Region GroupASX: RGN

2025 Modern Slavery Statement

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‌2025

Modern Slavery Statement

Supporting better communities through life's essentials.



‌Contents Letter from the CEO‌

Reporting Entity 2

Letter from the CEO 3

Region's Structure, Operations and Supply Chain 4

Region's structure 4

Region's operations 4

At Region, our purpose is supporting better communities through life's essentials. This continues to guide our actions and shape our

commitment to addressing modern slavery. This purpose inspires us to drive positive change and foster environments that enhance the wellbeing of our stakeholders.

Region's supply chain 4

Risks of modern slavery in Region's operations and supply chain 6

Operational risks 6

Supply chain risks 9

Measures taken to assess and address risks of modern slavery in Region's business 10

Preventing modern slavery in Region's operations 10

Preventing modern slavery in Region's supply chain 10

Assessing effectiveness 12

Consultation 13

Action plan for future reporting periods 14

Appendix 15

Reporting Entity

The Reporting entity of this Modern Slavery Statement is Region Group ("Region") which comprises Region Management Trust, Region Retail Trust (together, "Trusts"), Region RE Limited ("Region RE") and any entities owned and/or managed, either beneficially or legally, by the Trusts or Region RE for the financial year ending 30 June 2025. It also includes reference to some actions which have occurred after 30 June 2025. Where such actions have been included, the timing has been noted.

We acknowledge that our operations influence the lives of many, and we are dedicated to ensuring that this influence is constructive and responsible. As part of this commitment, we strive to create spaces that support the health, safety, and dignity of all those connected to our business.

We also recognise our duty to proactively identify and mitigate any risks of unintentional harm arising from our activities. A key aspect of this responsibility is our ongoing focus on understanding and managing modern slavery risks, an integral part of our broader commitment to human rights.

Modern slavery remains a complex and evolving issue that spans industries, supply chains, and geographies, particularly where vulnerable populations are most at risk. At Region, we remain firmly committed to ensuring that all work associated with our operations is carried out freely and ethically, without any involvement in slavery, servitude, forced labour, or human trafficking.

We view our supplier relationships as a vital opportunity to promote responsible and ethical conduct. By working collaboratively, we aim to uphold standards that reflect our values and reinforce our dedication to human rights across our supply chain.

During the reporting period, Region:

  • conducted a review of our active supplier risk map, categorising suppliers to better understand the inherent modern slavery risks within our supply chain;

  • monitored compliance with our Supplier Code of Conduct, which is specifically designed to support the identification and management of modern slavery risks;

  • continued the use of supplier engagement contract templates to address modern slavery risks within contractual arrangements with suppliers and service providers;

  • provided all employees with modern slavery awareness training;

  • included modern slavery requirements as part of the selection criteria in procurement processes and service contracts; and

  • awarded new national contracts for cleaning and security services in the second half of FY25.

The supplier selection process included specific modern slavery criteria within the evaluation matrix, ensuring potential suppliers were assessed on their approach to managing these risks. Modern slavery clauses were embedded in the new cleaning and security contracts.

This year's Modern Slavery Statement reflects Region's continued commitment to enhancing its capabilities and establishing a strong foundation for future initiatives. Building on the progress outlined in previous statements, it demonstrates our evolving understanding of modern slavery risks across



our operations and supply chain, and details the measures we have implemented to address these risks effectively.

Anthony Mellowes

Chief Executive Officer

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‌Region's Structure, Operations and Supply Chain‌ REGION'S STRUCTURE

Region comprises two registered managed investment schemes: Region Management Trust (ARSN 160 612 626) and Region Retail Trust (ARSN 160 612 788). The securities in each Trust are stapled to form the stapled listed vehicle, Region Group. Region is listed on the Australian Securities Exchange (ASX) under the code "RGN".

Region is internally managed, which allows alignment of management interests with the interests of security holders. Region RE is the responsible entity of Region Management Trust and Region Retail Trust. Region RE is a wholly owned subsidiary of Region Management Trust.

Region RE as Responsible Entity of Region Retail Trust owns 20% of SCA Metro Convenience Shopping Centre Fund and Matrix Trust (collectively, Metro Fund), a joint venture with a global institutional investor.

REGION'S OPERATIONS

Region's core strategy is to invest in a geographically diverse portfolio of convenience-based retail properties. The portfolio is focused on the non-discretionary retail sector and is anchored by long term leases to quality tenants. Region's operations include the management, leasing, acquisition, tenancy delivery, development and disposal of retail shopping centres undertaken by an in-house team of property professionals.

Since listing on the ASX in 2012, Region has completed a number of acquisitions and divestments and at 30 June 2025, owned 87 convenience-based shopping centres in Australia with a total value of $4,374m.

At 30 June 2025, Region had 123 anchor tenants with the majority comprising of Woolworths Group, Coles Group and Wesfarmers Group stores. Anchor tenants accounted for 46% of Region's gross rent for the year ended 30 June 2025, with specialty tenants accounting for 54%. Region also manages Metro

Fund which comprises 13 properties with a total value of $711.5m.

REGION'S SUPPLY CHAIN

Region relies on a large number of suppliers to execute its business activities of which the vast majority operate in Australia. Region's supply chain comprises products and services generally grouped into the following categories:

  • Property Operations - external service providers providing a range of operational services including external property management services, sustainability, cleaning, security and office equipment.
  • Corporate - external service providers providing a range of professional services including unit registry services, banking and financial services, information technology, payroll, property valuation, travel, recruitment, audit, compliance, sustainability, custodial services and specialist advice such as legal and tax.
  • Property Development - external service providers providing a range of services including development management, design and construction. TOTAL SPEND BY CATEGORY

    Information Technology

    1.0%

    Insurance

    3.1%

    Office and Supplies

    0.7%

    Professional Services

    9.4%

    Employee related expenses

    8.9%

    Travel

    0.4%

    Asset Management

    8.5%

    Statutory Charges

    7.6%



    Subcontracted Services 60.4%

    5



    4

    4

    WA

    5

    QLD

    1

    SA

    66

    NSW

    82

    Total number of employees directly employed

    5

    VIC

    1

    TAS



    ‌Risks of modern slavery in Region's operations and supply chain‌ OPERATIONAL RISKS

    Region has assessed the risk that it causes, contributes to or is directly linked to modern slavery. As in the prior reporting period, it has assessed the risk in its direct operations as low, with no instances of modern slavery having been identified.

    Region has a small workforce of 82 people operating exclusively in Australia and all staff are employed in accordance with Australian workplace law. We have offices in New South Wales and Victoria, with employees also working remotely from Queensland and Western Australia. Each of these jurisdictions have strong employment workplace health and safety and anti-discrimination laws which Region must

    comply with. The majority of its workforce is in the corporate office in New South Wales.

    Region's workforce is predominantly made up of trained professionals with 100% permanently employed.

    Region acknowledges the following risks in relation to the management of its employees:

    1. deficient employee grievance mechanisms could reduce Region's ability to identify and remediate modern slavery risks; and

    2. inadequate modern slavery training could reduce the effectiveness of Region's policies and grievance mechanisms to manage the risk of exploitation.

    See page 10 for measures taken to assess and address these risks.



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    ‌2025 Modern Slavery Statement‌

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    SUPPLY CHAIN RISKS

    Region considers that there will be people in its supply chain who are at higher risk of modern slavery than its direct workforce.

    In FY25, Region directly engaged approximately 500 suppliers. Region's supply chain comprises suppliers that provide a wide range of services and products, including construction, property management (such as facilities management, cleaning, security, and plumbing), energy retail, legal services, financial services, and professional consultancy. All suppliers engaged by Region are based in Australia.

    Region conducts supplier chain risk assessment by drawing on guidance published by the AS ISO 20400 Sustainable Procurement Standard, suppliers were assessed against four key risk indicators:

  • Location of product or service which included the consideration of the right of freedom of association, health and safety procedures, occurrence of discrimination and average living conditions.
  • Industry sector which included the consideration of recruitment practices and the termination of employment, employment profile (reliance on

    low-skilled and/or migrant workers), living wage and existence of grievance mechanisms.

  • Supplier relationship which included the consideration of the duration of the relationship, the level of oversight and the value of the contract.
  • Existing information which included the consideration of suppliers having an ethics/ whistleblower policy, existence of a code of conduct, non-compliances with policies and other factors that are indicators of modern slavery, and media or non-governmental organisation reports indicating possible problems with labour standards.

Region then categorised the suppliers by industry sector and assigned a modern slavery risk rating, based on the following risk scoring which draws upon the Social Responsibility Alliance's Global Slavery and Trafficking Risk Template, which identifies industries with elevated risks of human trafficking.







Risk ratings range from 1-5, with 5 representing the highest risk level

Score

Risk Rating

Type of Supplier

5

Significant

Low level of skill and migrant workers

4

High

Lower level of skill

3

Moderate

Uncertainty over level of knowledge/skill

2

Low

Licensed Professionals

1

Very Low

Highly Professional and Skilled

Region has invited selected participants within its supply chain to complete a Modern Slavery

Questionnaire or, alternatively, to provide their own Modern Slavery Statements.

For suppliers who did not respond, a high-level risk assessment was conducted to identify potential reasons for non-responsiveness. Where appropriate, further follow-up actions were undertaken to address any concerns or gather additional information.

Across Region's assessments, the suppliers identified as having a potentially significant modern slavery risk were primarily in the cleaning, security and facilities management industry sectors.



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