Ethical Sourcing and Supplier Code of Conduct

THIS POLICY APPLIES TO: All companies within the Patties Foods Group (Patties Foods, , Patties Foods Pakenham, Leader Products, and Australian Wholefoods) (the ‘Patties Foods Group’) and threshold suppliers of goods or services to the Patties Foods Group.

This policy applies to:All Suppliers to the Patties Food Group (including Bairnsdale, Pakenham, Adelaide, Perth, Brisbane and New Zealand sites, and the Mentone Head Office.)

Authorised by: Chief Executive Officer

GENERAL PRINCIPLES

All:

raw material and packaging suppliers which do business with the Patties Food Group (Patties); and

indirect suppliers which do more than $100,000 AUD/NZD p.a. business with Patties,

(Suppliers)

must confirm they will meet Patties’ ethical supply obligations by returning a copy of this policy signed by an authorised representative of the Supplier.

Additionally, all raw material and packaging suppliers which do more than $500,000 AUD/NZD p.a. business with Patties are required to have SEDEX membership, and link with Patties so that Patties can access the Supplier’s SMETA audit results and conduct an ethical risk assessment.

All supplier sites may be subject to an audit, either by Patties or an independent third party, as a condition of business or if Patties suspects its minimum standards are compromised.

RAW MATERIALS SOURCING

Patties prioritises sourcing raw materials domestically, where cost, quality and other trading terms are equivalent to alternative suppliers.

Patties does not use raw materials (including food additives and processing aids) that meet the labelling requirement for genetically modified food per the Food Standards Code Australia New Zealand. Suppliers are required to disclose whether raw materials contain any such GM material.

Patties is a member of the Roundtable on Sustainable Palm Oil and supports the industry wide move to advance production using only certified sustainable palm oil. We only work with Suppliers which also support this position.

Patties only uses cage free eggs in all branded products, and private label products where this is a customer requirement.

Patties respects animal welfare and requires its Suppliers to hold industry standard animal welfare certifications. Unless otherwise agreed, the certifications acceptable to Patties are:

AAWCS – Ausmeat (beef and lamb)

RSPCA – (Chicken, Pigs, Layer Hens, Turkeys, Salmon, Dairy Calves)

SPCA – (Free range and barn raised meat chickens, free range and free farmed pigs, beef cattle, dairy cattle, dairy sheep, sheep and lambs, Chinook salmon)

ESA – Eggs.

HUMAN RIGHTS AND MODERN SLAVERY

Patties acknowledges it has a responsibility to protect human rights, and to identify, prevent, mitigate and account for how we address our impacts on human rights.

Accordingly, Patties will only do business with Suppliers whose workers (including the workers in the Supplier’s supply chain) are treated in accordance with applicable law and regulations, present voluntarily, are not put at risk of physical harm, are provided with a safe workplace, are lawfully and fairly compensated, are allowed the right of free association, and not exploited in any way, including by modern slavery (trafficking, servitude, forced marriage, forced labour, debt bondage, unlawful child labour, or deceptive recruiting for labour services.) All overtime must be voluntary.

Suppliers shall not use unauthorised sub-contractors and shall declare in writing all sub-contractors prior to their use (including sub-contracting, home-working and any other external processing).

If a Supplier operates as a broker, it agrees to require the specific facilities which supply to Patties to confirm they will meet Patties’ ethical supply obligations by returning a copy of this policy signed by an authorised representative of the facility, and if requested, link with Patties on SEDEX.

In meeting the above standards Suppliers shall:

Take all reasonable measures to ensure that workers in their own supply chains are treated lawfully and are not victims of any form of modern slavery; and

Maintain oversight of employment conditions of any labour hire and sub-contracted labour.

ENVIRONMENTAL PROTECTION

Patties requires its suppliers to respect resources and protect the environment, and to pursue continuous improvement in the management of their environmental impact.

SUSTAINABLE PACKAGING

Patties requires its suppliers to supply goods and services in packaging which is recyclable, reusable or compostable (without compromising food safety standards) and to work towards Australia’s 2025 National Packaging Targets, and any NZ equivalent, that:

100% of all Australia’s packaging will be re-usable, recyclable or compostable by 2025;

70% of Australia’s plastic packaging will be recycled or composted by 2025;

50% average recycled content will be included across all packaging by 2025; and

Problematic and unnecessary single-use plastic packaging will be phased out through design, innovation or introduction of alternatives.

BUSINESS INTEGRITY

Suppliers shall conduct their business ethically in a legal, honest and transparent manner without any fraudulent practices.

In meeting this requirement suppliers shall:

Not engage in or tolerate bribery, corruption, fraud and coercion; and

Have systems in place for confidentially reporting, investigating and resolving concerns regarding unethical business practice.

REPORTING ISSUES AND VIOLATIONS

Suppliers shall report any suspected violations of regulations, laws and/or this policy as soon as possible.

Violations should be reported to legal@patties.com.au, or can be raised in accordance with Patties’ Corporate Whistleblowing Policy, available on its website www.pattiesfoodgroup.com.

Patties recognises that there will be suppliers in some industries that will find it more difficult to meet our minimum standards. In those cases, we will expect such Suppliers to demonstrate continuous improvement and be transparent with us about any issues they identify.

Declaration:

By signing this document, you (The Supplier) agree to comply with the Patties Food Group Ethical Sourcing Policy.

Failure by Suppliers to progress implementation of the principles underlying this policy may impact the Supplier’s business with Patties.

SIGNED BY SUPPLIER’S AUTHORISED REPESENTATIVE*:

………………………………………………………………….

Name: …………………………………………………..

Position: ……………………………………………..

Company Name: …………………………….

Date: …………………………………………………..

*General Manager, Head of Procurement, CEO or Director