2023 Modern Slavery Statement for BSR Group
Contents
(1) A message from our CEO ………………………………………………………………………………………………………. 2
(2) Overview ………………………………………………………………………………………………………………………….. 3
(3) Our Structure and Operations ………………………………………………………………………………………………… 3
(3.1) BSR Franchising ……………………………………………………………………………………………………….. 3
(3.2) Stan Cash ……………………………………………………………………………………………………………….. 4
(4) Our Supply Chains………………………………………………………………………………………………………………. 4
(5) Potential modern slavery risks ……………………………………………………………………………………………….. 4
(6) Our governance of modern slavery risks …………………………………………………………………………………… 5
(7) COVID-19 Pandemic Risk Review ……………………………………………………………………………………………. 7
(8) Board Approval …………………………………………………………………………………………………………………… 7
About this Statement
This Modern Slavery Statement serves as a review of the actions the BSR Group has taken to assess and
address the risk of modern slavery within our operations and supply chain during the reporting period 1
July 2022 – 30 June 2023.
It has been prepared in accordance with the Modern Slavery Act 2018 (Cth) (Act) and the
Commonwealth Modern Slavery Act 2018 Guidance for Reporting Entities dated May 2023 and is issued
by BSR Australia Limited on behalf of all the BSR Group’s reporting entities and controlled subsidiaries.
1. A message from our CEO
This is BSR Group’s fifth Modern Slavery Statement, which sets out our continuously improving efforts to
identify, manage and mitigate Modern Slavery risks in our operations and supply chains.
The International Labour Organisation, Walk Free, and the International Organisation for Migration
currently estimate that 50 million people globally are affected by modern slavery. This figure is an
increase on the 2017 estimate of 40.3 million and translates to nearly one of every 150 people in the
world. This increase is partially due to the effects of the Covid-19 pandemic, and the availability of
better data. These statistics are a stark reminder of the importance of our commitment to ensuring the
goods and services our corporate stores and associated retailers provide are free from modern slavery.
BSR Group continues to deliver on our due diligence obligations through the interrogation of our global
supply chains. This ensures that the confidence our customers place in the goods and services they
purchase from BSR Group is based on the knowledge that the human rights of workers who made those
goods and involved in all aspects of the supply chain have been respected.
We recognise that even for products sold in Australia, modern slavery can occur early in the supply
chain. To ensure transparency from the initial stages of production, right through the supply chain
process, we continue to work with the National Associated Retail Traders of Australia (NARTA), through
our support of its Modern Slavery Initiative (MSI). As it matures this initiative will streamline the Group’s
collection of modern slavery information from our major consumer electrical goods suppliers, further
strengthening our confidence.
2. Overview
This Modern Slavery Statement serves as a review of the actions the BSR Group has taken to assess and
address the risk of modern slavery within our operations and supply chain during the reporting period 1
July 2022 – 30 June 2023. It has been prepared in accordance with the Modern Slavery Act 2018 (Cth)
(Act) and the Commonwealth Modern Slavery Act 2018 Guidance for Reporting Entities dated May 2023
and is issued by BSR Australia Limited on behalf of all the BSR Group’s reporting entities and controlled
subsidiaries.
To find out more about the nature of our business, you can visit www.bsrgroup.com.au
3. Our Structure and Operations
BSR Group (BSR Group) is comprised of a parent company BSR Australia Ltd (ACN 122 529 695) (BSR
Australia) which is an unlisted public company (‘BSR Australia’), and the following wholly owned
subsidiaries:
1. BSR Franchising (ACN 122 556 094) (BSR Franchising).
2. Stan Cash Superstore Pty Ltd (ACN 160 223 914) (Stan Cash Superstore).
3. Stan Cash Online Pty Ltd (ACN 142 725 997), the holding company of Stan Cash Superstore.
During the reporting period this statement covers, we maintained a Modern Slavery Working Group
comprised of senior executives of BSR Australia, including those engaged in the businesses of BSR
Franchising and Stan Cash Superstore to inform and contribute to the development of the statement. For
clarity, all senior executives of the BSR Group are employed by BSR Australia. The directors of BSR
Australia are also directors of all the subsidiaries.
3.1. BSR Franchising
BSR Franchising undertakes the following business operations:
• As a franchisorto a network of Australian retail stores operating in the electrical and furniture
goods industries, under the brands Betta / Betta Home Living, Designer Appliances and
Furniture Zone, and also, as a service provider to retailers operating under their own brands
(BBA’s). There are over 200 independent retail businesses across Australia associated with
BSR.
• As joint venturer in the retail business Whitford’s Home Appliances providing marketing
assistance and supplying goods to the store network for resale.
• As logistics partner holding stock for resale in warehouses.
• As retail operator through six company owned electrical and furniture stores, Betta Home
Living Underwood, Betta Home Living Cannon Hill, Betta Home Living Hervey Bay, Betta Home
Living Belmont, Betta Home Living Parkes, and Betta Home Living Camberwell
• As online retailer of electrical and furniture goods via the following websites:
• www.designerappliances.com.au
• As a commercial supplier of furniture, electrical and bathroom goods via the brands RT
Edwards Commercial and BSR Commercial.
• As supplier of appliances through our insurance partners.
• As direct importer of furniture, electrical, kitchen and front of wall plumbing goods for resale
under the brands BSR Direct and Norj.
• As retailer of Australian made mattresses and beds under the Eversleep brand.
3.2. Stan Cash
Stan Cash Superstore undertakes the following business operations:
• As an online retailer of electrical and furniture goods via the following website:
• As an online retailer of electrical goods via the following website:
• As a retailer of electrical and furniture goods via its retail shops in Brooklyn and Keilor in
Melbourne, Victoria
4. Our Supply Chains
Our direct import product range consists of upholstered and timber furniture along with electrical
appliances and front of wall plumbing.
Furniture finished goods are sourced from China, Vietnam, Thailand, and Malaysia.
Electrical and front of wall plumbing finished goods are sourced from China, Turkey, and Italy.
Limiting our procurement to well-resourced suppliers within discrete geographic areas which have
verifiable international client bases allows us to deliver on our commitment to the abolition of modern
slavery within our supply chains by:
(a) restricting our dealings to suppliers experienced in complying with recognised international
brands’ procurement requirements including those relating to ethical sourcing of components
and modern slavery;
(b) avoiding smaller factories which may be incentivised to take advantage of perceived commercial
benefits of engaging in unlawful business practices; and
(c) engaging with internationally recognised logistics operators with readily verifiable business
practices which comply with all relevant legislation including modern slavery laws.
Our wider supply chain includes engagement with local wholesale importers and resellers. Through our
governance processes (including annual supplier self-audits and certification) we ensure these business
partners’ business practices:
(d) are ethical;
(e) align with the BSR Group’s values; and
(f meet all relevant legislative requirements.
5. Potential modern slavery risks
We have identified the following modern slavery risks which may arise through our business activities or
relationships, either directly or indirectly:
• Non-compliance with health and safety requirements.
• Unlawful or unsafe working hours.
• Underpayment of wages.
• Forced labour, child labour.
• Freedom of association.
• Broader non-compliance with human rights including employee rights to equality, fair pay,
safety, and privacy.
6. Our governance of modern slavery risks
BSR Group is committed to taking all reasonable steps to ensure that there is no modern slavery in our
supply chains or in any part of our business and acknowledge our role and responsibility in seeking to
safeguard human rights through ethical and sustainable business practices.
To identify and mitigate risk, BSR Group has the following systems in place:
6.1. Modern Slavery Policy
We have published a Modern Slavery Policy which sets clear objectives around our supplier
engagement process, grievance mechanisms and supplier collaboration.
6.2. NARTA Modern Slavery Initiative
BSR Group is a member of the National Associated Retail Traders of Australia (NARTA) and utilises
this membership to share and benefit from NARTA’s Modern Slavery Initiative (MSI), an industry
focused program which supports businesses in reviewing practices within their supply chain to
deliver best-in-class ethical standards and meet reporting requirements under the Act.
NARTA facilitates the collection of modern slavery content from consumer electronics suppliers
(non-direct import) via a standardised reporting system. NARTA then shares that content with its
members to assist them in meeting modern slavery reporting requirements. This aims to ensure
a higher level of transparency across the industry.
BSR’s Modern Slavery Working Group has incorporated the MSI data to streamline our collection
of annual modern slavery content from many of our major suppliers.
6.3. Compliance Questionnaire
We require all suppliers to complete an annual Compliance Questionnaire to:
(a) verify the supplier’s status as a “reporting entity” under the Act or otherwise;
(b) describe any identified risks of modern slavery in their operations and supply chains and
actions taken to address those risks; and
(c) provide details of all policies and procedures implemented to monitor, identify,
investigate, disclose, and remediate any instances or potential instances of modern
slavery.
All Group suppliers must have compliant modern slavery policies or equivalent which must be
provided:
(a) during onboarding;
(b) at contract renewal, or
(c) annually (for longer contracts)
6.4. Supplier Contracts
Where possible, we have incorporated modern slavery clauses into our contracts with all
suppliers (including suppliers of transportation and logistics services) and product
manufacturers. This includes our product supplier agreements which are updated on an annual
basis. The clauses include obligations requiring suppliers to:
• warrant compliance with modern slavery laws;
• take reasonable steps to eliminate modern slavery risks within their supply chains or the
supply chains of their subcontractors;
• notify us in the event of actual or suspected incidences of modern slavery in their business
operations or supply chain that has a connection to our business; and
• agree to our right to terminate the agreement if the supplier breaches any of the modern
slavery provisions of the agreement.
6.5. Reporting suspicions of slavery
BSR Group maintains a Whistleblowing Policy, which is available internally on our employee
intranet and externally at www.bsrgroup.com.au. Under the policy, all personnel, and other
eligible whistleblowers can report any conduct which raises suspicions of breaches of the
Modern Slavery Policy. We review and update our whistleblower policy regularly and provide whistleblower training to staff.
6.6. Training
All employees undergo an induction process where our policies, procedures and expectations
are outlined. This includes specific training on our Modern Slavery Policy and incident reporting.
6.7. Key performance indicators
BSR Group has the following key performance indicators in place to measure its effectiveness in taking all
reasonable steps to reduce the risk of modern slavery:
• An annual review and update of the modern slavery statement;
• Communication and personal contact with the supply chain to ensure their understanding and
compliance with our expectations;
• Review of supplier responses to the annual BSR Compliance Questionnaire regarding modern
slavery risks and mitigation;
• Sharing and receiving modern slavery compliance information regarding indirect furniture and
electrical suppliers via its membership with NARTA;
• Regular spot check audits of supplier manufacturer factories located overseas (will recommence
in FY24).
6.8. Establishment of an Environment Social Governance (ESG) Committee
BSR Group has recently established an ESG committee. The role of the Committee is to embed
sustainability and ESG into decision-making and long-term growth strategies, and also to monitor and
report on BSR Group compliance with modern slavery legislation and best practice corporate governance
initiatives.
7. COVID-19 Pandemic Risk Review
In response to the COVID-19 pandemic, BSR Group required supplier manufacturers to complete a COVID19 questionnaire which outlined the steps they have taken to protect their vulnerable workers from
COVID-19. This was to ensure workers were not underpaid or overworked due to the pandemic, and
systems were in place to support the safe return of migrant workers in the event of a shutdown of
factories due to COVID-19.
Due to the Government imposed travel restrictions during the pandemic, it was not possible for BSR Group
management to attend factories of supplier manufacturers to conduct routine spot audit checks.
However, the audit program to monitor supply chain exposure to modern slavery risks for overseas
manufacturers is scheduled to recommence in FY 24.
8. Board Approval
This statement was approved by the Board of Directors of BSR Australia Ltd and adopted by all BSR Group
subsidiaries on 18 October 2023.
