1.  STATEMENT

In accordance with the Modern Slavery Act 2018, this policy outlines the steps that SlumberCorp Pty Ltd has taken, and is continuing to take, to assess and reduce the risks of modern slavery within the business and the supply chain, and the plans for review and improvement.

2.  INTRODUCTION

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and complusory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another, to exploit them for personal or commercial gain.

SlumberCorp Pty Ltd recognises that it has a responsibility under the Modern Slavery Act to take a strong approach to reject any forms of modern slavery and human trafficking. We are committed to promoting ethical business practices and policies that protect workers from being abused and exploited, both in the business and the supply chain. We are committed to operating responsibly and adhering to the highest ethical standards.

3.  SLUMBERCORP PTY LTD OPERATIONS

SlumberCorp founded in 1995, is a manufacturer of mattresses, bases and headboards and supplies products to commercial distributors and retailers throughout Australia. SlumberCorp head office is based in Perth, Western Australia and operates 3 manufacturing sites in Australia (Western Australia, Queensland & Northern Territory) over 100 direct employees. SlumberCorp also has a close affiliation and licences its product to Crown Posture Bedding in Victoria to assist with supply to the eastern seaboard of Australia.

4.  SUPPLY CHAIN

We procure goods and services needed for our business’s day-to-day operations from preferred and approved suppliers operating in Australia and also overseas.

Our Supply chain arrangements include suppliers from the following key areas:

• Springs
• Timber
• Fabric
• Foam

Other than raw materials required to operate our business, we also identify key supply chains such as Manufacturing equipment, transportation, logistics, site services and Technology.

5.  POTENTIAL RISKS OF MODERN SLAVERY

SlumberCorp has undertaken a due diligence of its operations and supply chains to identify potential risks of modern slavery, and our assesment identifies no potential risk within our local operations in Australia and a low risk level for procurement from agents and suppliers from overseas. Due to the low risk from international suppliers, SlumberCorp has developed and conducts modern slavery assesments to identify any further risks associated with developing these partnerships.

SlumberCorp also purchases key materials from manufacturers and suppliers who supply major bedding manufacturers worldwide who also have modern slavery processes in place.

6.  DIRECTLY EMPLOYED WORKFORCE

There is minimal risk of issues in our directly employed workforce.

The labour market in Australia is highly regulated and recruitment is governed by a diligent selection process.

There are procedures and processes to facilitate pathways for communitcation and consultation with employees to disclose any misconduct in our business without recrimination. There have been no issues determined to date.

7.  SUPPLIERS

Key suppliers of goods and services are vetted by a selection process including a review of their performance to quality and deliver requirements.

Suppliers with operations based in Australia are determined to be at low risk for modern slavery occurring in their supply chains, as their operations are Australian based.

Suppliers from overseas are considered as a potential risk and vetted in this respect. At this stage no suppliers have been identified or indicating a potential risk, however, we will continue to work closely with our Suppliers to ensure that they operate in accordance with Modern Slavery law and that they also understand the expectations to comply. This can be done with inspections and audits when visiting where practicable, and, in conjunction with information provided by our suppliers, that they are committed to anti-slavery obligations.

8.  ACTIONS

SlumberCorp will make every effort, when partnering with new suppliers, to ensure that they have the correct accreditation, as well as maintaining an open and positive relationship with new and current suppliers, so we are able to monitor the relationship and practices.

This includes, but is not limited to, investigating reports of modern slavery practices, audits of supplier’s business operations, implementation of a whistleblower policy and educating our staff and suppliers to come forward to report any breaches.

9.  FUTURE DEVELOPMENTS

We aim to continue to revise and develop our approach to modern slavery compliance to build capacity within our business to monitor and act on modern slavery risks.

• Publication of our Modern Slavery Policy.
• Update of our tender documents to include a Modern Slavery Supplier Questionnaire
• Review of our procurement policy and procedures to ensure inclusion of the Modern slavery clauses.
• Update of our standard procurement agreements to include modern slavery clauses.