1. Introduction
This statement is published pursuant to section 14 of the Modern Slavery Act 2018 (Cth) on behalf of Australia By Saint Pty Ltd ACN 624 004 566 and its wholly owned subsidiary Life-Space Group Pty Ltd ACN 621 102 636, which in turn wholly owns Evolution Health Pty Ltd ACN 120 173 159, Ultra Mix (Aust) Pty Ltd ACN 067 526 596 and Divico Pty Ltd ACN 118 062 650 (collectively referred to as LSG, we, us or our). The purpose of this statement is to set out our approach to ensure that LSG has frameworks and processes in place to minimise the risks of modern slavery in our business operations and supply chain.
This statement sets out the steps that LSG has taken during the 12 month period ending 31 December 2020 to prevent slavery in our supply chain or any part of our business.
2. Our structure, operations and business
Life-Space Group Pty Ltd comprises Evolution Health Pty Ltd, which is responsible for domestic and international sales and Ultra Mix (Aust) Pty Ltd which is our manufacturing arm. The Life-Space Group Pty Ltd is wholly owned by Australia By Saint Pty Ltd, an Australian company which in turn is a wholly owned subsidiary of By-Health Co Ltd, a company listed on the Shenzhen Stock Exchange.
Neither Australia By Saint Pty Ltd nor Life-Space Group Pty Ltd is a trading entity in Australia. Neither of them acquires any goods or services nor enter into contractual relationships with external stakeholders with the exception of Australia By Saint Pty Ltd which engages professional taxation and accounting services for its reporting requirements.
We supply a range of complementary medicines and foods for sale in Australia, China and around the world. Our brands include Life-Space, Premedy, Elmore Oil and Coram’s.
Our supply chain mainly comprises procurement of raw materials, engagement of contract manufacturers for both turnkey and tolled operations and labour hire arrangements from a manufacturing perspective. Other services acquired include marketing, professional services and office consumables.
3. Policies and Governance Approach
We have a Workplace Discrimination and Harassment Policy and a Grievance and Dispute Policy which apply to all employees, volunteers and stakeholders which
enforce LSG’s commitment to providing a safe, flexible and respectful environment for our team members and external stakeholders.
All LSG team members are required to treat others with dignity, courtesy and respect. Between the two policies, the rights and responsibilities of all employees, volunteers and stakeholders with clearly set out with procedures in place for the handling complaints and grievances in an efficient, fair and just manner.
In FY2020, LSG developed a Code of Conduct, yet to be finalised, with the aim of formally fostering a culture in which employees, customers and suppliers are treated with dignity, respect and fairness. LSG fully endorses that all employees are not deprived of their basic human rights. Our Code of Conduct applies to all employees and provides the framework of principles for conducting business, dealing with other employees, clients and suppliers.
We have also developed a LSG Ethical Sourcing Policy requiring all suppliers to fully comply with all local laws and regulations regarding labour, health, safety and the environment. They are also required to fully comply with the legal requirements of the countries in which they operate in addition to all elements set out in the LSG Ethical Sourcing Policy. This policy forms part of our Anti Slavery provision which we insert into our procurement contracts.
All contracts with third parties that are governed by Australian law must go through an internal approval process to be vetted by the CEO, legal department before the same are signed off. Contracts governed by PRC law involving LSG are approved through the By Health Co Ltd’s approval process (LSG’s ultimate holding company).
4. LSG supply chains and risks of modern slavery
Our supply chain mainly comprises procurement of raw materials, engagement of contract manufacturers for both turnkey and tolled operations and labour hire arrangements from a manufacturing perspective. Other services acquired include marketing, professional services and office consumables.
5. Actions taken to assess and address modern slavery risks
Our contract manufacturers are mainly Australian companies which undertake their manufacturing processes in Australia where the risks of modern slavery is considered low. Labour hire, where required, are sourced from labour hire companies which hold a Labour Hire Licence under the Labour Hire Licensing Act 2018 (Vic).
In FY2020, Evolution Health Pty Ltd and Ultra Mix (Aust) Pty Ltd introduced an Anti Slavery provision into their procurement contracts which includes a requirement that suppliers comply with our Ethical Sourcing Policy, which may be amended from time to time. Where suppliers have their own responsible sourcing policy, are governed by their own professional standards or have aligned their commitment to
respecting human rights for their team members with the principles and guidance such as those contained in the United Nations Guiding Principles on Business and Human Rights, we have not insisted on the insertion of an Anti Slavery provision in their contracts.
Our Ethical Sourcing Policy makes specific reference to matters including but not limited to:
The prohibition of forced/bonded labour/child labour and illegal labour;
All employees must be treated with respect and dignity;
All employees must be engaged on a recognised employment relationship;
All applicable laws with respect to working conditions, health and safety, working hours, employee wages, benefits, freedom of association must be adhered to;
No discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political
Where suppliers are not prepared to abide by our Ethical Sourcing Policy, we have devised a Self Assessment Questionnaire which we require our suppliers to complete for our consideration prior to committing to the relevant contracts.
6. Assessing the effectively of the actions taken
We will undertake continuous and ongoing assessment of our supply chains by evaluating information that we receive from suppliers and to promptly act on any allegations or findings of involvement in prohibited practices.
7. Consultation with controlled entities
As one of the directors of Australia By Saint Pty Ltd and Life-Space Group Pty Ltd is also the sole director and sole secretary of each of Evolution Health Pty Ltd, Divico Pty Ltd and Ultra Mix (Aust) Pty Ltd, the boards of Australia By Saint Pty Ltd and Life- Space Group are aware of the day to day operations of its subsidiaries with full transparency within the group.
8. Looking forward
Over the next reporting period, we will continue to assess ways to reduce the risks of modern slavery and some steps will include:
Publishing LSG Ethical Sourcing Code;
Finalising our Code of Conduct to enshrine LSG’s values to ensure that all employees are clear on expected behaviours within LSG; and
Looking at formulating a Business and Human Rights Statement in line with the UN’s Guiding Principles on Business and Human
This statement is approved by the governing body of Evolution Health Pty Ltd, Life Space Group Pty Ltd, Ultra Mix (Aust) Pty Ltd and Divico Pty Ltd, being the board of directors of Australia By Saint Pty Ltd.
Signed: Fantine Wu
Position: Director of Australia By Saint Pty Ltd
Date: 09 June 2021
