Knowing where a product comes from is only part of responsible sourcing. We also need to understand the conditions in which it is made and make it easier for people to speak up when they have concerns.
COS has released its Modern Slavery Statement FY22, covering the year ended 30 June 2022. The statement shares what we have learned about risks in our operations and supply chains, the steps we took during the year, and where we will focus next.
What did we learn about supply chain risk?
Our highest area of potential risk continues to be the products we source and sell. During FY22, we reassessed product suppliers and expanded our risk framework to consider whether workers are provided accommodation as part of their employment. This can create additional risks relating to living conditions and freedom of movement.
COS rated two suppliers as high risk following concerns reported by customers through our internal grievance process. We increased monitoring and communication with those suppliers to help manage the identified risks. A high risk rating signals the need for closer attention; it is not a finding that modern slavery has occurred.
We also identified 14 significant Tier 1 and Tier 2 suppliers as presenting a medium risk. Across our operations and supply chain, our assessment continued to indicate a medium potential for modern slavery risks.
What action did COS take in FY22?
We put more of our responsible sourcing approach into practice. Supplier Terms and Conditions, which include a commitment to our Ethical Sourcing Policy, were implemented across suppliers representing approximately 80% of our procurement purchases. We also extended supplier self-assessment questionnaires to further groups of preferred suppliers.
Within COS, we expanded our modern slavery working group to include our Co-CEOs and introduced specialised training for staff involved in selecting suppliers and recruiting casual labour. We also made it possible for customers to raise modern slavery concerns anonymously.
With overseas factory visits affected by COVID-19, we used independent third-party audits in the relevant overseas jurisdictions.
Where will we focus next?
In FY23, we plan to add modern slavery awareness to the induction of employees in relevant roles, strengthen how we manage indirect suppliers and review the concerns raised during FY22. We will also work towards having all suppliers review and sign our Ethical Sourcing Policy, and examine our top 10 promotional product suppliers more closely.
Our second statement shows how our approach is developing as we learn more about the people and processes behind the products we supply. We will continue working with suppliers, customers and our team to identify risks and respond to concerns.
Read the full: Modern Slavery Statement 2022


