2024 Modern Slavery Statement (2024 Modern Slavery Statement)

SCENTRE GROUP2024 Modern Slavery Statement

Scentre Group owns and operates

42 Westfield destinations

in Australia and New Zealand

In this statement

2024 reporting suite

Responsible Business

Report

Eternal Sunshine by artist Mali Isabel

Acknowledgement of Country

We acknowledge the Traditional Owners and communities of the lands on which our business operates.

We pay our respect to Aboriginal and

Torres Strait Islander cultures and to their Elders past and present.

We recognise the unique role of

Māori as Tangata Whenua of

Aotearoa/New Zealand.

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Our Westfield destinations are part of the social fabric

of the communities we serve across Australia and New Zealand. They are places people visit frequently for social connection and to access a diverse range of experiences, products and services that we curate

to match their needs. Each destination is unique and

caters to multiple generations of customers.

Our Westfield destinations are strategically located in close proximity to 20 million people and major transport hubs. They provide a platform for 3,700 businesses encompassing 12,000 outlets.

Our strategic focus is to create more reasons for our customers to visit and spend their time in our Westfield destinations. In 2024, we hosted more than 22,000 events, of which more than 4,000

were community and cultural events. Most of these

events were free for customers to enjoy and create connection through experience, contributing to people staying for longer and visiting more often. We welcomed 526 million customer visits for the year, an increase of 14 million compared to 2023.

Our focus on attracting more customers to our Westfield destinations has driven higher occupancy and continuous sales growth for our business partners.

Our destinations are in demand with portfolio

occupancy at 99.6 per cent. In 2024, growth in

customer visitation enabled our business partners to achieve total annual sales of $29.0 billion in 2024, an increase of $544 million compared to 2023.

We have the largest high-quality retail portfolio in Australia and New Zealand. We continue to invest in

our destinations so they reflect customer needs and capture more of their attention and time.

The optimisation of existing space within our destinations is key to our approach to capital

investment. We have successfully taken back

existing department store space to introduce new and diverse uses that drive higher customer

visitation and engagement. In 2024, this included a $50 million redevelopment at Westfield Mt Gravatt

in Brisbane, a $27 million (SCG share: $13.5 million) redevelopment at Westfield Tea Tree Plaza in Adelaide, and the introduction of three new mini

majors: Rebel, JB Hi-Fi and an Aldi supermarket in space we previously took back from a department

store at Westfield Burwood in Sydney. Further

projects are underway at Westfield Bondi in Sydney

and Westfield Southland in Melbourne.

More information on Scentre Group's operations can be found in our 2024 Annual Report and 2024 Responsible Business Report.

Our people

Our people are the key to our pursuit of operational excellence and achieving growth. We have team members with diverse capabilities and expertise to design, construct, operate, manage and market our platform of Westfield destinations.

We employ 2,860 people across Australia and New Zealand, as at 31 December 2024. Approximately 93 per cent of our workforce is located in Australia and seven per cent is located in New Zealand.

The majority of our teams are made up of people in professional or managerial roles, who are permanently employed and covered by an award or are award free, and have their eligibility to work confirmed by us as part of our recruitment and onboarding process. Employees covered by an award are primarily covered by the General Retail Industry Award and Clerks Private Sector Award and are paid accordingly. Our employment policies and processes reflect industry practice.

As a result of the composition of our direct workforce and the established policies, procedures, and learning and development programs in place, we consider that the risk of slavery occurring in our direct operations is low.

Our values

To achieve our Purpose, Plan and Ambition, we are guided by our values - our DNA - which underpin the way we build relationships with our teams, business partners, communities and other stakeholders.

Our DNA is expressed as:

• We put our customers first
• We act with integrity
• We strive for excellence
• We succeed together
• We are constantly curious
• We create a positive legacy.

People protecting people

The health, safety and wellbeing of our people, contractors, business partners, customers and community is our priority.

Everyone is expected to play their role in creating workplaces that keep us all safe. It is part of our culture of people protecting people.

Code of Conduct -

Acting with Integrity

All our people must comply with our Code of Conduct. It sets out the expectation that they will treat everyone they deal with fairly, courteously and with respect, and requires them to comply with all applicable laws and regulations.

Everyone at Scentre Group is required to review and recommit to the Code each year, and learning and development programs educate our people about key workplace policies including our Code of Conduct. Our Code is supported by our governance policies.

We regularly review our policies, practices and behaviours to confirm they continue to meet the expectations of our business partners, communities and other stakeholders, as well as reflect social and regulatory developments. More information on our policies and practices can be found in our 2024 Corporate Governance Statement.

3. Modern slavery procurement training

Our procurement team, senior managers and other team members involved in making decisions that may be impacted by the risk of slavery, or who engage with suppliers who have a high-risk profile. The module covers:

• how to assess and address modern slavery risks with suppliers
• the role of our risk management framework and procurement processes to identify risk indicators
• identification of suppliers with a heightened risk of slavery and guidance on handling supplier-related slavery concerns
• our modern slavery response framework, which details our approach and possible courses of action if modern slavery is identified in our supply chains.

In 2024, 92 per cent of these team members completed this training on schedule. Completion of mandatory training is overseen by line managers and forms part of our approach to performance assessment.

Procurement risk training

Our people are a key part of our approach to managing the risk of slavery in our supply chain. We educate our teams about modern slavery, our aim to prevent it and how to manage the risks in our supply chain.

We do this through our learning and development programs, our approach to knowledge sharing and cross-functional project teams, and the tools we make available to our people to effectively perform their roles.

We share our knowledge about the risk of modern slavery with key suppliers and higher-risk supplier team members.

For our team members, we consider the nature of their roles and responsibilities to identify the best way to educate them about modern slavery risks. Education opportunities include:

1. Modern slavery awareness training

We have an online training module available to all team members to raise general awareness of modern slavery and our approach to this risk.

2. Guidance material

We have a dedicated page on our intranet site to provide our people with further guidance and access to a range of tools, including modern slavery risk screening questions, to help them manage the risk of slavery when they engage with suppliers.

4. Team-specific training

Team risk workshops are facilitated by the enterprise risk management team annually to review and discuss key risks impacting teams. Slavery risks are discussed where relevant.

We also train the team members who interact most regularly with our higher-risk cleaning and security suppliers about our supplier grievance management policy and processes. This training includes:

• the definition of a grievance and how to report incidents
• how team members should manage incidents
• the Group's role in supporting our contract partners.

Top 5 categories of spend

* Includes suppliers from Belgium, Canada, China, Finland, Germany, Ireland, Israel, Netherlands, Philippines, Singapore, Slovenia, Switzerland and UK in 2024.

2024 spend by operational area

The total spend includes Scentre Group's proportionate ownership and our joint venture partners' proportionate ownership. The spend reflects 100% of the outflows in relation

to the entire property portfolio of Westfield destinations.

Our direct supply chain includes a wide range of organisations and industry sectors. In 2024, 93 per cent of our total supplier spend in 2024 was paid to suppliers based in Australia.

Most of our supplier expenditure relates to the operation of our Westfield destinations, particularly cleaning services, security services and maintenance.

Our expenditure with suppliers in the design and construction categories is cyclical and depends on our development program and pipeline.

Our supply chain engagement

We are committed to high standards of ethical conduct and to promoting and supporting a culture of ethical behaviour and good corporate governance. This commitment extends to how we engage with our supply chain as part of our ordinary business practices.

We require our suppliers to abide by our Supplier Code of Conduct, Human Rights Policy and Supplier Grievance Management Policy. We operate under the Shopping Centre Council of Australia Code of Conduct for Fair Service Provisions and are a signatory to the Australian Supplier Payment Code.

Our Supplier Code of Conduct details our expectations of suppliers, including that they have safeguards to prevent instances of modern slavery occurring in their operations and supply chains, and that they comply with all applicable laws and regulations relating to human rights.

Higher-risk areas

Modern slavery risk assessments are embedded into our procurement processes. Our teams are asked to directly consider the risk of slavery in their supply chains as part of the annual review of team risk registers.

In 2024, our higher-risk areas remained labour hire services, including cleaning and security, and parts and materials sourced overseas (such as design and construction materials and technology).

The Group assesses its practices to address modern slavery risk, including for our higher risk labour hire services, in light of industry practice and other relevant external frameworks.

Risk indicators identified across our suppliers included:

• the use of foreign workers or temporary or unskilled labour by cleaning and security suppliers, delivery partners, and design and construction subcontractors
• the sourcing of construction materials, plant and equipment, and parts (which may include stone, glass, structural steel, HVAC, electrical and vertical transport) from countries outside Australia and New Zealand
• the sourcing of technology and technology components from countries outside Australia and New Zealand including digital screens, parking technology and solar panel technology
• software development, software service support and telecommunications providers with labour located in countries outside Australia and New Zealand
• the procurement of uniforms and other garments which may have been manufactured using cotton grown in countries outside Australia and New Zealand.

Further understanding our higher-risk areas

In addition to the steps the Group takes as part of its tendering, procurement, contract management and onboarding processes outlined below, suppliers who are identified as having a potentially higher risk for modern slavery and do not report under the Modern Slavery Act are surveyed using the Property Council of Australia's (PCA's) Informed 365 platform. This assesses risks present in supplier operations and supply chains, and identifies processes suppliers have in place to address their risk of modern slavery.

In 2024, 52 higher-risk suppliers were asked to complete a modern slavery risk assessment in the PCA's Informed 365 tool.

Of these suppliers, 81 per cent completed their 2024 survey and 22 suppliers had operations or direct manufacturing outside Australia and New Zealand. We continued to follow up suppliers who had incomplete 2024 survey responses, seeking to understand why responses were not provided in full, to assess potential risks and agree on follow-up actions. Opportunities for improvement identified through the survey

process include emphasising to suppliers how important completion of the survey is to Scentre Group, and improving our understanding of why suppliers are not completing the survey.

Tendering, procurement and contract management

Our contracting approach reflects how we operate as a responsible and sustainable business. Our tendering and procurement processes used in our higher-risk areas specifically address the risk of modern slavery in our supply chains.

Key aspects of our processes are set out below.

1. A pre-qualification form is completed

New suppliers complete this form prior to issue of tender. This includes modern slavery screening questions.

2. A tender is issued

A tender includes a requirement for suppliers to:

• comply with our Supplier Code of Conduct
• have a system in place to identify, assess and address the risk of modern slavery in their operations and supply chain.

3. Tender responses are received

Suppliers respond to screening questions about the risk of modern slavery in their operations and supply chains.

4. Responses are reviewed

Follow up actions are taken where the response is incomplete or indicates the supplier may be high-risk.

5. Contracts are entered into

Our standard form contracts require our suppliers to have a system in place to identify, assess and address the risk of modern slavery in their operations and supply chain. Monthly confirmations that workers are paid in accordance with applicable awards or enterprise bargaining arrangements are obtained from suppliers who provide these higher-risk services.

During 2024, we awarded 22 facilities management contracts across Australia and New Zealand. Of these, 11 were awarded to high-risk suppliers (cleaning and security services). 11 were awarded to lower-risk suppliers.

Onboarding and prequalification

All suppliers who provide services in our Westfield destinations are prequalified using Cm3 (an external supplier prequalification provider) and complete a modern slavery self-assessment questionnaire as part of our onboarding and prequalification process.

Supplier team members complete our induction process that covers work health and safety, emergency procedures, risk and hazard identification and our behavioural expectations.

For our higher-risk cleaning and security suppliers:

• We benchmark and assess pricing sustainability, and validate this against applicable awards or enterprise bargaining arrangements.
• Allowances are reviewed for suitability and whether they are fit for purpose, including to confirm provision for onboarding of new staff, leave loading, training, uniforms and equipment.
• Staffing charts are reviewed to confirm resourcing is adequate and workloads are safe and can be sustainably managed considering comparable centres and activities.
• Past performance is considered in relation to work health and safety, subcontracting arrangements and worker entitlements.

Ongoing engagement with our suppliers and their staff

Our site and centre management teams engage formally and informally with our suppliers and their team members. This engagement allows issues to be raised early and directly with us by workers.

Our people know and regularly engage with our suppliers and their team members, including through:

• face-to-facemeetings, including daily huddles, weekly team meetings, monthly contractor meetings, safety forums and emergency response training
• weekly safety walks and regular contractor audits on our construction sites
• weekly KPI inspections and quarterly supplier performance and KPI delivery meetings
• monthly work health and safety observations to confirm that work practices are carried out safely, with any non-compliance documented and tracked to resolution
• regular team talks that focus on areas such as lost time injuries and near-misses to gain feedback to improve our management and operational processes
• a dedicated contractor engagement program, where our team members meet directly with supplier team members on-site to discuss any concerns supplier team members may want to raise about their work conditions
• an annual review meeting where senior leaders from our cleaning and security providers outline their approach to modern slavery risk management including any issues or enhancements identified during the year.

We promote the avenues for supplier team members to raise grievances and the awareness of our supplier grievance management approach, through the information displayed in centre management offices and lunch rooms letting supplier team members know how they can raise any concerns about work practices or other grievances with Scentre Group directly.

Assessing risk

We partner and work with suppliers to continuously improve our approach to assessing and addressing modern slavery risks. How we do this depends upon the nature of the services being provided by our suppliers.

All centre suppliers completed a modern slavery self- assessment questionnaire through the supplier prequalification provider, Cm3. All contracts included clauses requiring suppliers to identify, assess and address modern slavery risks in their operation and supply chains.

Spot checks and audits

We conduct spot checks on matters relating to wages, employment and working conditions. This includes unscheduled checks after hours when we focus on cleaning and security supplier team members who work at times when our centres are closed and have less direct contact with our team members. On these occasions, we talk directly with supplier cleaning and security team members to discuss their feedback on a range of matters including pay, safety, training, workloads, equipment and personal protective equipment.

During 2024, we conducted 16 spot checks, including 12 which were unscheduled and conducted after hours. These checks identified the following opportunities for improvement:

• reviewing rostering to target operational requirements
• ensuring contractors had sufficient supply of uniforms, cleaning equipment and materials
• payment of award allowances including overtime.

Grievances

Our expectation is that our suppliers maintain their own grievance management mechanisms and that, where appropriate, an employee of a supplier engages first with the supplier's own grievance management process before raising a grievance with us. However, we recognise that this may not always be practical or realistic.

Our Supplier Grievance Management Policy sets out the principles we apply in managing concerns, issues or incidents raised by an employee of a supplier, or a supplier to a supplier, who believes they are the subject of unreasonable treatment by Scentre Group, its team members, contractors or suppliers, in or in connection with a Scentre Group workplace.

We recognise that the processes used to handle grievances need to be flexible in light of the circumstances in which a grievance may have arisen, and we will continue to refine our approach. At a minimum we:

• encourage speaking up
• respect confidentiality
• aim to be impartial
• believe that timely resolution is important.

All grievances raised with us in 2024 were investigated (with Scentre Group oversight where the investigation was undertaken by the employer). Recommendations were implemented depending on the outcome of the investigation and were tracked to resolution.