ILLEGAL LOGGING POLICY
PURPOSE OF THIS POLICY
Freedom Furniture Australia Pty Ltd and each of its subsidiaries in Australia and New Zealand (Freedom, we, us, our) is committed to ensuring compliance with the laws designed to reduce the risks of products containing timber from illegal logging entering the Australian and New Zealand markets, including the Illegal Logging Prohibition Act 2012 (Cth) and Illegal Logging Prohibition Regulation 2012 (Cth) (Illegal Logging Laws).
As part of this commitment, Freedom takes steps to comply with its responsibilities under the Illegal Logging Laws as an importer of regulated timber products, which include obligations to undertake due diligence on a product prior to import and keep records of the due diligence undertaken.
The purpose of this Illegal Logging Policy is to:
ensure awareness of Freedom's responsibilities and obligations as an importer under the Illegal Logging Laws;
provide guidance on the processes to be used to carry out due diligence prior to importing a regulated timber product; and
enable our team members to follow the correct procedures to create and maintain records of this due diligence as required by the Illegal Logging Laws.
WHAT IS ILLEGAL LOGGING?
Illegal logging occurs when logs are harvested from a forest or plantation without the required approvals under the relevant laws of the country in which the forest or plantation is located.
It is an offence under the Illegal Logging Laws to import products containing illegally logged timber into Australia. It is also an offence not to carry out and document due diligence on regulated timber product imports.
SCOPE OF THIS POLICY
This Policy applies to all persons working for or on behalf of Freedom, including employees, directors, officers, agents, contractors and consultants, insofar as they carry out work in connection with, or otherwise hold responsibilities in relation to, Freedom’s obligations under the Illegal Logging Law (referred to in this Policy as Team Members).
This Policy also applies to all of those who have, or seek to have, a business relationship with Freedom including suppliers, service providers and franchisees (referred to in this Policy as Business Partners).
OUR APPROACH AND COMMITMENTS
As an importer of regulated timber products, we are required to carry out a due diligence process for each product prior to import, to confirm there is low or no risk that the product contains illegally logged timber. Freedom is required to maintain a written due diligence system by the Illegal Logging Laws, which details the processes we use to comply with our due diligence requirements. Our due diligence system is contained in the document titled 'Due Diligence System – Importing Regulated Timber Products' (Due Diligence System).
The Due Diligence System outlines the processes that must be used to undertake the following steps prior to importing any regulated product:
Confirm due diligence is required. Before conducting due diligence using the system, it is necessary to confirm whether due diligence is required for a timber product that we are seeking to import (or whether for example the product is exempted from the due diligence requirements).
Gather information on the product. If due diligence is required for a product, certain information must be gathered on the product to enable us to assess the risk that the product (or a component of the product) could contain illegally logged timber.
Assess the illegal logging risk. Using the information gathered, a risk assessment must be carried out (using an approved method) to identify the risk that the product uses or includes illegally logged timber.
Undertake risk mitigation steps (if required). If the risk assessment process identifies a potential (i.e., greater than low) risk that the product uses or includes illegally logged timber, risk mitigation must be performed with the view of lowering the risk.
Our policy is to only import regulated timber products if, after following the due diligence process, we have identified there is low or no risk that a product contains illegally logged timber. If we identify that this is the case, we can:
provide our approval for the shipment(s) containing the product to be transported to Australia for import; and
instruct our customs broker to answer the Community Protection Question on the customs declaration stating that the consignment conforms to the due diligence requirements under the Illegal Logging Laws.
If we have identified there is a greater than low risk that a product (or a component of a product) may contain illegally logged timber, our policy is not to import the product and to inform our supplier of the outcome of our due diligence process.
OUR RECORD KEEPING PROCESS
Under the Illegal Logging Laws, we are required to keep records of all information gathered as part of our due diligence process for a minimum of 5 years from the day a product is imported. Section 7 of our Due Diligence System details the records that must be kept for each import of a regulated timber product.
Team Members must ensure that they follow requirements for creating and maintaining records so that we can show compliance with Illegal Logging Laws. For example, the Illegal Logging Laws require Freedom to assess and determine certain matters in a sequence and prior to importing products. To support compliance with record-keeping requirements, documents relating to a record for a proposed import must be dated accurately and promptly added to the record for that product.
RESPONSIBILITY
We are committed to giving our Team Members the appropriate systems and support to enable them to assist Freedom to meet its obligations under the Illegal Logging Laws, as required by a Team Member's role and responsibilities.
Team Members are required to comply with the Due Diligence System and the record keeping method outlined in this Policy when undertaking tasks in connection with the due diligence process for a regulated timber product.
Team Members must:
read, understand, and comply with this Policy;
read, understand, and comply with compliance material that forms part of the Responsible Sourcing Framework, including the Due Diligence System;
complete any mandatory Illegal Logging Laws training appropriate to their role;
seek advice from Legal in connection with any queries or issues connected with Freedom's obligations or compliance with the Illegal Logging Laws; and
immediately report any suspected issues relating to compliance with Illegal Logging Laws.
In addition to the above, Blue Rock Sourcing Solution Limited, in its capacity as Freedom’s off-shore quality assurance/quality compliance partner, must fulfil its contractual obligations with respect to ensuring Freedom’s compliance with Illegal Logging Laws.
Management must:
ensure Freedom’s policies and procedures comply with the Illegal Logging Laws;
provide training (as appropriate to a Team Member’s role) and resources to support compliance;
respond appropriately if any illegal logging issue or risk is reported to them; and
ensure that Team Members are provided with a copy of this Policy and are aware of their responsibilities under it.
EXPECTATIONS OF BUSINESS PARTNERS
We expect our Business Partners to:
establish appropriate systems to ensure that they act in a way which is consistent with this Policy;
adopt a similar policy to this Policy, including provisions for the identification and eradication of illegal logging risks in their operations and supply chains; and
identify, assess and immediately disclose to us any actual or potential occurrence of illegal logging with which the Business Partner may be involved or associated (either through its own operations or as a result of its business relationships).
REPORTING OR RAISING A QUERY OR CONCERN
Anyone who has a query or concern about Freedom and illegal logging compliance is encouraged to raise their concern (anonymously, if desired) via our SpeakUp! channel at https://freedom.stoplinereport.com/, or for our Team Members via our digital workplace platform.
CONSEQUENCES OF NON-COMPLIANCE
Any non-compliance with this Policy by Team Members will lead to disciplinary action up to and including termination of employment or engagement.
Any actual or suspected non-compliance with this Policy by a Business Partner must be notified to us immediately. We require all Business Partners to cooperate in any investigation or related processes which we may initiate.
Any substantiated non-compliance with this Policy by a Business Partner or an entity in one of its supply chains may result in corrective action and the suspension or termination of the contractual relationship.
In all cases we reserve the right to inform relevant authorities.
COMMUNICATION
The existence of this Policy and its contents will be communicated to Team Members and Business Partners.
This Policy will be made available on our digital workplace platform and the Freedom website.
UPDATES TO THIS POLICY
The Policy will be reviewed every two years, or when there is a legislative or regulatory change. Amendments will be made with Board approval.
GOVERNANCE
This Policy has been approved by the Board of Greenlit Brands Pty Limited.