Modern Slavery Policy

At Garolla, we are committed to upholding the highest standards of ethical conduct and human rights in our operations and supply chains. This policy outlines our commitment to preventing modern slavery and human trafficking in all aspects of our business activities.

Scope

This policy applies to all employees, contractors, suppliers, and business partners associated with Garolla, both domestically and internationally. It encompasses all aspects of our operations, including procurement, production, distribution, and partnerships, and extends to our supply chains, from raw material sourcing to finished product delivery.

Responsibilities

Management:

· Management is responsible for establishing a culture of zero tolerance towards modern slavery and human trafficking within the organization.

· They must ensure that appropriate policies, procedures, and training programs are in place to identify, prevent, and address instances of modern slavery.

· Management should provide leadership and resources to support the implementation of this policy and promote transparency and accountability throughout the organization.

Procurement and Supply Chain:

· The procurement and supply chain teams are responsible for conducting due diligence on suppliers and business partners to assess their compliance with anti-slavery and human trafficking laws and standards.

· They must incorporate contractual provisions and supplier codes of conduct that prohibit modern slavery and require suppliers to uphold ethical labour practices.

· The procurement and supply chain teams should work collaboratively with suppliers to address any instances of modern slavery identified within the supply chain and support remediation efforts.

Employees:

· All employees are responsible for familiarising themselves with this policy and understanding their role in preventing modern slavery within the organization and its supply chains.

· They must report any concerns or suspicions of modern slavery to management or the designated compliance officer promptly.

· Employees should participate in training and awareness programs to recognize the signs of modern slavery and understand their responsibilities in upholding ethical labour practices.

Policy Principles

Zero Tolerance: Garolla has a zero-tolerance policy towards modern slavery and human trafficking in all its forms. We will not knowingly engage in or support any activities that involve modern slavery, forced labour, or human trafficking.

Due Diligence: We are committed to conducting due diligence on our operations and supply chains to identify and address risks of modern slavery. This includes assessing the labour practices of suppliers, subcontractors, and business partners and taking appropriate action to mitigate risks.

Transparency and Accountability: We will maintain transparency in our operations and supply chains regarding efforts to prevent modern slavery. We will hold ourselves and our suppliers accountable for upholding ethical labour practices and complying with relevant laws and standards.

Continuous Improvement: We are committed to continuously improving our policies, procedures, and practices to prevent modern slavery. We will regularly review and update this policy to ensure its effectiveness and alignment with Australian legislative requirements and international best practices.

Reporting and Compliance

Any instances of modern slavery or human trafficking identified within Garolla, or its supply chains must be reported immediately to management or the designated compliance officer. Reports will be investigated promptly, and appropriate remedial action will be taken in accordance with applicable laws and regulations.

Training and Awareness

Garolla will provide training and awareness programs to employees, contractors, and suppliers to educate them about modern slavery, its signs and indicators, and their responsibilities in preventing it. Training will be conducted regularly to ensure that all relevant stakeholders are equipped with the knowledge and tools to address modern slavery effectively.

Review and Updates

This policy will be reviewed periodically to ensure its effectiveness and compliance with Australian legislative requirements and international standards. Updates may be made as necessary to reflect changes in laws, regulations, or best practices related to modern slavery and human trafficking.