SAFEWAY LIMITED

Policies described

Freedom of workers to terminate employment Freedom of movement Freedom of association Prohibits any threat of violence, harassment and intimidation Prohibits the use of worker-paid recruitment fees Prohibits compulsory overtime Prohibits child labour Prohibits discrimination Prohibits confiscation of workers' original identification documents Provides access to remedy, compensation and justice for victims of modern slavery

Training described

Your front line staff Human resources Procurement staff Your suppliers

Worker engagement and working conditions

Your suppliers Trade unions or worker representative groups Civil society organisations Professional auditors Workers within your organisation Workers within your supply chain Law enforcement, such as police, GLAA and other local labour market inspectorates Businesses in your industry or sector

Social audits

Third party audit arranged by your organisation Third party audit arranged by your supplier Announced audit

Grievance mechanisms

Using anonymous whistleblowing services, such as a helpline or mobile phone app Through trade unions or other worker representative groups

Actions addressing ILO indicators

Supporting investigations by relevant authorities

Demonstrated progress

Our statement set goals and reports on progress in each case.

Reported risks and mitigations

• Risk: Migrant worker exploitation in UK and Southern European agriculture and food processing
• Area: Within your supply chains
• Tier: Tier 1 suppliers Tier 2 suppliers
• Group: Migrants
• Location: Spain United Kingdom Italy
• Mitigation: Modern Slavery Group to review incidents, assess risk and drive improvement. Colleague training and briefing to raise awareness. Internal incident management and remediation process. Support the UK Seasonal Worker Scheme Taskforce to develop tangible actions to help safeguard and ensure access to workers’ rights in UK horticulture. Participated in ETI Grievance Mechanisms in Agriculture project to improve access to grievance mechanisms for vulnerable agricultural workers in Italy and Spain.
• Risk: Forced and bonded labour in the Chinese and Indian manufacturing sectors
• Group: Women Migrants
• Location: China India
• Mitigation: Third party audits at all tier one sites. Commissioned the specialist audit body TRN to conduct worker-focused, dialogue-based visits to selected factories based on risk. Training sessions and workshops for suppliers in our Chinese supply chain. All cotton sourced from China must be BCI certified. Restrictions on sourcing from countries and regions at extreme risk of human rights issues and/or where audits cannot be freely conducted.
• Risk: Migrant worker exploitation in the fish and seafood industry
• Tier: Tier 2 suppliers
• Mitigation: To address these risks within our supply chain we committed to funding and engaging in the ETI Shrimp responsible purchasing practices project. We are also developing a questionnaire to be directed to our key seafood suppliers to enhance our due diligence and identify potential actions to be taken in collaboration with our suppliers to improve working conditions in our fish and seafood supply chain.