In 2010, the State of California adopted the Transparency in Supply Chains Act, which requires certain retailers and manufacturers to post a disclosure statement on their web site detailing whether, and to what extent, they investigate or monitor slavery or human trafficking in their direct product supply chains.

Orora hereby declares that it requires suppliers in its direct product supply chains to comply with applicable laws, regulations and standards, will investigate claims brought to its attention regarding the use of slavery or human trafficking by its suppliers, and will take appropriate action to discontinue use of a supplier that uses such labor. Orora management is not aware of any claims regarding the use of slavery or human trafficking by any member of Orora’s direct supply chains since the company was founded in 1948.

 Verification

Orora has, with the assistance of a third party, commenced a risk profile review of its North American operations to enable Orora to gain a better understanding into any instances or risks of modern slavery within those operations or their complex supply chains.

Audit

Orora has minimum supplier standards (contained in the Orora Group’s Supplier Code of Conduct and Ethics Policy), including in respect of human trafficking and slavery, but has not yet conducted supplier audits to evaluate whether suppliers comply with these standards.

Certification

Orora further requires direct suppliers to certify through its procurement standard contract suite and purchase order terms and conditions that materials incorporated into products or services provided to Orora comply with the laws, regulations and standards addressing human trafficking and slavery of the country or countries in which they are doing business, and that they adhere to the Orora Group’s Supplier Code of Conduct and Ethics Policy, which includes a commitment to provide a work environment free from all forms of modern slavery.

Internal Accountability

Orora maintains internal accountability standards and procedures for employees and contractors failing to meet company standards regarding slavery and trafficking through performance reviews and internal grievance mechanisms.  Orora also operates an Integrity Reporting Services through an independent third party to facilitate reporting by co-workers and third parties of reasonably suspected misconduct or an improper state of affairs or circumstances within Orora. Each report to the Integrity Reporting Service is investigated thoroughly and appropriate action taken where necessary. Matters raised via the Orora Integrity Reporting Service are reported to the Board of Orora Limited.

Training

During fiscal year 2023, bespoke training and awareness material was developed for Orora team members globally to further the awareness and plight of modern slavery and other human rights abuses. Awareness material was shared on e-screens across the business, as well as discussed during business town halls. This was developed and delivered in both English and Spanish. Further, more detailed training was developed for our e-learning platform to be realised in FY24 to all staff required to complete Orora training modules via the dedicated e-learning program. This training pack included a video message from our Chief People, Sustainability and Governance Officer, highlighting the importance of mitigating modern slavery risks as well informing the business of our Human Rights Due Diligence Framework. This was also developed in both English and Spanish.