Woodbrook Wines Pty Ltd
2025 Modern Slavery Statement
Introduction and Reporting Entity
This is the Modern Slavery Statement of Woodbrook Wines Pty Ltd (ACN 663 564 850)
("Woodbrook") under the Modern Slavery Act 2018 ("the Act") in relation to the reporting period ended on 30 June 2025 ("the Reporting Period").
This statement has been prepared as a joint statement (*1) submitted by Woodbrook on behalf of Woodbrook and A.G. Oatley Wines Pty Ltd (ACN 118 584 928) ("AGOW") (both reporting entities under the Act).
Woodbrook has approved the joint statement on behalf of both related entities, their subsidiaries and other associated companies and entities (together the "Joint Reporting Entities") and the Chairman of directors of Woodbrook has signed the statement.
Structure, Operations and Supply Chains
Structure
Woodbrook beneficially owns 100% of AGOW.
The board of Directors of W oodbrook oversees the operations of the Joint Reporting Entities.
The Joint Reporting entities employ approximately 100 people in Australia.
Operations
Woodbrook Wines Pty Ltd (Woodbrook)
Woodbrook operates as the holding company of AGOW and as such, its principal activity is investment in an unlisted company (AGOW).
A.G. Oatley Wines Pty Ltd (AGOW)
AGOW operates vineyards and a winery in Mudgee NSW, Australia, and bottles and packages the wine it produces from that region and secures from other regions in Australia, for sale in Australia and overseas under the Robert Oatley, Wild Oats and various other brands.
Own brand sales and third party sales via distribution and agency agreements are undertaken in Australia by Oatley Fine Wine Merchants (a division of AGOW)(*2).
AGOW sells own brands to other overseas jurisdictions either directly or through arrangements with third party distributors.
Supply Chain
Products are provided by third parties for use in the products provided by AGOW to its customers.
AGOW undertakes primary production (viticulture) on its own account and contracts with third parties for the supply of grapes, juice and bulk wine. Bottling activities undertaken by AGOW from its Mudgee facilities involve the purchase of glass, labels and packaging materials from third party Australian suppliers and spares and equipment from the Italian supplier of the company's bottling line.
The supply chain of AGOW also includes significant transport and warehousing activities, either operated by the entity concerned or supplied by third parties.
Risks of Modern Slavery Practices in Operations and Supply Chains of the Joint Reporting Entities
Definition of risk
For the purposes of this statement, the risks of modem slavery practices "means the potential for the reporting entity to cause, contribute to or be directly linked to modern slavery through its operations and supply chains" (*3).
Cause: for example operate a factory that exploits labour;
Contribute to: operations and or actions in its supply chain contribute to modem slavery;
Directly linked to: the entity's operations, products and services may be connected to modem slavery through the activities of another entity it has a business relationship with.
Limitation in Scope
Under the Act, the Joint Reporting Entities are not required:
- to report on modem slavery risks associated with how their customers use the products or services they purchase (*4); or
- monitor or report on the operations and supply chains of individual investees that engage in investment activities where the Joint Reporting Entity does not have control over the actions of the investee (*5).
Accordingly, in providing a description of the risks of modern slavery practices in the operations and supply chains of the Joint Reporting Entities these risks have not been considered.
Description of Risks
The Joint Reporting Entities do not cause modern slavery. All operations for the manufacturing and supply of the Joint Reporting Entities products and services are undertaken in Australia.
The risks that the Joint Reporting Entities contribute to modern slavery include the risks that their operations, actions or omissions in their supply chains may facilitate or incentivise modern slavery. These risks are heightened where a Joint Reporting Entity is dealing directly with an overseas supplier based in a jurisdiction with known modern slavery concerns, the products involved are linked to modern slavery and the amount involved in the dealing is material.
The most significant risk to the Joint Reporting Entities is the potential that they are directly linked to modern slavery through the activities of a third party entity that a Joint Reporting Entity has a relationship with, specifically through the purchase of goods from those other entities.
Actions Taken by the Joint Reporting Entities to Assess and Address these Risks
Overview
Woodbrook has developed Ethical Dealing Principles and a Code of Conduct which have been adopted by the Joint Reporting Entities.
The Ethical Dealings Principles form the basis of the education of employees, suppliers, contractors and other stakeholders into the way Woodbrook conducts its business and what it expects of its business partners.
The Code of Conduct outlines how the Joint Reporting Entities should conduct themselves and applies to all officers, employees and contractors of the Joint Reporting Entities. Through appropriate contractual arrangements and procurement principles, consultants, agents, suppliers and other partners of the Joint Reporting Entities are expected to comply with this Code of Conduct in all of their dealings with or on behalf of the Joint Reporting Entities.
The Ethical Dealing Principles form part of the Code of Conduct
With respect to modern slavery, the Ethical Dealings Principles state:
Human Rights
We respect rights inherent to all human beings, regardless of race, sex, nationality, ethnicity, language, religion, or any other status including the right to life and liberty, freedom from slavery and torture, freedom of opinion and expression and the right to work and education.
We do not tolerate any form of modern slavery including slavery and slavery-like practices and conditions.
With respect to modern slavery, our Code of Conduct states:
Human Rights
We uphold and respect human rights for all people. We respect rights inherent to all human beings, regardless of race, sex, nationality, ethnicity, language, religion, or any other status including the right to life and liberty, freedom from slavery and torture, freedom of opinion and expression and the right to work and education.
We do not tolerate any form of modern slavery including slavery and slavery-like practices and conditions inclusive of child labour, forced labour, human trafficking or servitude.
We expect our suppliers and other partners to adhere to the same human rights standards as we do.
We comply with all relevant modern slavery legislation.
Woodbrook adopts a risk based approach to determine the actions taken to address the risk that a Joint Reporting Entity contributes to or is directly linked to modern slavery. This means that it focuses on those activities in the supply chain where the risk of contributing to or being directly linked to modern slavery is highest.
A risk based approach is adopted as W oodbrook does not have unlimited resources and wishes to focus its activities to those which are most effective in dealing with the issue of modern slavery.
Woodbrook uses the Global Slavery Index (*6) to identify those products and countries where the prevalence of modern slavery is high and therefore that the risk that a Joint Reporting Entity is contributing to or being directly linked to modem slavery is also high.
Contributing to Modern Slavery
As noted previously, the risks that the Joint Reporting Entities contribute to modem slavery are heightened where a Joint Reporting Entity is dealing directly with an overseas supplier based in a jurisdiction with known modem slavery concerns, the products involved are linked to modem slavery and the amount involved in the dealing is material.
Accordingly, prior to any contract being issued for the supply of a product with a value in excess of $100,000 to an overseas supplier based in a jurisdiction with known modem slavery concerns and/or the products involved are linked to modem slavery, the Joint Reporting Entity will undertake sufficient due diligence to provide comfort that the supplier does not cause or contribute to modern slavery. Initially, this due diligence will involve the completion of a declaration by the supplier with respect to the procedures and controls in force to ensure that the supplier does not cause or contribute to modern slavery. Further due diligence may be undertaken dependent on the assessment of the initial material provided by the supplier.
Direct Links to Modern Slavery
The Joint Reporting Entities consider that the highest risk that their operations, products and services may be connected to modern slavery is through the activities of another entity the Joint Reporting Entity has business relationships with. For example, whilst AGOW secures its packaging supplies from Australian suppliers, those suppliers may contribute to or be directly linked to modern slavery, without AGOW's knowledge.
The Joint Reporting Entities adopt the following actions to reduce such risk.
- All existing and new suppliers of goods and services to the Joint Reporting Entities with an annual spend of $3,000 or more have been sent a copy of the Ethical Dealing Principles and have been requested to contact the respective Joint Reporting Entity if they do not adhere to such principles ("Negative Assurance");
- The Joint Reporting Entities have adopted a risk based approach to identify and undertake due diligence with respect to suppliers where the risk of a direct link to modern slavery is highest. The criteria:
- Are applied to all suppliers with an annual spend of $100,000 or more on the basis that a Joint Reporting Entity has the ability to influence change, if required, from the supplier where the annual spend exceeds this amount;
- Assume that Australian suppliers and suppliers from jurisdictions with laws dealing with modern slavery are lower risk;
- Identify products and countries considered to be at greater risk of modern slavery (*7) and, initially, request suppliers where such criteria apply to complete a risk assessment questionnaire ("Positive Assurance"). The results of such questionnaire are used by a Joint Reporting Entity to determining whether remediation action is necessary ( or indeed possible) or whether the relationship with the supplier should be terminated.
In relation to the Reporting Period the following actions were taken for suppliers (*8):
- the Joint Reporting Entities emailed the Ethical Dealing Principles to 322 suppliers and received no queries or concerns from suppliers in relation to the Ethical Dealing Principles which were not satisfactorily resolved; and
- the Joint Reporting Entities assessed 118 suppliers this year with an annual spend of$100,000 or more. As a result of these assessments, the Joint Reporting Entities issued a total of 11 questionnaires for completion by suppliers. At the date of this statement:
- 9 questionnaires had been returned. Of these:
- The responses of 9 questionnaires and any related due diligence resulted in the Joint Reporting Entities concluding that the risk of modern slavery was low and the relationship with the respective supplier continues; and
- No relationships with suppliers have been terminated or suppliers required to undertake remediation actions.
- For the 2 outstanding questionnaires, further due diligence has been undertaken (including review of both suppliers own modem slavery statements and modem slavery policies) and, at this point, the Joint Reporting Entities concluded that the risk of modem slavery was low and the relationships with the respective suppliers are ongoing. Accordingly, the Joint Reporting Entities have determined that no further action was required.
- 9 questionnaires had been returned. Of these:
- At the date of this statement, the Joint Reporting Entities were not aware of any direct links to modem slavery through the activities of a supplier that a Joint Reporting Entity has a relationship with.
Remediation
Instances of modem slavery identified by the due diligence activities of the Joint Reporting Entities, if any, are brought to the attention of the Woodbrook Board and a decision is made as to any additional steps ( other than the termination of the business dealings with the entity concerned) to be taken to ensure the harm cannot recur, formal apologies are received, compensation is paid or the entity concerned ceases certain activities. Illegal acts, if any, are reported to the relevant authorities ("Remediation").
During the Reporting Period no additional steps were approved by the Woodbrook as a result of the due diligence activities of the !oint Reporting Entities.
How the Joint Reporting Entities Assesses the Effectiveness of these Actions
The Woodbrook Board and representatives from AGOW:
- approve:
- the description of the risks of modem slavery practices in the operations and supply chains of each of the Joint Reporting Entities; and
- The actions proposed to be taken by each Joint Reporting Entities to assess and address these risks, including due diligence and remediation processes; and
- assess the effectiveness of these actions by way of ongoing monitoring and reporting at Woodbrook Board level on compliance with the above process and Woodbrook's Ethical Dealing Principles and Code of Conduct.
Following such assessment, the Woodbrook Board and the representatives from AGOW will determine what immediate remedial action or changes are required for subsequent reporting periods to ensure the procedures and controls in force remain effective. Joint Reporting Entities recognise that, while an evolving process, they are committed to the ongoing review of the effectiveness of the actions being taken to assess and address modem slavery risks in their operations and supply chains.
Process of Consultation with Joint Reporting Entities
Each of the Joint Reporting Entities was actively engaged and consulted in the process of preparing this joint statement, including the description of the risks of modern slavery practices; the actions proposed to be taken to assess and address these risks; reporting requirements; and other relevant materials and updates.
As noted above, the board of Directors of W oodbrook oversees the operations of the Joint Reporting Entities through regular meetings. During the Reporting Period, the Woodbrook Board met 6 times in conjunction with meetings of the AGOW Board and Executive Management which also oversee compliance with Woodbrook's Ethical Dealing Principles and Code of Conduct.
The chief executive of AGOW reports on operations to the Woodbrook Board. This will include any issues arising with respect to the Woodbrook's Ethical Dealing Principles or Code of Conduct, including modern slavery.
Following:
- the assessment of the effectiveness of the execution of the modern slavery plan; and
- the preparation and review of the statement by _the Joint Reporting Entities
the Woodbrook Board and representatives from AGOW resolve to recommend approval of the annual statement to the directors of Woodbrook and its signature by the Chairman of Woodbrook.
This statement was approved by the Board of Directors of Woodbrook Wines Pty Ltd on 18 December 2025.