The following documents outline our governance framework and are available at www.woolworthslimited.com.au:

• Code of Conduct.
• Corporate Governance Manual.
• Constitution.
• Risk Management.
• Charter for the Competitive Sale of Independent Supermarkets.
• Options/Shares Trading Policy.

 

The Board of Directors is accountable to shareholders for performance and is responsible for Woolworths’ corporate governance practices. The board’s principal objective is to maintain and increase shareholder value while ensuring that Woolworths’ overall activities are properly managed. In doing so the board supports the highest standards of corporate governance, which it sees as fundamental to its commitment to business integrity and professionalism in all its activities.

As part of its commitment to good corporate governance, the board regularly reviews the practices and standards governing the board’s composition, independence and effectiveness and the accountability and compensation of directors and senior executives.

For more information refer to the Annual Report 2007–08.

 

The board has established a number of committees to support the board in matters that require more intensive review. These are:

• Audit, risk management and compliance committee.
• Corporate governance committee.
• People policy committee.
• Superannuation.

More information on committees of the board, their roles and responsibilities is contained in the Annual Report 2007–08.

 

All Woolworths employees, management and the board have a responsibility to maintain the highest legal, moral and ethical standards in our dealings with customers, suppliers, employees, local communities, government and regulatory bodies.

The Code of Conduct outlines our policies and practices relating to:

• How we do business.
• Our customers.
• Woolworths Limited shares.
• Conflict of interest.
• Privacy and confidentiality.
• Gifts and gratuities.
• Property and ownership.
• Health and safety.
• Anti-discrimination and equal employment opportunity.

Every employee is asked to read the Code of Conduct during their induction and then sign and return the enclosed declaration. Copies of the Code of Conduct are readily available to all staff in hard and soft copy and it is also available to the general public on our website at www.woolworthslimited.com.au.

Employees from all supermarkets and our head office have access to a 24 hour hotline where they can anonymously report incidents such as inappropriate behaviour.

 

Risk management is an essential element of good corporate governance and an integral part of good management practice. It is an iterative process of continual improvement in identifying and managing risks. We place strong emphasis on maintaining a risk-aware culture in decision making and operations and believe it is the responsibility of every Woolworths’ employee to appropriately manage risk in their day to day activities.

The Group’s Risk Management Framework embodies our overall system for managing material business risks. The Risk Management Framework is applicable to all Woolworths’ activities in all jurisdictions and countries in which we operate. Our approach to risk management has regard to relevant regulations, standards and guidelines. These include the Committee of Sponsoring Organisations of the Treadway Commission paper on Enterprise Risk Management – Integrated Framework (COSO), the ASX Corporate Governance Council’s Corporate Governance Principles and Recommendations and the Joint Australian/New Zealand Standard Risk management (AS/NZS 4360:2004).

The Board oversees and reviews the effectiveness of risk management in the organisation and is assisted and advised in this role by Board committees. Management is responsible to the Board for identifying, managing, reporting upon and implementing measures to address risk and compliance and fostering a risk-aware culture. Further, independent audit (both internal and external) and management provide regular assurance and other reports to the Board and its committees.

A summary of the Group’s Risk Management Policy is available on our website.

 

Woolworths aims to keep governments and other important stakeholders abreast of its activities. Woolworths does not make any outright political donations. All political contributions are transparent and made in the spirit of supporting the democratic process and strictly adhere to all relevant laws and regulations.

 

Our corporate responsibility agenda is simple – doing the right thing – underpinned by policies and strategies on workplace management, corporate governance, environmental sustainability and community investment. While our workplace management and corporate governance strategies are well integrated into our core business strategy and the way we do business, integrating our community investment and sustainability strategies is a work in progress. This report is our first integrated Corporate Responsibility Report.

A number of our senior managers who report directly to our Chief Executive Officer are accountable for delivering our corporate responsibility agenda. Workplace strategies are the responsibility of our Director of Human Resources; Corporate Governance is the responsibility of our Group General Counsel and Company Secretary; community investment and environmental sustainability strategies are the responsibility of our Director of Corporate and Public Affairs.

 

Ethical Sourcing Policy

There has been much debate and concern about human rights in emerging markets and developing countries, specifically in relation to ethical sourcing of products purchased overseas and sold locally.

We want to ensure we source our products responsibly, encourage our vendors and agents to improve their social and environmental practices, and protect our corporate reputation and that of our individual businesses and brands.

In response to this we have developed an Ethical Sourcing Policy that will be rolled out in a staged process commencing in February 2009. The policy relates to all Woolworths Limited businesses and brands, all imported products sourced directly by Woolworths or through our agents, and incorporates both environmental and socioeconomic criteria.

We have identified four common risk factors across all businesses and all of our brands and product categories: bribery and corruption, labour rights (including OHS), environmental compliance (waste, air and water), and packaging. The policy sets out clear and globally recognised standards for our vendors and agents and we will be continually monitoring our vendors and agents and purchasing practices to ensure they comply. Implementation involves auditing of facilities and strict Terms of Trade agreements to ensure vendors and agents adhere to policy conditions.

Woolworths has identified a number of sustainability issues relating to specific product categories such as paper and tissues, palm oil, fish and seafood. We are continuously investigating these issues and the progress on development of relevant global standards and best practice so that we can set clear guidelines for our business.

 

Partnerships

CSIRO

Woolworths was a sponsor of the CSIRO’s Future Fuels Forum, a research program that brought together fuel stakeholders from community, industry and government. The nine month, sectorwide initiative looked at developing and analysing scenarios to address the challenges facing secure and sustainable transport fuel in Australia to 2050. For more information click here.

Australian Food and Grocery Council (AFGC)

We have partnered with AFGC to fund a study into ways of measuring the carbon footprint of food, beverage and grocery products – to help industry and government better understand and evaluate the concept of carbon footprinting in the Australian context. For more information click here.

Landcare Australia and Country Women’s Association

Our National Drought Action Day aims to help Australian farming families affected by drought. By partnering with Landcare and the Country Women’s Association we have been able to ensure that the funds raised, through donating all of our profits for one day, go to families most in need and support sustainable farming programs around Australia.

For more information click here.

Sustainability Advisory Group

Woolworths is keen to learn and grow in the area of sustainability. In 2007 we established a Sustainability Advisory Group to provide independent strategic advice and a diverse range of views to Woolworths’ CEO and senior management group.

The Group brings together leaders in the fields of environment, sustainability and corporate responsibility to guide us on our sustainability strategies and represent the views of the broader community and our diverse range of stakeholders. In this way we are able to gain input from experts, thought leaders and the community as a whole to work towards best practice in sustainability and corporate responsibility in the retail sector.

Since its formation, the Group has met three times and discussed a range of issues such as Select tissue products (mentioned previously in this report), Woolworths’ ethical and sustainable sourcing policy, biofuels and food security and forestry certifications. The Group met on 29 November 2007, 1 April 2008 and 31 July 2008.

The members of the Group are:

Mr Greg Bourne
CEO, WWF Australia

Ms Roberta (Bobbie) Brazil
Chair, Australian Landcare Council

Dr Walter Cox
Chairman, Independent Audit Group for water use in the Murray-Darling Basin Immediate past chairman, WA Environment Protection Authority

Dr Simon Longstaff
Executive Director, St James Ethics Centre Chairman of Sustainability Advisory Group

Ms Sam Mostyn
Group Executive, Culture and Reputation, IAG

Ms Fiona Wain
CEO, Environment Business Australia

Mr Bob Welsh
Chair, Sustainability Victoria and CEO, VicSuper

Maryanne Macleod
Group Manager – Strategic Direction, Environment – Bay of Plenty, New Zealand
Ms Macleod resigned from the Advisory Group on 9 June 2008

Members from within Woolworths are:

Michael Luscombe, CEO

Andrew Hall, Director of Corporate and Public Affairs

Armineh Mardirossian, Group Sustainability Manager

Stakeholder engagement framework

Since August 2007 we have been working to develop a stakeholder engagement framework that will enable us to better predict and manage emerging stakeholder issues. With expansion plans of around 720 stores over the next five years in Australia and New Zealand, how we manage community concerns around the development of new stores is critical to help deliver the best outcomes for the communities we move into while still meeting our commercial objectives.

We have undertaken research within our property division to understand current stakeholder engagement practices. This information is being used to develop a new approach that will be used to help us understand and respond to the issues faced by local communities where a new Woolworths store is being developed.

Non-government organisations

As part of a comprehensive review of our community investment strategy we held a workshop in June 2008 with key opinion leaders in the not-for-profit sector to gather information on how our community and social programs are perceived, and to provide ideas for future guidance on these issues.

The issues discussed at the workshop included programs addressing obesity, nutrition and labelling, tobacco and alcohol, disadvantaged groups, awareness of existing programs, customer values and drought.

The workshop outcomes will be used in the development of our new community investment strategy (for more information see Community Investment section) and will form the basis for future engagement with these groups.

Groups that participated in the workshop were:

• Youth off the Streets.
• Heart Foundation.
• Country Women’s Association.
• Healthy Kids School Canteen Association.
• RSPCA.
• Salvation Army.
• YWCA.
• Cancer Council NSW.
• Parents’ Jury.

 

Eco Ambassador Program

We have set a number of environmental targets in key areas and are investing in technologies and initiatives to reduce our environmental footprint. But these investments will only take us so far unless we engage our employees in being more efficient in our stores, offices and Distribution Centres.

Through our Eco Ambassador Program we are developing sustainability expertise at the store and Distribution Centre level by raising participants’ awareness and empowering them to take action. They will also be equipped with the knowledge to influence their colleagues’ behaviour and educate customers about our sustainability initiatives.

We currently have about 530 Eco Ambassadors across all business divisions throughout Australia. The New Zealand program will commence in early 2009.

Our Eco Ambassadors have received training in sustainability and the environmental challenges that are being faced globally, nationally and within the business. They have also been instrumental in identifying sustainability opportunities for their workplace, barriers to change and solutions to those barriers.

Our Eco Ambassadors have taken what they have learned back to their workplaces and are encouraging their co-workers to conserve energy and water, and recycle correctly, both at work and at home.

We support our Eco Ambassadors with ongoing communication and by setting tasks for them to complete in their workplace.

Employee feedback and consultation

We operate a range of formal and informal employee consultation techniques across the business to also inform our people and provide opportunities for them to communicate their views back through the business. These include workshops, focus groups, online surveys, team talks, roadshows and conferences.

“I’ve got an idea” program

Since its inception in 2006, this initiative for all Woolworths and Safeway supermarket staff has seen over 2,600 business improvement ideas submitted.

Communicating with our people

A range of methods is used to facilitate employee communications within Woolworths, from store team talks to regional managers regular videoconferencing, area management meetings and so on. As only a small percentage of our staff have regular access to email and intranet, most employee communication happens face to face or through printed and audiovisual means.

Some of the methods we use to communicate with our people include:

• WoW TV, weekly television programs broadcast to all of our supermarkets.
• Woolies News, a quarterly magazine for all Woolworths staff, Norwest News, a monthly email for employees at our Norwest support office in Sydney and WoW Express, a monthly newsletter for all supermarket staff.
• Divisional magazines and newsletters including Xpress, a monthly newsletter for supermarket staff; Cheers, a monthly magazine for the BWS team; and BIG News, a monthly newsletter for BIG W staff.
• Monthly CEO communications meeting at our Norwest support office.
• Annual four day company conference attended by all store managers and key support staff, plus their partners (approximately 5,000 people in total).
• Company intranet (WOWnet) available to employees working in support areas of our business who have access to a computer.
• An external internet site, the WoW Noticeboard which enables staff to access company news and information via the internet.

 

Private Label

Our most recognised supermarket house brands are Homebrand, Select and Essentials.

The Woolworths Homebrand range has been one of the country’s most popular brands for over 20 years, and now encompasses around 800 products. This value range provides quality products within the budget price category. Homebrand is Australia’s largest selling single brand of groceries.

The Woolworths Select range was introduced in March 2005 to provide customers with over 1,200 premium Private Label products.

Our customers have responded enthusiastically to the quality and value that Woolworths Select offers, with recent research indicating 75% of Woolworths customers who have purchased a Woolworths Select product have become repeat buyers.

As a healthy lifestyle and diet are becoming increasingly important concerns for many Australians, all products in the Woolworths Naytura range have been carefully selected to care for our customer health and wellbeing. Each product is selected to provide the highest quality taste, while being low in salt, sugar, fat and additives.

The Naytura range currently includes nuts, dried fruits, cereals, spreads and biscuits. We are continually looking to expand the range to provide our customers with a wider variety of healthier food options.

Woolworths Organics is a range of organically certified fresh foods and grocery products for customers who prefer organic produce, or who are looking to explore something new. The range currently includes fresh fruit and vegetables, poultry, tinned products, milk, and cheese. We are continually looking to expand this range in line with customer demand.

We remain committed to our long standing policy of giving preference to Australian vendors who can meet our supply requirements.

Product information and labelling

We support product labelling that clearly details ingredients, nutritional content and country of origin. Our team of in-house food scientists and nutritionists reviews every specification and ingredient list to ensure that each product meets our high standards. We also aim to minimise the use of artificial colourings, additives and preservatives.

Our Private Label brands aim to exceed regulatory standards and provide as much information as possible. This includes listing ingredients such as trans fat content.

Green claims

The retail market is becoming increasingly saturated with green product claims. Unfortunately some claims can be misleading if they are not supported by evidence or not well explained. This practice of “greenwash” has led to a great deal of consumer confusion when it comes to making decisions about buying environmentally friendly products.

With more and more suppliers wanting to put environmental claims on their products it is becoming increasingly difficult to distinguish between different environmental certification standards, particularly when dealing with international suppliers. There is a demonstrated need for retailers, including Woolworths, to improve environmental labelling and verification processes to build customer trust and make it easier for customers to choose legitimately sustainable products.

Choice Australia recently carried out an investigation into green claims on non-food items from three stores from different chains in Sydney in January and March 2008. Choice looked at 185 items that carried green claims and found a total of 637 claims, an average of over three claims per product. They found that some of the green claims repeated the same or similar claim and were difficult to verify.

We developed an Environmental Claims Policy to help our buying, advertising and marketing staff to make sure that the environmental claims made on Woolworths controlled brands and in our catalogues have been properly verified and described in a way that does not mislead our customers or the general public. The policy was developed with reference to the ACCC guidelines on green marketing.

Sustainable sourcing

Palm oil

Woolworths is working to reduce the use of palm oil in Private Label food products for both nutritional and environmental reasons. Palm oil contains about 50% saturated fats and is inferior in quality to other vegetable oils. Production of palm oil can contribute to destruction of habitat and biodiversity, and some of our customers had contacted us to express their concerns about this issue.

We have been able to exclude direct use of palm oil from our Select brand food products and are in the process of phasing it out from all Homebrand food products and in store baked goods. Our Private Label team implements this requirement through the product development process working with our suppliers.

This is an issue that is very much dependent on the cooperation of the entire supply chain supplying the various ingredients for our Select and Homebrand products.

While all our manufacturers of Select and Homebrand know our policy position on palm oil in our Private Label food products, some of their suppliers may change the source of their ingredients such as an emulsifier or a flavour base which may contain a palm oil derivative. This is not easily identifiable as there are no mandatory labelling or disclosure requirements of palm oil under the current Australian food regulations.

This is presenting a challenge for us in terms of continuous monitoring and enforcement. Our Private Label team is working with our supply chain to understand and overcome these issues.

Fisheries

We have started working with the Marine Stewardship Council to help develop an understanding of the issues relating to sustainable fishery practices and chain of custody certification. Our aim is to use this information to develop a policy on fish sourcing.

Quality assurance

Supermarkets

Our quality assurance (QA) team is made up of 18 qualified technical staff in Australia and four qualified technical staff in New Zealand. These include food technologists, nutritionists, chemists and the QA food laboratory team located in state of the art laboratory facilities at Norwest.

The QA team is responsible for ensuring all products sold to our customers in our Fresh Food Departments and under our Private Label brands are safe and of the highest quality.

All suppliers of fresh food and Private Label in Australia must be certified to the Woolworths Quality Assurance (WQA) standard, and all suppliers are independently audited biannually to demonstrate compliance to the WQA Standard.

WQA certification is under way in New Zealand for suppliers of Private Label products that are procured locally for Homebrand, Signature range and Select. We are currently rolling out WQA certification into the New Zealand fresh food suppliers with full certification expected by 30 September 2009.

A quality manager works with the Private Label business manager to ensure all products are sourced from WQA approved suppliers and developed in accordance with brand guidelines on quality. The quality manager ensures all claims made on products are validated and comply with relevant regulations.

BIG W and General Merchandise

The Quality Assurance Team for BIG W and Woolworths General Merchandise is responsible for improving the quality, safety and functionality of goods for our customers, minimising risk and improving compliance with laws and regulations that protect the Australian consumer. Our team also plays a vital role in establishing and protecting the credibility of the Woolworths and BIG W brand names.

Seventeen technicians based at our Norwest laboratory work in two teams: Hardgoods which tests and monitors the quality of toys, electrical appliances and all general merchandise; and Softgoods which tests and monitors design and textiles for apparel, homewares and shoes. The laboratory, called Qualtest, is an accredited testing laboratory and is National Australian Testing Authority (NATA) accredited for toys.

Our Hong Kong operation has seven technicians who currently concentrate on post production, pre shipment inspections, factory audits in China and influencing the quality of goods sourced internationally. The quality and safety of our goods are also monitored at each Distribution Centre, assisting with our speed to market and acting as an inspection filter before products are made available to customers.

Consumer Electronics

Our consumer electronics QA team manages third party inspection providers, performs incoming QC testing, reviews and analyses product reliability history and determines and implements product improvements. In conjunction with the Engineering and Compliance team, they ensure that our house brand products comply with mandatory safety standards and achieve satisfactory levels of performance and reliability.

 

Customer research

We conduct regular research on customer needs and wants to help us tailor our services and products to meet customers’ expectations.

Customer research comprises two main streams: shopper monitors and specific research studies.

Shopper monitors provide ongoing measurement of customer perceptions and satisfaction and include:

• Brand health trackers: to measure brand health, performance on key customer needs and customer satisfaction.
• Customer satisfaction program: to measure customer satisfaction with their shopping experience, including Woolworths’ performance on key customer needs.
• Roy Morgan monitor: to monitor general shopping behaviour and attitudes, including perceptions of Woolworths and key competitors.

Examples of specific research studies include:

• Obtaining customer feedback on shopping experience, particularly around new store design (Supermarkets and BIG W).
• Identifying strengths, weaknesses and areas for improvement in the Woolworths offer/experience (Supermarkets, BIG W, Consumer Electronics, Liquor, ALH).
• New product development (Supermarkets, Group Financial Services).
• New business development (Thomas Dux, Business Development, Customer Engagement).
• Developing customer loyalty programs (Customer Engagement).

All our customer research complies with the Australian Market and Social Research guidelines and codes of conduct. Our research is designed to ensure the results are both reliable and representative of the customer base.

Tools used to seek customer feedback include:

• Face-to-face interviews and accompanied shopping trips.
• Focus groups or workshops in a central location.
• Focus groups held in store.
• Telephone and online surveys.
• Mystery shopping.

CUSTOMER RESEARCH RESULTS 2007–08

Sample size (among Woolworths customers)	5,670
% Customers who associate Woolworths with
You can buy everything there	56.0%
They have friendly and helpful staff	50.1%
They are clean and tidy	69.1%
They are well laid out	62.3%

Source: Roy Morgan Supermarket Monitors.

Customer complaints and enquiries

Woolworths has policies to handle all types of customer feedback:

• Service oriented.
• Product contamination.
• Shortfalls in product quality.
• Transaction charging disputes.

We have systems in place to capture customer feedback and complaints including:

• Store Management details displayed at the entrance of our stores for complainants to consult when they have feedback.
• If a customer does not wish to discuss the complaint at store level they can contact Woolworths on the customer line 1300 767 969 or via the Woolworths Supermarkets website www.woolworths.com.au.

If the issue cannot be resolved at store level, the complaint is escalated to either a regional or national level. The complaint is investigated and the customer contacted (if they have requested further contact).

If the issue is with a product the supplier may become involved and contact the customer to help resolve the issue. This will only occur if the customer has given their consent to have their details passed on.

On a monthly basis we receive between 3,500 and 4,500 customer queries. These range from customer complaints, compliments and general enquiries.

 

Respecting customer privacy

Woolworths complies with the National Privacy Principles for the Fair Handling of Personal Information that sets standards for collection, access, storage and use of personal information that we obtain as part of our business operations.

Our respect for our customers’ right to privacy of their personal information is paramount. We have policies and procedures to ensure that all personal information, no matter how or where it is obtained, is handled sensitively, securely, and in accordance with the National Privacy Principles.

This Privacy Policy sets out:

• The types of customer information we collect.
• Our policies on the management of personal information.
• How we collect, hold, use and disclose information.

Personal information collected

We may ask customers for personal details such as name, address, telephone number or email address in line with privacy laws. Some examples of where we may need these details are lay-bys, home delivery of groceries, or in-store competitions. We take measures to ensure personal information is protected from unauthorised access, loss, misuse, disclosure or alteration. We destroy or permanently de-identify personal information when it is no longer required. How we do this varies with the type of information, and how it is collected and stored.

Generally, customers have no obligation to provide any information requested by us. However, customers who choose to withhold requested information may not be able to access the goods and services depend on the collection of that information, particularly if collection of that information is required by law.

How personal information is used

The personal information we ask for is generally used to provide goods or services to customers. For example, for a credit card transaction we need the card number, and for a competition we need the customer’s contact details so we can inform them if they win.

We may also use personal information to provide a better service to customers. This may include using personal information to advise customers of new products and services.

Where possible, we try to ensure our disclosure of information to other organisations (for example market researchers, and others with whom we have commercial arrangements) is done in a way that does not personally identify individuals.

Access to personal information

We will provide customers with access to any of their personal information we hold (except in the limited circumstances recognised by privacy law).

Customers seeking access to their personal information can email privacy@woolworths.com.au or phone (02) 8885 8000 for more information.

 

Memberships

Some of the organisations that Woolworths is a member of are listed below:

• Australian National Retailers Association.
• Australian Institute of Packaging.
• Packaging Council of Australia.
• Business Council of Australia.
• Efficient Consumer Response Australasia.
• Australian Logistics Council.
• Produce Marketing Association.
• Horticulture Australia Limited.
• Australian Citrus Growers.
• Sydney Chamber of Commerce.
• Australian Employers Network on Disability.
• Environment Business Australia.
• Victorian Transport Association.
• NSW Road Freight Advisory Council.
• Safety Institute of Australia.
• Victorian Storage Industry Alliance.
• Procurement Strategy Council.
• Customs Brokers and Forwarders Council of Australia.
• Consumer Electronics Suppliers Association.
• Western Australian Chamber of Commerce and Industry (Retail Trade Association).
• Australian Hotels Association.
• Urban Taskforce.
• New Zealand Retailers Association.
• New Zealand Business Council for Sustainable Development.
• Packaging Council of New Zealand and a signatory to the New Zealand Packaging Accord.
• New Zealand Business Roundtable.
• Property Institute of New Zealand.

Industry codes

Woolworths is a signatory to the following industry codes:

• Electronic Product Code.
• Produce and Grocery Industry Code.
• Retail Logistics Supply Chain Code of Conduct.

Product requirements

All products must meet the current Australian Commonwealth, state or territory’s regulatory requirements including:

• Food Standards Australia and New Zealand (FSANZ) – Governs all food legislation in Australia relating to food safety, labelling.
• Australian Competition & Consumer Commission (ACCC) – Stipulates the requirements relating to country of origin statements and deceptive and misleading labelling.
• Therapeutic Goods Administration (TGA) – Stipulates the requirements relating to country of origin statements and deceptive and misleading labelling.
• Australian Quarantine and Inspection Service (AQIS) – Body accountable for inspection of all imported goods.
• Trade Weights and Measurements – Legislation governed by the Department Fair Trading within each Australian state/territory.
• Trade Weights and Measurements (New Zealand).

Alcohol

• Alcohol Beverages Advertising Code (ABAC) and Complaints Management Scheme.
• Various state and territory based mandatory licensing restrictions and voluntary product restrictions.

Consumer Electronics

• AS/NZS 61558.1:2000: Safety of power transformers, power supply units and similar.
• AS/NZS 60065:2003: Audio.video and similar electronic apparatus – Safety requirements.
• AS/NZS 60950.1:2003: Information technology equipment – Safety – General requirements.
• AS/NZS 60335.1:2002: Household and similar electrical appliances – Safety – General requirements.
• Telecommunications Labelling (Customer Equipment and Cabling) Notice 2001.
• Radiocommunications (Compliance Labelling – Electromagnetic Radiation) Notice 2003.
• Radiocommunications (Compliance Labelling – Incidental Emissions) Notice 2001.
• Radiocommunications Devices (Compliance Labelling) Notice 2003.

 

 

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