Legal: Modern Slavery Statement - Identifying the risks of modern slavery practices in our operations and supply chains

In the first tier of Flybuys' supply chain, Flybuys considers that the risk of modern slavery continues to be relatively low. Drawing on a number of internationally available resources including the Global Slavery Index and the 2020 List of Goods Produced by Child Labor or Forced Labor², we acknowledge that there are areas of our supply chain that may pose higher risks of modern slavery. These include technology and IT suppliers, property maintenance, security and cleaning services. Flybuys also acknowledges that there are increased risks in the shipping and logistics industry as a result of the COVID-19 pandemic. However, as a result of a review of our supply chain, we assessed this as a low risk in terms of the first tier of Flybuys supply chain on the basis that Flybuys only uses Australia Post and Australian based couriers for shipping services and does not generally require overseas shipping or logistics services. Flybuys recognises that some of its suppliers are likely to use international shipping services and will seek to engage with its suppliers to gain greater visibility of these risks deeper within its supply chain in upcoming reporting periods.

During the current reporting period there has been an increase in our use of staff augmentation services for IT specialists. Flybuys recognises that the staff augmentation industry generally has a higher risk of forced labour, however we note that the majority of specialists engaged by Flybuys via augmentation services were based in Australia, which significantly moderates the risk of forced labour. For a minority of specialists based overseas, Flybuys engaged with those specialists via suppliers based in Australia with whom appropriate contracts are in place. Flybuys has also engaged with two key suppliers of labour hire services as part of the supplier questionnaire due diligence exercise.

As identified in our statement for the first reporting period, many of our suppliers who provide products for points redemption obtain those products from countries considered at higher risk of modern slavery according to the Global Slavery Index. We have continued to engage with those suppliers during the current reporting period, particularly as we transitioned our rewards partners onto our new rewards platform and to our revised supplier agreements (which have been updated to address modern slavery compliance).

The COVID-19 pandemic continues to pose an increased risk of modern slavery across global supply chains. During this reporting period, we updated our Supplier Questionnaire to include questions which specifically address the COVID-19 pandemic so we could better understand what impact the pandemic may have had on our suppliers. Based on the majority of responses received, it appeared that whilst the COVID-19 pandemic has had some impact on our suppliers in relation to their workforce (such as due to lockdowns), our suppliers did not report an increased risk of modern slavery. Most of the service based suppliers who responded were able to transition their personnel to working from home arrangements which resulted in continuity of service, including those suppliers who we engaged in relation to staff augmentation. We will continue to monitor modern slavery risks associated with the pandemic over the next reporting period and in particular will be monitoring any increased risks associated with the supply of hardware to Flybuys.