2020

Lowes Manhattan Pty Ltd MODERN SLAVERY STATEMENT

Lowes Manhattan Pty Ltd Modern Slavery | 1 AUSTRALIAN ICON SINCE 1898

MANAGING DIRECTOR Mrs Linda Penn DIRECTOR Mr Jeffrey Mueller

SENIOR LEADERSHIP MANAGING DIRECTOR / CEO MRS LINDA PENN This Document is approved by the principal governing body of the Chief Advisor Lucy Gibson entity Mrs Linda Penn set out in Chief Advisor Sarann Ryan the Modern Slavery 2018 (the Act) as per section 31(2). Chief Financial Officer Jim Kondonis Head of People Jason Heap MRS LINDA PENN Head of Merchandise Michael Manios CEO/ MANAGING DIRECTOR Head of Property David Johnston

LOWES PANEL FOR MODERN SLAVERY COMPLIANCE Chief Advisor Sarann Ryan Head of School-wear Timothy Bryant Head of People Jason Heap Head of Merchandise Michael Manios

CONTINUOUS IMPROVEMENT COMMITTEE Team Leader Tim Zhu Chief Advisor Sarann Ryan Head of School-wear Timothy Bryant Buyer Menswear Don Phrachanh Buyer School-wear Kathy Adair

2 | Lowes Manhattan Pty Ltd Modern Slavery Report 2020 Lowes Manhattan Pty Ltd Modern Slavery | 3 CONTENTS Identify the reporting entity ENTITY 3 Directors | Leadership 6 Modern Slavery statement 8 Reporting entity Describe the structure, 9 Structure | Turnover operations and supply chains 10 Mens Finance company

STRUCTURE | OPERATIONS 11 Suppy Chains 14 Our store locations 16 Our Brands 18 Lowes school uniforms

Describe the risks of modern RISK slavery practices in the operations and supply chains 25 Identifying, Mitigating & Remediating risk of Modern Slavery The reporting entity consulted on its statement 27 Consultation with controlled entities with any entities it owns or controls 28 List of suppliers and risk

Describe what actions the ACTIONS reporting entity is taking to assess and address the risks 30 Timelines of modern slavery practices occurring 32 Addressing Modern Slavery | Lowes Panel 33 Lowes training & Internal accountability 35 Lowes Gateway process 36 Audit schedule 37 2021 commitments

Include information that ANNEXURE you think is relevant, but that is not covered by the other six mandatory criteria 41 Lowes whistle-blower policy

4 | Lowes Manhattan Pty Ltd Modern Slavery Report 2020 Lowes Manhattan Pty Ltd Modern Slavery | 5 LOWES MODERN SLAVERY STATEMENT

As a leader in the retail industry, Lowes takes its Lowes staff members conduct inspections of the Lowes’ goal is to only engage suppliers who Lowes will not source from a manufacturer who ethical and social responsibilities seriously. We are facilities and working conditions for all suppliers operate under acceptable human rights conditions fails one of these annual audits. committed to upholding human rights and fair in the countries we source from. and protect workers’ human rights. To monitor this, Lowes seeks to form close, long-term working conditions and ensure that our suppliers every supplier is subject to an independent audit Additional to this, Lowes has engaged third relationships with its providers to better enable adhere to our legal, moral and ethical standards on an annual basis. Audits conducted under the party provider ‘Intertek’ whom is a globally us to ensure that these guidelines are enacted. that are governed by the 2018 Modern Slavery Business Social Compliance initiative (BSCI) which recognised leader in governance and assurance Act. is an initiative of the Foreign Trade Association This statement is made pursuant to section 11 (2) to conduct Audits of our factories and validation (FTA) are an example. of the Modern Slavery Act 2018 and constitutes We ensure that all products we purchase come on previously obtained aduit assessments. the Lowes – Manhattan Pty Ltd’s slavery and from ethical sources and that we, by association or Lowes will not accept, under any circumstances, human trafficking statement for the financial year otherwise, are not party to any illegal or unethical any of the following practices from the suppliers The audit covers the following areas. ending 2020 and was approved by the CEO on manufacturing practices. we deal with: 30th of June 2020. • Producer’s background We have a range of measures in place that form our responsible sourcing guidelines. All • Management practice • Child labour employees of Lowes, or agents working for Lowes, • Health and social facilities SIGNED: MRS LINDA PENN must always comply with these guidelines. They • Unsafe working conditions must ensure that any supplier, either local or • Occupational Health and Safety • Illegal conduct offshore, must always fully comply. • Dormitories (if applicable) • Corruption The following represents the minimum • Environment requirements Lowes requires in regards to all our • Excessive work hours • Documentation suppliers. • Discrimination • Working hours All suppliers, either local or offshore, must comply • Forced labour of any kind with all laws, regulations, building codes, and • Compensation industrial regulations of the country or countries • Denial of the right of freedom of association • Child labour in which they operate, always. and of collective bargaining. • Young Workers Every factory that produces garments for Lowes • Inhumane treatment must provide Lowes or its agents with their • Forced labour annual compliance certificate. • Disciplinary measures Work conducted for Lowes cannot be • Prison labour subcontracted to another supplier. To ensure this every production run is checked both during • Freedom of association manufacturing and at the time of shipping • Collective bargaining to ensure compliance as part of our quality assurance process. • Discrimination/harassment and abuse • Working conditions.

6 | Lowes Manhattan Pty Ltd Modern Slavery Report 2020 Lowes Manhattan Pty Ltd Modern Slavery | 7 REPORTING ENTITY OUR STRUCTURE ENTITY: LOWES - MANHATTAN PTY LTD QUICK STATS ABN: 31 000 307 666

Lowes is a leading Australian menswear, young Today, Lowes continues to offer the public a range EMPLOYEES : 1206 Lowes has a combination of employees comprising of store staff both menswear and schoolwear retail chain offering of well-made clothing at affordable prices. Lowes SENIOR LEADERSHIP 7 permanent, part- time and casual and head office support. well-made clothing at affordable prices. has expanded from its traditional offering of HR 7 The head office support has two separate divisions Menswear and menswear and business wear to offer a full range As a family-owned business, Lowes is part of a FINANCE 13 Schoolwear. With field support comprising of Area and State Managers of school wear, menswear, sportswear, active wear, small but elite group of companies, which have MARKETING 5 for the store network and Account Managers for the school network. footwear and work wear. been in business for 122 years and still 100% IT 10 Lowes is a 100% Australian family owned company and has always Australian owned. Lowes Annual turnover ranges between 240 Million SCHOOL-WEAR 33 had a family feel to its culture, this is shown in how many of its staff and 230 million with on average six and a half For over a century, the company has been built CORPORATE 3 have been employed for 10, 20, 30 or 52 and counting years. But it’s million transactions per year. on integrity, forward planning and financial BUYERS 7 also shown in how our staff view Lowes as an employer. Lowes has success. Today, with 192 stores nationwide, it PLANNERS 3 won “Retail Employer of the Year” in the large employer category for continues to expand steadily as it has for many ADMIN 8 3 years running. This award is voted on by the employees of Lowes. years. LEASING 1 Lowes values its employees and works hard to ensure that we are an employer of choice with fairness at the heart of everything we do. In a brand conscious society, while many outfitters have paid dearly to charge more for STORES 192 a somewhat pretentious, upmarket image, See pg 12 Lowes have maintained a simple, down to Anual turnover earth integrity in the way they have conducted business for over a century. Since it was founded $235,500,000.00 SCHOOLS: 742 in 1898, it has grown from a traditional “value for money” menswear store to become a well-known NSW 522 Australian icon in its own right. ACT 84 QLD 108 Transactions SA 19 WA 50 VIC 79 6,500,000 TAS 7 NT 1

SUPPLIERS: 219 HEAD OFFICE See pg 24

HEAD OFFICE: 240 Arncliffe 2205 SUPPLYCHAIN | FREIGHT State Office QLD Unit 2/56-58 Burchill St Loganhome 4129 3PL’s 1 Lowes “Retail employer ROAD FREIGHT 3 State Office VIC Unit 29/350 Settlement Rd Thomastown 3074 FREIGHT FORWARD 1 State Office WA Unit 3/3 Brennan way Belmont West 6104 CALL CENTRE 1 of the Year” 3 consecutive years!

8 | Lowes Manhattan Pty Ltd Modern Slavery Report 2020 Lowes Manhattan Pty Ltd Modern Slavery | 9 SUPPLY CHAINS OUTSOURCED LOGISTICS

MENSWEAR FINANCE COMPANY (MFC) 5.5 MILLION UNITS PER ANNUM ZERO | EZYWAY SERVICING MENSWEAR FINANCE COMPANY (MFC) SCHOOLWEAR ABN: 21002677778 & MENSWEAR FROM IWS MINTO MFC is a wholly owned entity that provides an LOCATION in-store finance card for customers of Lowes TO OUR STORE menswear operating under the business name NETWORK “Lowes Zero”. Its operates out of Lowes Menswear Arncliffe Head office and provides services solely for Lowes Menswear.

ACTIVE USERS: 133,306 AVERAGE APPLICATIONS PER YEAR: 23,710

Established in the early 1950’s by Hans Mueller as one of the first credit providers in Australia, his mantra ‘pay as you wear’ was an instant success, it was relaunched in 2016 under the new product

‘ZERO’ managed by ezyway. WS. * image of our 3PL Minto I 3PL INDEPENDENT WAREHOUSE SOLUTIONS LOCATION: , AUSTRALIA The Lowes credit facility is highly compliant and governed by responsible ABN: 51 611 960 297 lending criteria, Lowes adheres to the strict NCCP legislation to maintain its IWS is a Sydney-based third-party logistics (3PL) services company credit lending license. committed to consistent and continuous improvement within the warehousing and distribution operations industry. Extensive range of value-add services at 2 Western Sydney facilities with over 18,000 sqm Implementing best practices throughout supply chain, state of the art The Zero card technological EDI solutions and system integration promotes efficiency and accuracy and reduces manual handling and cost. represents 10% of Employing 55 employees executives and all other employees coveded by the Australian award scheme. Three Lowes employees are permanently situated at the Minto facility Lowes sales working in collaboration with the IWS team.

10 | Lowes Manhattan Pty Ltd Modern Slavery Report 2020 Lowes Manhattan Pty Ltd Modern Slavery | 11 SUPPLY CHAINS OUTSOURCED LOGISTICS

FRIEGHT STOCKWELLS - STOCKWELL INTERNATIONAL PTY LTD CALL CENTRE BDE GROUP ABN - 19000871330 LOCATION: FIJI SYDNEY | QLD ABN 68 601 293 403

Operating for 49 Years with; 14 agents 28 employees on Clerks Private Sector Award. 4000 inbound calls from Australia per week 22 employees on Roads Transport Distribution Award. The call center assist in taking calls for the ZERO card, customer 6 salaried employees. care for our online division and service our head office switch. “ To Provide the highest level of service – whether it is by air, sea or road at a BDE supply telephone system, IT Development, Applications competitive rate that will satisfy our client’s needs each and every time” software, Provide Australian support and management of Stockwell International maintains the objective to ensure respect of human outsourcing to Greymouse in Fiji . rights of individuals. All employees should enjoy a work environment free Lowes staff inspect the working conditions in Fiji 4 times per year from all forms of modern slavery. to ensure working conditions and standards. Stockwell International all staff support the responsibility to respect human BDE has star rating in Fiji with their employees getting paid 10- rights and as a business enterprise Stockwell International retains the duty of 15% above award. avoiding causing or contributing to adverse human rights impacts through The call center also has a drop off policy where all staff are driven their own activities, and address such impacts when they occur. Stockwell home after their shift or a taxi is provided. International seek to prevent or mitigate adverse human rights impacts that are directly linked to their operations, products, or services by their business A Security guard stands watch after 6.00pm every day and relationships, even if they have not contributed to those impacts. monitors all activity. Stockwells policy here is to treat every suspicion seriously and report all All staff have a Rostered Day off and have the 10 day sick leave per modern slavery concerns to the appropriate authorities. By doing the right year as well as 4 weeks annual leave. thing, we can try and abolish modern slavery for a brighter and fair future for Greymouse is an equal opportunity employer and employs everyone. indigenous Fijians, Fijian Indians and other nationalities. Operations o/s affiliated or owned – (Staff for overseas offices not included in BDE have escalation procedures to raise any workplace issues. above staff numbers as they fall under their own offices). We are an Equal Opportunity employer and are ISO accredited in Health and Safety, Environment and Quality procedures and systems. We are audited yearly. With regards to our overseas offices they are also audited yearly for working conditions and acceptance and signing of all company policies and procedure (New Zealand/USA) With regards to our agents, as they are a service provider only (FOB) and the person exporting the goods (or the owner of the supply chain) falls under their own modern slavery system, we have agreed to yearly office visits to our high volume countries.

TOLL See Tolls Modern Slavery statement https://www.tollgroup.com/about/policies-procedures/ modern-slavery-act-statement

AUSPOST | STARTRACK See Australia Post Modern Slavery statement https://auspost.com.au/content/dam/auspost_corp/media/ * image of our fijian call centre in Suva, Viti levu. documents/publications/2019-australia-post-annual-report.pdf

12 | Lowes Manhattan Pty Ltd Modern Slavery Report 2020 Lowes Manhattan Pty Ltd Modern Slavery | 13 OUR STORE LOCATIONS

Airport West Corio Lake Haven Melton Rouse Hill Corner (Park House) Leichhardt ‘Lowes has 192 Menai Runaway Bay Armadale WA Cranbourne Park Lilydale Merrylands Salamander Bay Armidale Dalby Lismore stores nation Midland Gate Savvy Tuggeranong Arndale SA Dapto Lithgow Mildura Seven Hills Ballarat Central Darwin Liverpool Minto Shellharbour Ballina Dubbo Loganholme wide!’ Miranda Shepparton Bankstown East Hills Girls High School Macarthur Mirrabooka Singleton On Campus Bateau Bay Macdonalds Jamison Morayfield Southport Elanora Batemans Bay Mackay Morwell Springfield Elizabeth Bathurst Macquarie 2 Mt Druitt St Joseph’s On Campus Ellenbrook Shop Beenleigh Maddington Mt Gambier Erina St Marys Belconnen Maitland Mt Gravatt Fairfield Stafford Belmont Mandurah Mt Pleasant Figtree Strathpine Belmont WA Maroochydore Murray Bridge Forster Taigum Bendigo Lansell Square Marrickville Muswellbrook Fountain Gate Tamworth Bendigo Marketplace Maryborough Narellan Glendale Blacktown 6 Newcastle Glenorchy Tea Tree Booval Noosa Gosford Toombul Brimbank Normanhurst Campus Goulburn Shop Toormina Brisbane Grafton North Lakes Top Ryde Broadmeadows Grand Central Northland Townsville Browns Plains 3 Green Hills Nowra Tuggerah Bundaberg Griffith Oakleigh Tuggeranong Burwood Plaza Gungahlin Ocean Keys Tweed City Cairns Central 51 Gympie Orange Victoria Point Cairns Earlville Head Office Pagewood Wagga Wagga Cairns Smithfield Helensvale Palmerston Warrawong Caloundra Hervey Bay Parabanks Warriewood Campbelltown Highpoint Parramatta Warringah Mall Campsie Hornsby Penrith Warrnambool Capalaba Park Horsham 81 Perth Modern School On Warwick Carindale Campus Hurstville Waverley Gardens Carlingford 11 Plenty Valley Inala Plaza Werribee Castle Plaza Port Macquarie Ingle Farm 9 West Lakes Castle Towers Queanbeyan Jesmond Wetherill Park School Castletown Raymond Terrace Uniforms Joondalup Centenary Redbank Kardinya Park Cessnock Richmond Woodcrest State college Karingal Hub Charlestown Riverlink Woodridge Kawana 28 Chatswood Robina Woy Woy Kingaroy Chermside Rockdale Wynnum Kippa-Ring Clifford Gardens Rockhampton Yeppoon Kirwan Coffs Harbour Rockingham Knox Colonnades Roselands Kotara Coomera 2 Rosny Park 15 14 | Lowes Manhattan Pty Ltd Modern Slavery Report 2020 Lowes Manhattan Pty Ltd Modern Slavery | 15 COUGARS QUIK DRY LOOP FOLD LABEL

**Design and artwork is intellectual property OUR BRANDS of First Choice Distributors Pty Ltd.

Lowes OUR CATEGORIES APPAREL TYPES Big Mens Shirts lowes Kidswear Tops Work-wear T-Shirts Baby @ Lowes Unisex Tanks Pets @Lowes Hawaiian Polos Vests Outdoor-wear ACTUAL SIZE : DBK Blazers SIZES TO CHANGE ON MAIN LABEL: Formal Wear Shorts COUGARS School-wear Trousers Sportswear Jeans APPAREL Elliott’s Chinos Swimwear Overalls Traders Matchy Matchy Suits Prodigy Business Wear Work Boots Training Shoes Underwear Socks & PJ’s Manhattan Socks S M L Shoes & Accessories Jackets POLYESTER WARM MACHINE WASH Iconic Soul Baby-wear Jumpers WITH LIKE COLOURS DO NOT BLEACH Hats DO NOT SOAK Dog Wear DO NOT RUB Beare & Ley Business shirts LINE DRY ROBERT HUNTLEY WARM TUMBLE DRY COLLECTION Home & Gifts DO NOT IRON TRIM OR Underwear Socks & PJ’s PRINTS Botany Bay Traders COOL IRON ON REVERSE Rashies DO NOT DRY CLEAN X Robert Huntley Swimwear Towels Riley Adams Tunics Skorts XL 2XL Outer Peak Blouses Womens Business Skirts ESSENTIALS BY LOWES Anglers Edge Sports Representive Traders 308 Leavers bespoke tshirts / jersey MAIN LABEL COLOURS: Perizzi DISTINCTIVE PROCESS BLACK Maxsport CYAN NAVY GREY Street SCUBA BLUE- EXCLUSIVE TO LOWES PANTONE 16-4725 TPX

OPTICAL WHITE Woven Label Design

Baby at Lowes

Swing Tag Design

16 | Lowes Manhattan Pty Ltd Modern Slavery Report 2020 Lowes Manhattan Pty Ltd Modern Slavery | 17 “LOWES PROVIDING A PREMIUM CONVENIENCE TO LOCAL SCHOOL COMMUNITIES ALL OVER ‘THE GREATEST RISK OF WASTE IS AUSTRALIA, SELLING TO SCHOOLS FOR OVER 100 YEARS!” TRANSITIONING UNIFORMS, OUR CONTRACTS UPHOLD A BI-LATERAL WASTE MANAGEMENT AGREEMENT THAT SHARES EQUAL RESPONSIBILITY BETWEEN RETAILER AND THE SCHOOL ‘

LIST OF SCHOOLS

Georges River College Marist College - Kogarah Masada College St Mary Mackillop College Carlingford High School Homebush Boys High LOWES SCHOOLS Perth Modern High School Freeman Catholic College St Aloysius St Clare's College Ellenbrook Secondary Pascoe Vale Girls College St Patricks College Sutherland Casimir College Years 7-10 Glenala State High School Lowes Schoolwear is the largest provider of school Catholic Education Department, Parramatta Wollondilly Anglican College Y Strathfield Girls High Oran Park High School uniforms around Australia. As part of the process in Archdiocese -Uniform Supply panel of preferred Patrician Bros Fairfield Magdalene Catholic High School Caroline Chisholm Glenmore Par securing and retaining business Lowes participates suppliers Cardijn College Mackay North State High School in Tenders for schools and request for Tenders Catholic Education Department, Wollongong with procurement departments, including various Mccarthy College Tamworth East Hills Girls High School Henry Kendall High Uniform Supply panel of preferred suppliers religious archdiocese and state governments Arthur Phillip High School Karabar High North Sydney Girls High School around Australia. Lowes submissions are Sydney Catholic Schools -Uniform Supply panel of Waverley Christian College Campbelltown Performing Arts Springfield Central State Scho required to satisfy criteria as set out in the tender preferred suppliers John Therry Catholic High Port Hacking High School Junio Asquith Boys High Yr 7- 8 documentation with past performance taken Note: Lowes at present have submitted Cherrybrook Technology H/S Telopea Park School Hunter Sports Hs Gateshea into consideration. Successful candidates must applications Requesting for Tender with ACT and Marist Sisters College Woolwic John The Baptist Ps Gympie High School provide evidence and satisfy contractual terms and SA Government. Lilydale High School Normanhurst Boys High School Hunter River High conditions during tenure. Terms and conditions Emmaus College Lisarow High School are established to not only serve community Additionally, Lowes is currently tenured with St. Patrick's Marist College D Gladstone Park Secondary Colle Terrigal High School expectations, but to satisfy requirements with various schools under Department of Education applicable regulations or regulatory frameworks. NSW, ACT, Victoria And Tasmania contracts. Ryde Secondary College Sydney Technical High St. Pauls High School - Yrs 7- Aquinas College Tamworth High Lowes is and has been in contact with schools Cronulla High School Burwood Girls Harrison School facilitating the supply of uniforms for over half CONTINUOUS IMPROVEMENT COMMITTEE AND St. John's High Nowra Oxley High Tamworth Good Shepherd Plumpton a century. In recent times the move to centralise OUR RECYCLING PROGRAM procurement for various groups has resulted Our waste Management approach is complicated Epping Secondary College St John Bosco High College Eng Champagnat Catholic College in supplier qualifying under overreaching comparative to regular fast fashion. Our garments Endeavour Sports High School Camden High School Tempe High School arrangements to ensure adherence and compliance are bespoke distinctive wear that cannot be resold Hume Central Secondary Collage Xavier High School Oak Flats High School with but not limited to, practices regarding, or reused based on copyright and contractual Woodcrest State College Murrumbidgee Regional High Sch Rosehill Secondary College labour regulations, ethical employment practices, obligations. Saint John Paul Ii College Kirwan State High School Mary Immaculate Ps Boss Park environmental impacts and Workplace health and This paved way for an affiliate program monitored Maronite College Mernda Primary Lara Secondary College safety. by our continuous improvement committee to have Blakehurst High School All Saints College Bethlehem College Lowes Schoolwear has qualified under these our textiles recycled and prevented from landfill. La Salle College Bankstown Holy Family Primary Menai Amaroo School arrangements based on our experience and We use an Australian Firm; MANRAGS https:// Oran Park Public Hornsby Girls High School Rutherford Public School performance with initiatives in place to ensure manrags.com.au to manage our oversupply of fabric Mount St Joseph Secondary Scho Keira High Wagga Wagga Christian College compliance and continual improvement, with the that cannot be resold or reused. St Marys College Ipswich Macquarie Fields High School St Justins Primary following governing bodies. Of our discontinued schoolwear range we also Kildare Catholic College Callaghan Waratah Campus Coburg High Queensland Government DETSOA 78764 Standing donate school uniforms to developing countries Kalamunda Senior High School Jubliee Primary School Manning Valley Ac Yrs 3-6 Offer of Arrangement for provision of school such as Fiji, Papua New Guinea and Pakistan. Richard Johnson Anglican Yrs 1 Jerrabomberra Public School uniforms and accessories St Francis Xavier College Wamberal Public Crusoe College Our continuous improvement committee join the Western Australian Government ED19088 Supply Sports High School St Catherine Of Siena Preston Lowes Modern Slavery panel on request to pitch of School Uniforms and Specialty School Apparel – for new and improved methods to handle waste Lavalla Catholic Colleg Tlsc - Tumbi Umbi Campus Ambarvale High School Panel management and sustainability. Phoenix College De La Salle Revesby St. Therese's Primary New Lamb St Joseph College Randwick Boys High School

18 | Lowes Manhattan Pty Ltd Modern Slavery Report 2020 Lowes Manhattan Pty Ltd Modern Slavery | 19 Blue Haven Public Bethany Primary - Glenmore Par Northern Beaches State High School Mount Annan High St Marys Star Of The Sea Hurst Secret Harbour Primary School St Marys Primary Ipswich Dapto Public School St Joseph East Maitland Singleton Public School Beverly Hills North Public Sch Holy Spirit Primary Nicholls Kooringal High Gold Creek School Heatley Secondary College Our Lady Of Mercy College Burr St Marys Primary Dubbo Mount Stromlo High School St Andrews Christian College Emmaus Christian School Wagga Wagga Lutheran School Glenroy College St Ann's School Rose Bay High School Blacktown Boys High St Pius Primary School, Banyo Camira St Mary's Primary Rydalmere White Friars Catholic School Belconnen High School St. Mary's Ps Warners Bay Warnervale Public School St Thomas Ps Willoughby All Saints Ps Liverpool St Keiran Catholic Primary Good Shepherd Primary Amaroo Tlsc - The Entrance Campus Our Lady Of Rosary Ps Kensing Runcorn Heights State School De La Salle Boys College Ashfi Thornton Public School Stella Maris Catholic Primary Grandis Primary School St Francis Of Assisi Primary Arbor Grove Primary Springfield Lakes State School Sarah Redfern High School St Josephs Moorebank St Paul's Camden Primary Coolamon Central School Ellen Stirling Primary School Spring Farm Public School West Wallsend High Thuringowa State High Mary Immaculate Ps Eaglevale Picnic Point Hs Chifley College - Bidwill Glendale High Canberra High School Salisbury High School St John's Catholic Primary Sch St Michaels Ps Tralalgon St Johns Primary Dubbo The Hills Sports Snr Wyong High School Maitland Christian School Griffith North Public School Woolooware High School Howrah Primary School St Gregorys Primary Carlton Public Melba Copland Secondary Sch St Josephs Merewether Upper Yarra Secondary College De La Salle College Caringbah De La Salle Senior College Cro Richard Johnson Anglican Yrs 7 Red Cliff Secondary College Bellingen High School St. Therese Ps West Wollongong Asquith Girls' High School Ballarat High School Putney Public School Holy Cross Ps Trinity Park Heathcote High School St Josephs Primary Tweed Heads Sacred Heart Ps Booval Mother Teresa Primary School Marrickville High School Saint Helena's Catholic Primar St Joseph's Ps Warrnambool Pearsall Primary School Canterbury Girls High Al Zahra College All Saints Ps Seaford St Michaels Nelson Bay Orange High School Border Christian College Immaculate Heart College Aveley North Public St Carthage's School Lismore Surveyors Creek Public School St. Aidan's Primary Rooty Hill Richmond River High Our Lady Of The Rosary F'field Kingsgrove High School St Mary & Josephne Primary Sch Kurnai College St Anthony's Ps Wanniassa Camden South Public Kogarah High School St Mary's Primary Sch Casino Helensvale State School Lake Gwelup Primary School Wheelers Hill Secondary College All Saints Senior Catholic Hig West Lakes Shore School R-7 St. Michaels Nowra St Thereses Ps Bentley Pk St Therese Ps Mascot Coorparoo Secondary College Belmore Boys High Ashfield Boys High Strathfield South High Thomas Reddall High Clontarf Beach State School Gungahlin College Kingaroy State High School St Patricks Primary Griffith Aveley Primary School Dubbo Public Malvern Springs Primary School Tamworth Hamilton South Public Kanwal Public Yarra Hills Secondary College Good Shepherd Catholic School St Martha's Primary Strathfiel Tamworth Public School Orara High Coffs Harbour Timboon P-12 School Merrylands High School Good Shepherd Ps Hoxton Pk North Bundaberg State High Sch Sacred Heart Primary Cabramatt Neville Bonner Primary School St. Patricks Ps Blacktown Lismore High School

20 | Lowes Manhattan Pty Ltd Modern Slavery Report 2020 Lowes Manhattan Pty Ltd Modern Slavery | 21 Minchinbury Public Cobbitty Public School Jurien Bay District College Emu Plains Public Our Lady Sacred Heart Merbein Monash Primary School Thurgoona Public School St Mary's Ps Warwick Craigie Heights Primary School Dallas Brooks Community Primar Aranda Primary School Wyoming Public School St. John's Ps Campbelltown Currajong State School Holy Spirit Ps Lavington Gwynneville Public Our Lady Of The Rosary Waitara Wyrallah Road Public Our Lady Of The Rosary St Mary Horsham West & Haven Primary Rainbow Street Public School St Josephs Primary Kilaben Bay Woori Yallock Primary School West Goulburn Public School St. Benedict's Primary Edgewor Arkana College Kingsgrove Sarah Redfern Public St Laurence's Dubbo Calare Public School Lyneham Primary School St Patrick's Parish Ps Albury St Anne's Ps Nth Albury Highfields Prep & Kindy School Gymea Technology High School Eaglehawk North Primary Meadows Primary School Hillarys Primary School Nambucca Heads High School Sacred Heart Primary School Canley Vale Public St Matthew's Primary School Nanango State High School Edney Primary School Elermore Vale Public School St.josephs Primary Oatley Lake Albert Public School St Benedict's Primary School Our Lady Of The Assumption, En Butler Primary School James Cook Boys Technology Hig Our Lady Of The Way Ps Emu Pla St. Anthonys Primary Marsfield Sir Joseph Banks Holy Trinity Primary Wagga Nazareth Catholic Primary Unanderra Public William Ross State High School Turner Primary School East Hills Boys Kelso Public Matraville Sports High St. Nicholas Primary Tamworth Bathurst Public School St.pius X School Unanderra Galilee Catholic St Mels Primary Campsie Jones Hill State Primary Schoo St James Primary Belair Public School Merriwa Primary Fairview Heights State School Catherine Mcauley Mount Clear College Our Lady Help Of Christian Ear Merewether Heights Public St. Cecilia's Ps Wyong Findon Primary School East Griffith Public St Pauls Ps Gateshead Mortdale Public School The Hills Sports H/S Jnr Fitzgerald State School St Dominics Ps Broadmeadows Corpus Christi Ps St Ives Canterbury Boys High Mary Help Of Christians Toormi Moana Primary School St Edward's Primary Tamworth Barraba Central School Balga Primary School Ramsgate Public School Holy Family Catholic Ingleburn Calvary Lutheran School Pitt Town Public Chifley College - Dunheved Cam Kooringal Public School Heritage Christian School K-5 Delacombe Primary School Woodmans Hill Campus Ngunnawal Primary School St Vincent's Primary School Melrose High School Brandon Park Primary Cronulla Public School St Gerard's Primary School Aberdeen Public School Mcauley Primary School St Josephs Ps Bulli Canobolas Rural Techology Hig Rosetta Primary School Golden Square Primary School Aldridge State High School Southern Montessori School Queen Of Apostles Primary Scho Grahamstown Public School Yale Primary School St John Vianney Ps Morisset Taree West Public School St. Thomas More School St Gertrudes Smithfield St Vincent De Paul Ps Hendon Primary School Orange Public School Townsville Central State Schoo Pioneer State High School Gooseberry Hill Ps Durack State School St Peters Primary Stockton Keilor Heights Primary Blair State School St Brendan's Ps Bankstown Trinity Ps Kemps Creek Figtree Heights Public School Rasmussen State School St Marys District School St Mary's Catholic School Belmont High Maida Vale Primary School Leda Primary School Moonee Ponds West Primary Sch St John The Apostle Primary Campsie Public School Horsham Primary School Vincentia Public St. Therese's Ps Denistone St Mary Magdalene's School Werrington County Public Schoo Westdale Public School Mildura West Primary School Kingsford Smith School Ipswich East State School St Josephs Rockdale Holy Family Primary School New Town Primary School St. Declans Primary St Margaret Mary's Primary Sch Penola College Buy Back Branyan Road State School St.luke's Ps Revesby Mackillop College Bathurst Cambridge Park High Palmerston Primary School Richard Johnson Anglican Schoo St. John's Ps Lambton Anne Hamersley Primary School St Francis Xavier Ps Ashbury Kingsgrove Public School St. Joachim Ps Lidcombe Sans Souci Public Queanbeyan East Primary Our Lady Of Mt Carmel Primary Colyton Public School St Joseph's School, Nundah Bucasia State School Maddington East Ps Richmond Primary School Beaconsfield State School St Brigid's College St Anthonys Primary Clovelly Mundingburra State School Chatham High St. Felix Ps Bankstown St Patricks Primary Wallsend Bohlevale State School Hughes Primary St Brigids Primary Gwynneville Golden Square Primary Red Hill Public School Woongarah Public School Holy Spirit Carnes Hill Granville South Creative & Per Queanbeyan West Primary School Kennington Primary School North Parmelia Primary School St. Francis Xavier Ps Arncliff St Thomas Aquinas Primary Serviceton South State School Nareena Hills Public School Quarry Hill Primary St. Raphaels Primary Oxley Vale Primary School Lindisfarne Primary School St. Christophers Primary Panan St. John Vianney Doonside Nulkaba Public School Mabel Park State School Moorefield Girls High School St. Patrick's College Mackay Avondale Primary School Grafton Public School Penola Catholic College Holy Family Emerton J J Cahill High School Warwick West State School St. Marys Primary Georges Hall Queanbeyan South Primary Sch Albury Public School Raglan Public Palmerston Chrstian College Pleasant Heights Public Our Lady Queen Of Peace Quinns Rocks Primary School Murray High School Bambara Primary School West Tamworth Public Emmaus Catholic Primary School Irrawang Public School Bethel Christian School Mt Dru Tomaree Public School Heatley State School Playford College Our Lady Of Annunciation Ps Churchill State School Arncliffe Public School Goodna State School Caroll College St Joseph's Kingswood Our Lady Help Of Christian Ros Mountview High Cessnock The Entrance Public School St Michael's Primary School Nursery State Special School Keilor Primary School St Clare Of Assisi Primary Antonio Catholic School Kirwan State School Namadgi School St Joseph's Primary School Eleebana Public School Weetangera Primary School Waraburra State School Glengarry Primary School Weir State School Queens Park Primary School Metella Road Public School Hassall Grove Public School Torrens Primary School St. Therese Primary Sadlier St.john The Apostle Narraweena St Brendan's Primary School Anna Bay Public John Calvin Christian School Wanniassa School K-10 Lavington Public School Canterbury South Public Fadden Primary Chifley College - Mt Druitt Ca Armidale Secondary St Andrews Christian Community Toormina Public Yarrilee State School Oakey State High School St.patricks Primary Kogarah Our Lady Of Dolours Chatswood Swansea High Leonay Public School St. Paul Of The Cross Ps Enmor St Patricks School Bundaberg St Michaels Primary Meadowbank St John The Apostle Ps C Beach Westport Primary School Gundagai High School St Philomenas Primary Our Lady Of Victories Ps Townsville State High School Holy Cross Ps Kincumber Majella Primary School Melton West Primary St Patricks Ps Port Kembla Woodport Public School Wedge Park Primary School Fort Street Public School Ben Venue Public Armidale St Joseph's Primary Wagga Wagg Riverview State School St Kevins Eastwood Tamworth South Public High School St Nicholas Of Myra Primary Rosewood High School Fairfield Heights Primary Scho Our Lady Help Of Christians St Mary Mackillop Ps Sth Pnrth Seven Hills High School Our Lady Help Of Christian Hen St Joseph Primary Bileola Campbelltown North Public Scho St Anthony's Ps Kingscliff Assumption College Hillston Central School Our Lady Of Rosary Ps Wyoming Holy Family Primary Luddenham Maryborough State High

22 | Lowes Manhattan Pty Ltd Modern Slavery Report 2020 Lowes Manhattan Pty Ltd Modern Slavery | 23 Our Lady Queen Of Peace Glades Coomealla High School Hillvue Public School Blessed Sacrament Primary Scho Preston North East Ps Gowrie State School St. Fiacres Ps Leichhardt Abermain Public Tallangatta Primary School Villa Maria Primary School East Goulburn Public Timbumburri Public School Verity Christian College St Francis Assisi Ps Warrawong Theodore Primary School Forest Street Primary St Monica's Primary School Goodna Special School Cessnock West Public School East Maitland Public School St Mary's Catholic Ps Armidale Annandale State School Holy Family Elc Toukley Public Osborne Primary School St Joseph's Primary Tamworth Macgregor Primary School Fraser Primary School St Pius Dubbo St John The Baptist Ps Maitlan Bletchington Primary Muswellbrook Public Black Mountain School St. Columba's Ps Leichhardt Nt St Mary’s School Wellington St Brendans Primary Annandale St. Bernadettes Dundas Valley Ashtonfield Public School Aitkenvale State School Sandgate State School Callaghan - Jesmond Senior Cam Broadmeadows Primary School Cundletown Public School Morwell Park Primary St Monicas Primary Footscray Kangaroo Flat Primary Kurri Kurri Public School Table Top Public School Marcellin Technical College Maddington Primary P&C Assoc. Wondai State School Broadmeadows Valley Primary Sc Byford John Calvin School Sacred Heart Primary School Wagga Wagga Public School St. Oliver's Harris Park Inala State School St John The Baptist Freshwater New Lambton South Public Schoo Walkerston Primary School Northview State School St Annes K-10 Temora Oonoonba State School Redbank State School Ballina Primary School Chifley College - Shalvey High RISK Fern Bay Public School Rosary Primary School Hendra State School IDENTIFYING, MITIGATING & REMEDIATING RISK OF MODERN SLAVERY Charlestown South Public Schoo St Michaels Thirroul Ipswich East State School Kingswood High Ipswich North State School Learn Achieve Celebrate Warriapendi Primary School Florey Primary School Lalor East Primary Risks of modern slavery in any international retail these workers and their employment terms. We have visited these locations and undertaken assessments St. Michaels Stanmore Charles Conder Primary School Campbell Primary School supply chains are dynamic and complex. We are constantly reviewing risks to prioritise our efforts of the work environments to ensure they comply with Holgate Primary Evatt Primary School Curtin Primary where there is greatest impact to people in our local legal conditions and do not provide conditions Hawker Primary School Lightning Reef Primary Sacred Heart Primary Villawood operations and supply chain. for potential risks for modern slavery conditions. We Woodridge North State School Western Suburbs Special Sch Jennings Street School are working on improving auditing in this area as it is Since 2019, we have conducted risk assessments Calwell Primary School Orange Grove Primary School Lavington East Public new operational environment. designed together with our advisor partner Turvey Park Public School St. Agnes Matraville Karangi Public School Intertek, a compliance and sustainability solutions The products we sell in our stores and online are Huntly Primary School Kelso State School St John Vianney Primary School provider. These assessments are informing our sourced from 9 countries. Each of these products Mount Rowan Campus St Thomas More's Primary Sch Caves Beach Public Responsible Sourcing Program and areas of focus. and sourcing countries presents a different set of St Mary's School Bellingen Sturt Public School St Therese's Primary Lakemba This year, we focused on supply chains. These human rights challenges, including risks of modern Medina Primary School St. Paul's Primary Rutherford Chapman Primary assessments focused on the inherent risks of slavery. We source products from suppliers that are Tuggerah Primary Hill Top Public School Caladonian Primary exploitation involved in producing the products in both vendor and non-vendor branded. With our own St. Joan Of Arc Primary Haberf Eaglehawk Primary School Lanyon High School our supply chains. branded products we are more directly connected to these products because suppliers are producing Lilydale Primary School Cathedral Primary Bathurst Padstow Park Public School Lowes Menswear acknowledges the following and packing products directly for our business, which Sacred Heart Primary Morwell Mount Austin Public School Riverlands Montessori School modern slavery risks as most salient in our supply means we have greater connection to the workers Jewells Public Kitchener Public St Kieran Catholic Primary chains. and influence to remediate breaches. Cronulla South Public School Queanbeyan Primary School Sunshine Bay Public School The types included, forced labour, debt bondage, Generic, wholesale or non regular suppliers will be Carrington Public Rockingham John Calvin School Wilsonton State School deceptive recruiting for labour, forms of child subject to further risk assessment. Similarly where our St Anne's Primary Strathfield Ourimbah Public School Wooroloo Primary School labour, restrictions of movement, intimidation, suppliers themselves source their supplies from, such St Christophers Holsworthy Armidale City Public Yoogali Public School threats and human trafficking. as cotton, provides additional levels of risk. St Thomas The Apostle Primary Albury North Latham Primary School We do not directly employ any staff overseas so This risk assessment will allow us to “segment” Big Hill Primary School Wagga Wagga North Prim. Lilydale West Primary School this lowers modern slavery risks within our direct suppliers into three groups: priority, moderate and Padbury Primary School Oakey State School St Patrick's School Allora team. Therefore, our operational risk assessment minimum. Each segment will have different due Mackay State School Raymond Terrace Public School focused on the only areas of the business that diligence requirements based on associated risks. use contracted labour or service providers whose Muswellbrook South Public Scho St.francis Xavier Belmont We are still developing our supplier segmentation workforce engaged with us in overseas locations. St John's Primary Riverstone Redcliffe Special School methodology. We have less direct visibility and control over

24 | Lowes Manhattan Pty Ltd Modern Slavery Report 2020 Lowes Manhattan Pty Ltd Modern Slavery | 25 Mitigating and remediating risks of modern slavery Lowes recognises that it may contribute to a greater is a high priority and we are developing new risk of slavery in our supply chain by placing pressure Policy frameworks to build upon our long standing on suppliers by such means as asking for reduced practices of strict supplier agreements and regular costs or better quality. We will be factoring this into 3rd party audits in the country of origin for our our future risk asessment profiles for suppliers products. CONSULTATION We recognise the importance of building greater We are enhancing our set of policies and understanding of modern slavery risks and our procedures that articulate our values, ways of requirements with the team members who are WITH CONTROLLED ENTITIES. working and expectations of our suppliers that will responsible for supplier relationships and oversight be reviewed regularly. This policy framework will so that they are equipped to provide guidance to ensure that our suppliers clearly understand our our partners to comply. We have and will continue to Where Lowes held a “controlling interest” expectations. raise awareness via training for all team members in in an entity (MFC) we met with the entire this area. Strengthening supplier contracts is one of the team to educate, raise awareness and set our key ways in which we articulate our human rights expectations in mitigating modern slavery expectations and control the potential risk of risks. We provided documentation outlining modern slavery arising in our global supply chain our expectations and will provide a copy of is through our contracting process with our this document upon its completion. Lowes direct suppliers. Building on existing Responsible does not have a controlling or any other Sourcing provisions, modern slavery specific equitable interest in any other entity. provisions have been incorporated in our many Lowes undertakes that if we do in the future of our trade procurement contracts and Vendor look to taking a controlling interest in another Trading Terms. We intend to have these provisions entity, a full risk assessment and audit for risk in all agreements by 2021. of modern slavery will form of our assessment In the future, we intend to use a Slavery before we take control and based on that we Compliance Statement, which is a supplier will undertake the appropriate actions. modern slavery compliance confirmation. We request the supplier to sign and provide this statement to Lowes on the commencement date of an agreement and on each anniversary of the commencement date during the agreement term.

“STRENGTHENING SUPPLIER CONTRACTS IS ONE OF THE KEY WAYS IN WHICH WE ARTICULATE OUR HUMAN RIGHTS EXPECTATIONS AND CONTROL THE POTENTIAL RISK OF MODERN SLAVERY”

26 | Lowes Manhattan Pty Ltd Modern Slavery Report 2020 Lowes Manhattan Pty Ltd Modern Slavery | 27 LIST OF OUR SUPPLIERS | ASSESSMENT OF RISK TAIWAN Risk assessment: MEDIUM* Solid Textile Co Ltd

Risk assessment : HIGH* HONGKONG Mel Enterprises CHINA Uking Industrial Co.,Limited Afw Pty Ltd Shaoxing Dengao Garment Co Ltd Jiangxi Huyan Industrial Krayons Sourcing Limited Shiny Pty Ltd Shaoxing Daxin Sunshine Industry (Hk) Ltd Jiangxi Handsome Garments Better International Jiangxi Shaoxing Guyue Clothing Co.ltd Ningbo Hongli Group Co. Ltd. Ningbo Lianyi Imp & Exp Excellent Promos Co.limited Yichang Mingshen Garments.,Co Yong Ri (China Adv) Reason Imp. & Exp. Co. Ltd Risk assessment : MEDIUM* Zhejiang Willing Foreign Tradi Ningbo Yinzhou Karuisi Textile Shanghai Shimei Garments Co.l Ningbo United Group Imp & Exp Quzhou Municipal Senior Trade Suzhou Peifa Arts&Crafts Co.lt Hong Ho Precision Textiles Co Jiangxi Boruang Jinyu (Fujian) Dress Weaving Beijing Textiles Imp&Exp Corp. Anhui Garment Imp & Exp Co.ltd Beijing Garments Imp & Exp Smartex International Shantou Zhongyuan (Tunnyfish) Hubei Bbh International Trade Beijing Chengfangjie Garment Ningbo Yinzhou Yida Knitted Jiangxi Angmai Industrial Co., Beijing Yuxi Costome Co Ltd. Jiangxi Textile Group Imp&Exp Nanchang Giant-Tex Industry Co Qingdao Yijia E.t.i. Jiangxi Ruizhi Garments Imp&Ex High Hope Int’l Group Sunny Jet Textiles Taizhou Rongbang Imp.&Exp.co.l Ningbo Huazhong Dress Co,Ltd Time Develop Co.

SINGAPORE

Jagger Pte Ltd

Risk assessment : LOW*

BANGLADESH J Mm Fashion (Boydtex) Risk assessment : LOW* Tamshna Fashion Wear Ltd. Tung Hai Sweaters Ltd Boyd International Pty Ltd First Choice Distributors P/L Rifa Knitwear And Designer AUSTRALIAC & S Marketing Co Pty Ltd Licensing Essentials Sisal Apparel Ltd Mdr Global Trading P/L (Usd) Brand Collective Pty Ltd Mactex Industries Limited Capital Link Imports Pty Ltd Isidor’s Pty Ltd Majumder Garments Limited Risk assessment: HIGH* Koala Clothing Australia P/L Top Shoe International Pty Ltd

* REF: GLOBAL SLAVERY INDEX,INDEPENDENT PRIVATELY FUNDED INTERNATIONAL HUMAN RIGHTS ORGANISATION FUNDED IN PERTH, AUSTRALIA BY ANDREW FORRESTOR

28 | Lowes Manhattan Pty Ltd Modern Slavery Report 2020 Lowes Manhattan Pty Ltd Modern Slavery | 29 “MITIGATING AND REMEDIATING RISKS OF MODERN SLAVERY IS A HIGH PRIORITY AND WE ARE DEVELOPING NEW POLICY FRAMEWORKS TO BUILD UPON OUR LONG STANDING PRACTICES”

ADDRESSING MODERN SLAVERY

TIMELINE

OCT 2017 MAR 2020 QLD (SOA) standard offer arrangement formalises Lowes responsible stock Covid 19 Global pandemic significantly halts all WCA conversions and planned management plan, this becomes the base approach for all contracts signed by all Audits until Sept 2020. Lowes submits it’s Modern slavery statement for review to school procurement officers and business managers. * see pg16 green team. ( Green team is leadership members NOT partipating in Lowes Modern Slavery Panel known as red team ) JUNE 2018 APRIL 2020 Donating to countries such as New Guinea, Fiji, Pakistan. Lowes whistleblower policy *See Annexure. is published and sent to all Lowes Staff. Creating an escalation pathway and providing an internal environment and a culture of safety.

JUNE 2019 MAY 2020 Commonwealth Modern Slavery Act guide is distributed to Leadership group and All (SOA) standard offer arrangement now include waste minimisation plan on key heads of departments for review. All groups are to report back on what their distinctive uniforms, including using brokers ‘active international’ selling direct to understanding is of ‘Modern Slavery’ and to determine and identify high risk in the public in exchange for advertising trade credits. business. DEC 2019 JUN 2020 CEO appoints a Select Group * to establish ‘Lowes Panel for Modern Slavery Establishment of Continuous Improvement Committee. Tim Zhu prepares audit Compliance’. The Panel meets each Financial year quarter for 2 hours to deploy schedule for 2021. Kathy Adair onboards Manrags fashion recycle group, whose strategy for governance and outstanding actions. { *see panel p3.} mission is to reduce the number of textiles that end up in landfill, due to massive garment overproduction and non-existent recycling. FEB 2020 SEPT 2020

Lowes Panel engage Third part ‘Intertek’ to run 3-day workshop with all Panel Statement moves to internal review with Leadership group* members. Annual budget is set for Factory Audits and other waste management initiatives. Schedule of current audit conversions and list of factories servicing over 25% supply is deemed first to be audited using Intertek OCT 2020 Statement moves to review with intertek and awaits publication.

30 | Lowes Manhattan Pty Ltd Modern Slavery Report 2020 Lowes Manhattan Pty Ltd Modern Slavery | 31 LOWES GATEWAY PROCESS MENSWEAR & SCHOOLWEAR PRODUCTION AND DEVELOPMENT TRAINING AND INTERNAL CONTINUOUS IMPROVEMENT ACCOUNTABILITY

Lowes embarked on a continuous improvement approach well before any sanctioned reporting and Our commitment to upholding global standards compliance. In order to officially report and demonstrate our commitment to respecting human rights, require that all areas liaising with external Lowes CEO, Mrs. Linda Penn developed a ‘Lowes panel’ to formalise agreements with all sectors of our suppliers/ agents must adhere to company Supply chain and goes to market to engage ‘Intertek’ to set strategic benchmarks to monitor activities sanctioned policy. All staff at head office are in accordance with the Modern Slavery Act 2018 required when onboarded into the company to review our core policies. Lowes has an extensive learning management system regulated by HR called the Lowes Academy. LOWES PANEL FOR MORDERN SLAVERY • Capturing the performance of our factories COMPLIANCE by reviewing the outcomes of all audits INTERNAL TRAINING conducted by Intertek Lowes Academy is for all 1206 staff and is sectioned Lowes is committed to bilateral long-term into core areas managed by our internal intranet outcomes that benefit suppliers, schools • Schedule audits for the next fiscal year. called the Lowedown. and our consumers. We recognise robust negotiations are inevitable in business practice LOWES FORMALLY ENGAGES INTERTEK TO All staff here have individual user profiles that and contribute to innovation, efficiency and the FACILITATE ALL ACTIVITIES monitor the training modules and the timeframe for long-term sustainability. completion. Lowes policy has always been for the suppliers The panel recognised the need to engage a third These modules include all work health and safety to provide certification of factory audits as party to validate audits. modules, compliance and ethics training, our company may take disciplinary action against any evidence of compliance. Lowes understood the need to consult with worker who violates our policy. These were usually in the forms of various third party resources and databases, by utilising certificates: consultants and having them evaluate slavery WHISTLEBLOWER this would broker an arrangement to remediate • BSCI We have a whistle-blower hotline accessible on the identified deficiencies and where necessary Lowedown that is available to all staff and this has • SMETA terminate supplier factories that refuse / fail to now been extended to agents and factories. • QIMA comply with procedures and guidelines GATE PROCESS The Panel consists of 4 leadership members Intertek results yield several decision-making Lowes developed The “Gate Process” which is a whose areas govern Technical operations, factors based on previous audits and how these project management technique to keep all buyers, Sarann Ryan, Merchandise Control, Michael dictate future frequency of audits. Audits are product developers and planners accountable in Manios, Human Resources Jason Heap and Head scheduled in advance with the suppliers in order the developing, sourcing and purchasing phases. of school Operations Tim Bryant. to foster relationships of co-operation and trust, we only suggest unannounced audits when we The gateway is reinforced at the leadership level, The panel meets every quarter to initiate, suspect violations. it unpacks the process to make sustainability and forecast and remediate on all supply chains. waste management a key performance indicator for all personnel involved. This consists of; • Reviewing and aligning all international standards and policies by communicating The Gate way is divided over a few stages. • Go – Concept is good enough to proceed to the standards and requirements to our agents next stage These stages are separated by ‘gates’. Each stage is and business partners. the decision point for whether or not to proceed • Kill – Concept is not good enough to develop • Evaluating by continuing to monitor to the next stage. This decision is made by a further and is therefore shut down compliance by conducting a pre-sourcing manager or steering committee. The quality of the • Hold – Concept is not good enough to continue assessment with our agents. All buyers idea, finances, timeframe and succession rate is all with development at this time but has enough and Merchant controllers submit any new assessed at each of the gates. After each gate, one merit to not be shut down. It will be put on hold supplier to the panel for review. of the following decisions can be made: to possibly be resumed at a later date.

32 | Lowes Manhattan Pty Ltd Modern Slavery Report 2020 Lowes Manhattan Pty Ltd Modern Slavery | 33 APPAREL DEVELOPMENT PROCESS The Gate Process consists of several stages, which Gate 3: Development & Wear Trial are connected to each other by gates. Each stage is • Create specifications designed to collect specific information: RECEIVE SAMPLE REQUEST 1 • Arrange 1st development samples of the Account Manager → Product Team • Stage 1: Scoping/Range Justification/ design in selected fabrics (jump size set) This is the brief. It includes everything Feasibility from identifying the school, outlining their • Conduct fit and wear trials (on numerous body request and needs in detail, desired • Stage 2: Design timeline, price point and size range. This shapes and sizes) can be accompanied by samples for • Stage 3: Development & Wear Trial reference to colour, fabrics and embroidery. • Assess fit and wear trial feedback • Stage 4: Final Sign Off/Launch CREATE ARTWORK • Revise specifications and organise 2nd 2 Gate 1: Scoping/ Range Justification/ Feasibility development samples (if required) Product Team → Graphics → Account Manager The concept is almost ready to come to life! • Concept – Describe idea and identify where it • Present to team This is the phase where sketches become fits in core range/ our fashion demographic interpreted. Storyboards are drawn up to • Sign Off show the design of the garment, trims, fabric, colours and logo details. This helps • Design consideration - specify styles, colours, the school see the indent style or uniform sizing, fit, features range. Before the sampling stage begins, this Gate 4: Final Sign Off/Launch is the time to make any design changes and get • Proposed deletions – suggest any existing styles/ DEVELOP TECH PACK & REQUEST SAMPLE the schools tick of approval. 3 SKUs for deletion (e.g., style it will replace or • Confirm styles, colours and order quantity Spec Technician → Product Team styles that are not selling) • Sign Off: price per unit, volume (per colour), The tech pack is the blueprint for each piece of apparel. It has details ranging • Rationale – specify/justify reason(s) for total cost of order, GP% from the style’s description, trims, fabrics, size range, placement of logos, launching and how it will grow the business • Issue final QC report to supplier packaging and manufacturing details. The (sales, profits etc.) tech pack is sent to the supplier and the • Garment Set Up first sample is requested. • Competitor analysis – present any competitor styles that have similar products already in their • Raise Purchase order RECEIVE SAMPLE & OBTAIN APPROVAL 4 range. • Lock in Ex/factory date Product Team → Account Manager Sample arrives and the QA/Spec • Competitive advantages – list the point Technician checks the sample against the tech pack, ensuring the product is made as of differences between our product and initially requested. Sample is presented to competitor’s product (e.g., features and benefits, the school and approval/sign off is acquired. Worst case scenario, the school rejects the price point etc.) sample. Repeat steps 3 & 4 until approval is obtained and the product is perfected. • Target financials – target price per unit, GARMENT SET UP proposed volume (per colour), proposed budget 5 Product → Spec Tech → Data Integrity Admin

• Agreed timing – to be discussed during Gate 1 Garment request forms are completed. (e.g. launched at the best time of year to ensure Final quality control comments are issued to the supplier and costings are peak sales). confirmed. The style is set up in pronto and a 5-digit number is created. • Sign off Gate 2: Design FORECASTING & ORDERING • Design – present to team: research, initial design 6 Planners → Stock Control Team sketches, fabric options, colour options and The style is quantified and units per size costings. are determined. An official purchase order is raised and sent to the supplier. • Sign off Bulk production is now underway.

PRODUCTION & SHIPMENT 7 Spec Technician → Production Co-ordinator Fabric is made. Pre-Production sample is sent for quality control and approval. Bulk production is completed and a shipment sample is sent for final sign off. The order is shipped to warehouse and delivered to stores.

© 2020 LOWES MANHATTAN PTY LTD. ALL RIGHTS RESERVED

34 | Lowes Manhattan Pty Ltd Modern Slavery Report 2020 Lowes Manhattan Pty Ltd Modern Slavery | 35 SCHEDULE OF AUDITS 2021 COMMITMENTS

2020 2021 Report LOWES SUPPLIER PRODUCTS FACTORY NAME FACTORY LOCA- RECENT AUDIT PASS AUDIT INTERTEK WCA SCORE LOWES SUPPLIER PRODUCTS FACTORY NAME FACTORY LOCATION RECENT AUDIT Expired & Follow Up INTERTEK TION REPORT DATE REPORT Date WCA SCORE Sunshine Apparel/Garments Ningbo Chenhong YinZhou District BSCI 20/7/20 90 Sunshine Industries Apparel/Garments Ningbo Chenhong YinZhou District BSCI 2021 May Garments Co.Ltd. Ningbo (HK) Ltd Garments Co.Ltd. Ningbo Elegant Apparel/Garments Elegant Knitting Biyagama, Malwa- SMETA 03/7/20 100 International Ltd. na, Sri Lanka Elegant Knitting Apparel/Garments Elegant Knitting Biyagama, Malwana, SMETA 2021 July International Ltd. Sri Lanka AFW Pty Ltd. Apparel/Garments Yangzhou Yiju Hanjiang District, SGS 19/1/20 96 AFW Pty Ltd. Apparel/Garments Yangzhou Yiju Garm- Hanjiang District, SGS 2021 Jan Garmnets Co. ltd Yangzhou City nets Co. ltd Yangzhou City China China Georges Apparel Apparel/Garments PT. Dan Liris Indonesia SMETA 2021 Aug Georges Apparel Apparel/Garments PT. Dan Liris Indonesia SMETA 30/8/19 98 Apparel/Garments Th Ning Bo Blossom Hangcheng Street, QIMA 2021 Oct Apparel/Garments Th Ning Bo Blos- Hangcheng Street, QIMA 06/10/19 87 Knitting Changle City Fuzhou, som Knitting Changle City China Fuzhou, China Shiny Pty Ltd Apparel/Garments Fujian Changle Sanhe Hangcheng Street, BSCI 2021 Oct Shiny Apparel/Garments Fujian Changle Hangcheng Street, BSCI 28/10/19 84 Garment CO. Ltd. Changle City Fuzhou Sanhe Garment Changle City China CO. Ltd. Fuzhou China AZD (Australia) Pty Apparel/Garments Hongze Sainty Fortune Hongze County BSCI 2021 July Ltd Garment Huai’an, Jiangsu, China AZD Apparel/Garments Hongze Sainty Hongze County BSCI 09/07/20 87 Fortune Garment Huai’an, Jiangsu, Mitch Dowd Socks Zhejiang FENLI Hoses Beiyuan Industrial BSCI 2020 Dec China Industry Co.,Ltd Zone, Yiwu, Zhejiang, China Mitch Dowd Socks Zhejiang FENLI Beiyuan Industrial BSCI 13/12/19 88 Socks Zhejiang Greenwood Fotang Town, Yiwu, BSCI 2021 May Hoses Industry Zone, Yiwu, Zheji- Knit Co., Ltd Zhejiang, China Co.,Ltd ang, China Socks/Tights Zhuji Hongfei Socks Beiting Village, Jiyang BSCI 2021 Sept Socks Zhejiang Green- Fotang Town, BSCI 19/05/19 90 Factory Jiedao,Zhuji Zhejiang, wood Knit Co., Ltd Yiwu, Zhejiang, China China Uniform MGMT/Cor- Apparel/Garments Uniform Management Vung Tau City, Ba Ria, SMETA 2021 June Socks/Tights Zhuji Hongfei Beiting Village, Ji- BSCI 07/09/20 89 porate Services Vung Tau Province Socks Factory yang Jiedao,Zhuji Vietnam Zhejiang, China Noone Accessories - Tie PT Trisco Tailoired Ap- Katapang,SOREANG, BSCI 2021 Mar parel Manufacturing Bandung, Indonesia UMS Apparel/Garments Uniform Manage- Vung Tau City, SMETA 17/7/20 96 ment Services Ba Ria, Vung Tau First Choice Distribu- Apparel/Garments Nanchang Qunde HighTech industrial Intertek 2021 Sep Province Vietnam tors P/L Garments Co., Ltd park Nanchang, Jiangxi, China Noone Accessories - Tie PT Trisco Tailoired Kata- BSCI 13/03/20 Under Verification Apparel/Garments Wuhu New Garments Suncun Town Industri- Intertek 2021 Sep Apparel Manufac- pang,SOREANG, Co.,Ltd la Area, Wuhu, China turing Bandung, Indo- nesia Spartan School Bags/Hats/Accessories Will follow up with supplier once 2020 WCA compliance is completed Supplier Spartan Bags/Hats/Accessories Factory audit is scheduled end Oct 2020 Under Verification Kootex International Apparel/Garments Will follow up with supplier once 2020 WCA compliance is completed Kootex Apparel/Garments Factory audit is scheduled end Oct 2020 Under Verification Pty Ltd Instyle Apparel/Garments Will follow up with supplier once 2020 WCA compliance is completed Instyle Apparel/Garments Factrory report received and Ineterk Verification is under Under Verification progress Mackahat Hats Jiangsu Holly Manu- Xihua North Rd, BSCI 2021 June facturing Co., Ltd Dongxing Town, Jiang- Mackahat Hats Factrory report received and Ineterk Verification is under Under Verification jiang Jiangsu, China progress Epicentre Trading Pty Hats Will follow up with supplier once 2020 WCA compliance is completed Epicentre Hats Factrory report received and Ineterk Verification is under Under Verification progress OnTrack Sportswear Sportswear Not Applicable (under GuangDong Province, INTERTEK 2021 Jan NDA) China OnTrack Sports- Sportswear Factrory report received and Ineterk Verification is under Under Verification Calcoup Knitwear Not Applicable (under Nadi, Fiji SMETA 2021 June wear progress NDA) Calcoup Knitwear Factrory report received and Ineterk Verification is under Under Verification Midford Apparel/Garments Will follow up with supplier once 2020 WCA compliance is completed progress PNW (Bocini) Apparel/Garments Will follow up with supplier once 2020 WCA compliance is completed Midford Apparel/Garments Factrory report received and Ineterk Verification is under Under Verification progress JIiangxi Handsome Apparel/Garments Will follow up with supplier once 2020 WCA compliance is completed PNW (Bocini) Apparel/Garments Factrory report received and Ineterk Verification is under Under Verification Garments progress Zhejiang Willing Apparel/Garments Will follow up with supplier once 2020 WCA compliance is completed Foreign Tradi Shaoxing Daxin Apparel/Garments Will follow up with supplier once 2020 WCA compliance is completed

Jiangxi Ruizhi Gar- Apparel/Garments Will follow up with supplier once 2020 WCA compliance is completed ments Imp&Ex J Mm Fashion (Boy- Apparel/Garments Will follow up with supplier once 2020 WCA compliance is completed dtex) Krayons Sourcing Apparel/Garments Will follow up with supplier once 2020 WCA compliance is completed Limited

36 | Lowes Manhattan Pty Ltd Modern Slavery Report 2020 Lowes Manhattan Pty Ltd Modern Slavery | 37 ANNEXURE

reaches leislation relations or local overnment bylas or is  ny etaaton o han made the doe e teated a eo ondon nde urther a histleblower may choose to remain anonymous while maing their disclosure over the otherise illeal incldin histlebloer las corporations la thet course of the investigation and after the investigation is finalised. A histleblower if they do not want th Poy Overview dr sale se violence or threatened violence or criminal damae aainst anyone to now their identity including officers may adopt a pseudonym for the purpose of their property disclosure. Lowes Manhattan Pty Ltd is guided by its company values. These values are the foundation of how the the ppoe o th poy (hee appae) we conduct ourselves and interact with each other, our clients, customers, employees, suppliers, thical les and standards or riht condct and practices in bsiness 1.2 Whistleblower Protection Officer directors and other stakeholders. The Company is committed to ensuring corporate compliance  noae doe to epot ondon f the histleblower wishes the fficer may be appointed to support and provide and promoting ethical corporate culture by observing the highest standards of fair dealings,  ne doe ae deat th appopatey and on a tmey a protection to the histleblower according to this policy. honesty and integrity in all of our business activities. spectin he histlebloer main the report has reasonable ronds or sspectin the reportable rondoin  Pode tanpaeny aond Loe anhattan Pty Ltd ameo o een handn he protection officer must have a direct reporting line to a governance officer from an area of the This policy applies to all directors, executives, all staff, contractors and consultants at Lowes histlebloer and netatn doe organisation that is independent of line management in the area that is the subect of the report of Manhattan Pty Ltd. This policy also extends to customers, clients and suppliers. This rotections rovides spport and protection to the histlebloer wrongdoing. Whistleblower Policy will be widely disseminated to and easily accessible by all within and outside icer  ne ndda ando op ho mae a doe o ondon an do o eey the business. For internal use, this will be made available on the company’s intranet and training histlebloer he person that ill receive histlebloer disclosres o rondoin and oversee he protection officer will provide mentoring and other support deemed necessary. and aey th ondene that they e poteted and ppoted thohot the ente via the Learning Management System. For external use, the policy can be accessed by selecting overnance a resoltion he rotection fficer is responsible for eeping the histleblower informed of the progress and the link on Lowes Manhattan Pty Ltd website. icer poe outcomes of the inuiryinvestigation subect to considerations of privacy of those against whom a  To ppot Loe anhattan Pty Ltd ae and ode o ondt disclosure has been made. Purpose  To ppot Loe anhattan Pty Ltd ontem eptaton and tanaty and The purpose of this policy is to provide all employees, former employees, contractors, associates, Policy Statement 1.3 Identity Protection  trustees, relatives of or dependants of aforementioned to safely and securely report any wrongdoing oes anhattan ty is committed to the hihest standards o condct and ethical behavior to eet Loe anhattan Pty Ltd ea and eatoy oaton his will state the measures andor mechanisms for protecting the confidentiality of a such as policy breaches, illegal, unethical or undesirable behaviour involving the business. This policy spport and promote a cltre o honesty and ethical behavior corporate compliance and ood histleblowers identity where applicable protects individuals who make a confidential disclosure to the officers. Employees who wish to report corporate overnance eople ho have a orin relationship ith oes anhattan ty td are Responsibilities  All personal information or reference to the individual witnessing and event will be other issues such as grievances i.e personal work-related grievances should refer to the Policy, redacted Guideline and Procedures Manual and/or the Employment Guidelines and Procedures Manual. oten the irst to realise that there may be somethin seriosly ron oever they may not ish 1.1 Whistleblowers Poteton aaae to hteoe ho doe ondon that made th ond  he discloser will be referred to in a genderneutral contet to spea p or ear o appearin disloyal or may be concerned abot bein victimised or sbect to Examples of Grievances that include Personal Work-Related Grievances: eaonae to eee t te hh nde t not mted to  isclosures will be handled and investigated by ualified staff reprisals or reportin rondoin  All paper and electronic documents and other materials relating to disclosures will be stored  Interpersonal conflict between colleagues;  dentty poteton securely  A matter that does not involve a breach of workplace laws;  Poteton om detmenta at o omon oes anhattan Pty Ltd (“The Company”) encoraes the reportin o any instances o sspected  Access to all information relating to a discloser will be limited to those directly involved in  Decisions about internal promotions or external recruitment; and  Compenaton and othe emede and managing and investigating the disclosure  Disciplinary actions, suspension or termination of an individual. nethical illeal radlent or ndesirable condct involvin oes anhattan ty td and provides  C mna and admntate aty poteton  nly a restricted number of people who are directly involved in handling and investigating a protections and measres so that those persons ho mae a report may do so conidentially saely disclosure will be made aware of a discloser’s identity (subject to the discloser’s consent) or Definitions To ene that a empoyee ae teated ay and that eoe ae not ated poteton not and ithot ear o intimidation disadvantae or reprisal aaae hee the doe information that is liely to lead to the identification of the discloser Terms used in this policy are:  ommunications and documents relating to the investigation of the disclosure will not be  Ta o eato n nate th no tane Th e teated n the ame manne a a sent to an email address or to a printer that can be accessed by other staff and hen an aorementioned person maes a disclosre in confidence ae epot and may te onttte ondon  Whistleblower/ A person who anonymously discloses information to an officer or higher authority ach person who is involved in handling and investigating a disclosure will be reminded  ntantated aeaton hh ae ond to hae een made maoy o nony Whistleblowing about any wrongdoing within a business. A person who is a witness of actual or  heir identity mst remain confidential according to their wishes about the confidentiality reuirements including that unauthorised disclosure of a to e ae Thee e eed eoy and may e et to dpnay aton that discloser’s identity may be a criminal offence. suspected wrongdoing  hey ill be protected rom reprisal discrimination harassment or victimisation or main od nde dma temnaton o ee o eaton o a ee o ent eatonhp the disclosre 1.4 Whistleblower Governance Officer Conduct and/or behaviour that includes but is not limited to: hteoe mt pode nomaton to at any nynetaton o the ondon he histleblower overnance fficer is the ead of eople. he ead of eople will receive Wrongdoing - Illegal or dishonest behaviour;  n independent internal iniry or investiation ill be condcted or i appropriate an doed - Unethical or undesirable behaviour; whistleblower disclosures of wrongdoing and overseeing resolution. - Is an unethical breach of the Code of Conduct of Lowes Manhattan Pty Ltd eternal investiator may be approved an a doe may not potet the hteoe om the oneene on om he histleblower overnance fficer must after a reasonable preliminary inuiry - Has financial or non-financial loss detrimental to the interest of Lowes  sses identiied rom the iniryinvestiation ill be resolved andor rectiied involvement in the wrongdoing itself. A person’s liability for their own conduct is not affected by their  rotect the identity of the histleblower Manhattan Pty Ltd; epot o that ondt nde th poy oee ate oopeaton n the netaton admon  f the histleblower agrees to appoint the fficer the fficer will - Repeated breaches of administrative procedures;  hey ill be inormed abot the investiation and otcomes and emoe may e taen nto aont hen onden dpnay o othe aton provide support to the whistleblower - Unreasonably endangers the health and safety or the environment;  he disclosre can still aliy or protection even i their disclosre trns ot to be - Is dishonest or fraudulent; en thoh a hteoe may e mpated n the ondon they mt not e eted to any  e satisfied that each disclosure of wrongdoing they received was appropriately inuired - Is an offence against any other law of the Commonwealth is punishable by incorrect ata o theatened etaatoy aton o tmaton n epa o man a epot nde th poy into or investigated imprisonment for a period of 12 months or more;

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38 | Lowes Manhattan Pty Ltd Modern Slavery Report 2020 Lowes Manhattan Pty Ltd Modern Slavery | 39  e satisfied that action taen in resonse to the inuiryinestiation is aroriate to the  strateies to hel a discloser minimise and manae stress time or erformance imacts or Lowes Manhattan Pty Ltd will take reasonable precautions to store any records relatin to a report Current Officials for this Policy circumstances other challenes resultin from the disclosure or its inestiation of wrondoin securely and to restrict access to authorised persons only

 roide oernance oersiht oer any inuiryinestiation into retaliatory action taen  actions for rotectin a discloser from ris of detriment—for eamle the business could aainst the histleblower allow the discloser to erform their duties from another location reassin the discloser to 1.13 Retaliation another role at the same level, make other modifications to the discloser’s workplace or the Lowes Manhattan Pty Ltd will not tolerate any retaliatory action or threats of retaliatory action aainst lternatiely if the disclosure contains alleations aainst any owes anhattan ty td eecutie or way they erform their wor duties or reassin or relocate other staff inoled in the a Whistleblower or against a Whistleblower’s colleagues, employer (if a contractor, consultant or Officers where the histleblower has a reasonable belief that the histleblower oernance fficers are not Whistleblower Protections disclosable matter supplier or relatives ny retaliation in reprisal for a disclosure made under this policy will be treated sufficiently indeendent a reort may be made to the anain irector of owes anhattan ty td as a breach of serious misconduct and will result in disciplinary action Officer WHW fficer oumana allad 1.10 Reporting a Disclosure 1.5 Protected Disclosures Coordinator histleblower must not be disadvantaed or victimised for havin made the report by: owes anhattan ty td will need to assess each disclosure to determine whether he rotected isclosures oordinator is the ead of eole he ead of eole will receie all  ismissal or termination of employment, services or contracts information about all whistleblower eents and erforms the followin functions  isclosures will be handled confidentially Whistleblower Governance  emotion of contract Head of eople ason Heap  ach disclosure will be assessed and may be subject of an inestiation Officer  uort the welfare of disclosers  iscrimination, victimisation, bullyin and harassment  hen an inestiation needs to be undertaen the rocess will be objectie fair and  rranes for an inuiryinestiation into the disclosures made by the histleblower  forementioned matters above indeendent  nsures aroriate oernment aencies are notified about histleblower eents where  t ualifies for rotection and reuired 1.14 Disclosure Management Protected Disclosures  formal indeth inestiation is reuired  aintains a histleblower eister for trend analysis and to identify systemic issues Lowes Manhattan Pty Ltd reconises that individuals aainst whom a report is made must also be Coordinator Head of eople ason Heap

reuirin attention supported durin the handlin and investiation of the wrondoin report he business takes (a) Internal Whistleblowers reasonable steps to treat fairly any person who is the subect of a report, particularly durin the 1.6 Investigator assessment and investiation process in accordance with an established support protocol which may (urrent or former emloyees directors contractors or consultants) owes anhattan ty td will inestiate all matters reorted under this olicy as soon as racticable be etended to include appointin an eecutive member of the leadership roup to provide support after the matter has been reorted he rotected isclosures oordinator who is the ead of eole nternal histleblowers are encouraed to reort their concerns to the histleblower oernance here a person is identified as bein suspected of possible wrondoin, but preliminary inuiries will aoint either an internal or eternal inestiator to inestiate the matter owes anhattan ty fficer to see an immediate resonse here the internal histleblower beliees this is not determine that the suspicion is baseless, no evidence or unfounded and that no formal investiation td may not be able to undertae an inestiation if it is not able to contact the discloser n eamle aroriate then an alternatie reortin mechanism is to reort the matter to the histleblower is warranted, then the histleblower will be informed of this outcome and the matter laid to rest is if a disclosure has refused to roide or has not roided a means of contactin them rotection fficer Lowes Manhattan Pty Ltd will ive its full support to a person who is the subect of a report where the he internal inestiator may be the oernance fficer and or an aroriate erson as aointed (b) External Whistleblowers alleations contained in the report are clearly wron by the oernance fficer (hese indiiduals include clients customers suliers) herefore, where an investiation does not substantiate the report, the fact that the investiation has 1.7 Investigation here an eternal histleblower is reluctant to reort it to the oernance fficer or the rotections fficer they can reort their concerns to the anain irector of owes anhattan ty td been carried out, the results of the investiation and the identity of the person who is the subect of he inestiation will be conducted in an objectie and fair manner and as is aroriate hain the report must be handled confidentially reard to the nature of the disclosure and circumstances here a reort andor matter is submitted (c)Anonymous Reporting anonymously owes anhattan ty td will conduct the inestiation and its enuiries based on the nonymous reorts of wrondoin are acceted under this olicy nonymous reorts hae urther, where an investiation is conducted and the investiator finds there may be a case for an information roided urther anonymity can at times reent the business from tain the issue sinificant limitations that may inhibit a roer and aroriate inuiry or inestiation hese individual to respond, the nvestiator must ensure that a person who is the subect of a disclosure: further if owes anhattan ty td is not able to obtain further information from the source of the limitations include the inability to roide feedbac on the outcome andor to ather additional  s informed of the substance of the alleations reort articulars to assist the inuiryinestiation ecific rotection mechanisms may be difficult to  s iven a fair and reasonable opportunity to answer the alleations before the investiation enforce if you choose to remain confidential 1.8 Managers and Line Supervisors is finalised

ll manaers and line suerisors who receie a disclosure about wrondoin must notify the  Has their response set out fairly in the Investigator’s report; and oernance officer and roide articulars and maintain confidentiality at all times 1.11 Protection  s informed about the substance of any adverse conclusions in the investigator’s report that owes anhattan ty td will adot the rincile of rotection of the identity of internal and eternal affects them 1.9 Protection from detrimental acts or omissions histleblowers owes anhattan ty td may refer to the followin measures and mechanisms for rotectin disclosers from detrimental acts or omissions (where alicable) 1.12 Confidentiality 1.15 Failure to Comply Lowes Manhattan Pty Ltd will not disclose a whistleblower’s identity unless: ny breach of this policy may result in disciplinary action that could result in severance from Lowes  rocesses for assessin the ris of detriment aainst a discloser and other ersons (e other Manhattan Pty Ltd staff who miht be susected to hae made a disclosure) which will commence as soon as  he disclosure is reuired or authorised by law and ossible after receiin a disclosure  t is necessary to further an inestiation and the histleblower consents to the disclosure  suort serices (includin counsellin or other rofessional or leal serices) that are aailable to disclosers

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TIM ZHU LOWES PRODUCTION MANAGER AND LEADER OF THE CONTINUOUS IMPROVEMENT COMMITTEE IS FLUENT IN CHINESE AND IS USED AS A MANDATORY REPORTER FOR ANY SUSPICIOUS ACTIVITY. HE COMMUNICATES FREQUENTLY WITH OUR FACTORIES IN CHINA AND LETS WORKERS KNOW DISCREETLY THAT THEY CAN ESCALATE ANY ISSUES DIRECTLY TO HIM.

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