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7. Supplier adherence to our values and ethics
6.3 We investigated our supply chains and for our initial statement decided to focus on the fifty top tier suppliers and nine main service providers (as determined by spend) – being mostly suppliers and service providers to the Blooms Network Pharmacies but also including suppliers and service providers to Blooms itself. Our supply chain assessment will continue to deepen each year.
6.4 We asked each supplier and service provider to complete a survey containing questions regarding its operations, supply chain, goods and services and requesting details of any applicable polices or training that relate to modern slavery. We also requested that a copy of any modern slavery statement and/or any supporting documentation that details how the business combats modern slavery be provided.
6.5 Our personnel reviewed all information we received. We then undertook a risk assessment for each supplier/service provided based on the following.
(a) Country or region risk: We used the 2019 ITUC Global Rights Index to identify regions as high risk. In our supply chain India and China is a higher risk.
(b) Sector/industry risk: We used the 2019 ACSI and the 2018 Global
Slavery Index country specific findings report as a bases to identify sectors as high risk. In our supply chain Health Care is a higher risk.
(c) Commodity/product risk: We used the 2018 Global Slavery Index to identify commodities and products as high risk. In our supply chain plant and animal based products, in particular cotton is a higher risk.
6.6 From the top fifty suppliers, two suppliers have identified within their own businesses that there is evidence to suggest modern slavery is occurring within their supply chain. These businesses have confirmed they will put measures in place to put a stop to modern slavery.
6.7 Should a supplier or service provider not act or work towards eliminating modern slavery, we will review the terms of the agreement in place.
6.8 Each potential case will be reviewed on a case by case scenario and may result in terminating existing agreements.
7.1 We have a zero tolerance of slavery and work to ensure all those in our supply chain and contractors comply with our values and ethics. Should we suspect that there is modern slavery in the supply chain we are to notify our General Counsel and report this in accordance with our Whistle Blower Policy.
7.2 Our dedicated compliance team, consists of the following:
(a) Our General Counsel, Dianne Hamilton, ensures that Blooms is in compliance with all applicable laws. Direction is provided on how we continue to combat modern slavery and guidance is given should we need to terminate any agreements with a supplier and/or service provider who is not able to meet the requirements of our Modern
Slavery Policy (when in effect). Our General Counsel ensures that we and any of our affiliated parties comply with our Code of Ethics and
Conduct.
(b) Our Audit, Risk and Governance Committee is a sub-committee of our Board. This Committee ensures that the business meets applicable audit requirements and reviews compliance systems put in place by Blooms. (c) Our People and Culture business unit, facilitates and assists with development of business strategies. This business unit is driven by
Kelly Hyland. Kelly’s team ensures that all policies are in place and are reviewed. Should any policy be breached or where misconduct has occurred, the team will facilitate the appropriate course of action as described in the Whistle Blower Policy. (d) Our merchandising business function supports our stores and manages supplier expectations. The Merchandise team liaise with suppliers directly and are the first point of contact. Merchandising also review and conduct risk assessments of all suppliers and ensure that suppliers are endeavouring to combat modern slavery.