour risk assessment and LRQA’s social risk scores. Non‑trade suppliers in these categories have then been assessed to determine their connection to the Group. Consistent with our approach to in‑scope trade suppliers, in‑scope non‑trade suppliers will be subject to further risk segmentation, with proportionate human rights due diligence depending on their risk segment.
The Policy and Standards
The Human Rights Policy outlines our overarching commitment to upholding respect for the human rights of the workers in our supply chain. The Policy applies to all of our suppliers globally and is a part of doing business with the Group.
The Responsible Sourcing Standards are a key way that we implement our Policy commitments and they outline our expectations for suppliers in scope of the Responsible Sourcing Program. They include comprehensive criteria on business integrity, labour rights, fair and safe working conditions and environmental compliance.
As part of the rollout and ongoing due diligence, we are committed to supporting suppliers with relevant information sessions, guidance documents, training materials and, in higher-risk categories, establishing communities of practice.
We regularly review our Human Rights Policy and Standards to maintain best practice and to align with our communities and customer needs, detail regarding our verification and audit framework, clarification on the role of our Guidance notes, and recognition of our extended Speak Up program for management of grievances. Our 2020 Policy enhancements included explicit endorsement of the UN Guiding Principles on Business and Human Rights; acknowledgement of our human rights governance via the Board Sustainability Committee; further emphasis on the expectation for suppliers to cascade requirements into their own supply base; and recognition of our internal responsibility (e.g. Responsible Purchasing Practices) as a vital factor in promoting respect for human rights. Our 2021 update was paused due to COVID-19 disruptions, and our 2022 update included the following enhancements:
Language updated to clarify scope of the policy and standards
Structure and narrative updated to reflect greater clarity on implications when standards are breached
Updated to reflect program maturity, including with reference in particular to guiding principles
Our 2023 update included changes to include non-trade suppliers and majority owned businesses in scope of the Responsible Sourcing Standards.
Our 2025 update focused on integrating recommendations from both an internal review and an independent external governance review which were conducted to identify key gaps and opportunities for improvement in our Human Rights Program. Key updates included:
Renaming our Responsible Sourcing Policy to Human Rights Policy in order to provide greater clarity of the full scope of the Human Rights Program
Providing greater clarity on which suppliers and categories are in scope of our Responsible Sourcing Program
Additional requirements | Addendums to the Standards
A number of additional requirements are referenced within the Responsible Sourcing Standards which outline specific requirements that suppliers should be aware of. These stand alone as separate documents in addendum to the Standards but must be read in conjunction with the relevant sections in the Standards.
1. Woolworths Group Labour Hire Addendum
In February 2019 we released an Addendum to the Standards, Requirements for Labour Providers in our Australian Supply Chain. The Addendum outlines specific requirements relating to the engagement of labour providers by participants in our horticulture supply chain.
Safeguarding responsible employment practices by labour providers involved in our supply chain is a key component of Woolworth Group's responsible sourcing commitments. Our approach to responsible recruitment is aligned with industry standards and underpinned by three core principles known as the Priority Industry Principles:
every worker should have freedom of movement;
no worker should pay for a job; and
no worker should be indebted or coerced to work.
Information on labour providers currently used by our recognised third party programs can be found below:
Queensland Government's Register of Labour Hire Licences here
South Australia Register of Labour Hire Licences here
Victorian Register of Labour Hire Licences here
Seasonal Worker Program Listing of current Approved Employers here
The Registry of StaffSure Certified Workforce Service Providers here
For more information please read these FAQs.
2. Woolworths Group Child Labour Addendum
In July 2022 we released specific requirements for the prevention and remediation of Child Labour as an extension of guidance that previously existed on Child Labour within the Standards. These requirements must be read and understood by all suppliers and upheld in conjunction with Standard no. 6 | Child Labour.
3. Woolworths Responsible Recruitment Addendum
In April 2022, Woolworths Group further strengthened our position on responsible recruitment when we joined the Consumer Goods Forum Human Rights Coalition (the Coalition).
The Responsible Recruitment Requirements should be considered by all suppliers engaging foreign migrant workers either directly or indirectly in their operations. However, Woolworths Group will take a proactive, risk-based, and phased approach to rollout and supplier verification, therefore Thailand and Malaysia are prioritised for implementation.