Bendigo and Adelaide Bank : 2022 Modern Slavery Statement

BENDIGO AND ADELAIDE BANK

Modern

Slavery Statement 2022

This Modern Slavery Statement (Statement) has been prepared in accordance with the Australian Modern Slavery Act 2018 (Cth) (the Act) on behalf of Bendigo and Adelaide Bank Limited (ABN 11 068 049 178) (the reporting entity) and the entities it owns or controls (the Group). The Statement does not apply to the Group's joint ventures.

Bendigo and Adelaide Bank Limited is the parent company of the Bendigo and Adelaide Bank Group. The principal activities of the Group were the provision of banking and other financial services including lending, deposit taking, leasing finance, superannuation and funds management, insurance, treasury, foreign exchange services (including trade finance) and trustee services.

The Statement sets out the actions taken by the Group during the year ended 30 June 2022 to assess and address the risks of modern slavery in its operations and supply chains.

References to 'modern slavery' are as defined in the Act.

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Contents

Message from our Managing Director	4
Our business structure, operations and supply chain	5
In our operations	9
Financial products and services	9
Lending and investment	9
Employment	9
Community investment	9
In our supply chain	10
Procurement	10
Our approach to addressing modern slavery risks	10
In our operations	10
Financial products and services	10
Lending and investment	11
Employment	13
Community investment	14
In our supply chain	15
Procurement	15
Modern slavery governance	17
Training and awareness building	17
Grievance mechanisms and remediation	18
Engagement and advocacy	19
Assessing the effectiveness of our approach	19
Consultation with Group entities	20
Our ongoing commitment and future focus	21

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Message from our

Managing Director

Modern slavery is a complex global humanitarian issue that can only be tackled collectively and collaboratively by businesses, not for profit organisations, and governments. At Bendigo and Adelaide Bank, we are committed to playing our part.

As Australia's most trusted bank, we recognise we have a responsibility to respect human rights and to proactively seek out ways to make a positive impact through our operations and supply chain.

Given the nature of our operations, financial institutions can become unwitting participants to modern slavery. The financial sector's integration with the rest of the economy and its connection with every industry means it has an influential role in driving the global economy to address modern slavery and protect human rights.

For this reason, we support a unified approach where businesses, not for profit organisations and governments work together to address the serious impacts of modern slavery on communities across the globe.

While the past year has seen the return of uncertain economic conditions, it has also seen our Bank continue to build on creating policies and procedures to ensure we are doing our part to tackle modern slavery.

We have been working hard to further develop our understanding and management of key risks associated with modern slavery, along with embedding a clear process to identify and report scenarios where modern slavery may be prevalent. This work has helped inform our first Modern Slavery Roadmap.

The development of our Modern Slavery Roadmap has enabled the Bank to set out key actions to continuously improve our approach to identifying, mitigating, and addressing modern slavery risks across the Bank's operations, products, and services.

In addition to the roadmap, Bendigo and Adelaide Bank will progress the development of our Human Rights Position Statement which will set out

our commitment to protecting and respecting human rights and remedying any violations. We

look forward to sharing this Statement with our stakeholders in the 2023 financial year.

We have also advanced how the Bank deals with suppliers, developing a Supplier Code of Conduct which sets out our values and the minimum requirements expected of our suppliers.

We are Australia's most trusted bank, and we remain focussed on our purpose of feeding into the prosperity of the community, and not off it. While this past year has seen continuous improvement in the Bank's efforts to identify and report instances of modern slavery, we know there is more work to be done and I look forward to building on our progress in the 2023 financial year.

Marnie Baker

Managing Director

FY22 key highlights

• Developed a Modern Slavery Roadmap
• Progressed the development of our Human Rights Position Statement
• Developed a Supplier Code of Conduct
• Incorporated modern slavery provisions into supplier contracts
• Implemented a third-party modern slavery risk monitoring platform to help detect the presence of modern slavery in our supply chain
• Commenced developing our approach to modern slavery risks for our employment and community investment activities
• Implemented actions to uplift our understanding and management of modern slavery risks in our agricultural lending activities

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Our business structure, operations and supply chain

OUR STRUCTURE AND ENTITIES

For more than 160 years, we have actively listened and responded to the needs of our customers and their communities. Over this period, more than 80 different organisations have come together to become the bank we are today - an Australian owned, top 100 ASX listed company, with more than 95,000 shareholders.

Bendigo and Adelaide Bank Limited is the parent company of the Bendigo and Adelaide Bank Group. All Group subsidiaries are wholly owned, operate under the direction and governance of Bendigo and Adelaide Bank Limited and all share the same executive management.

We are one of Australia's biggest banks, with around 7,000 employees helping over 2.2 million customers achieve their financial goals. Our operations also include indirect workers including contractors and sub-contractors that support our business with labour or the provision of services.

Our vision is to be Australia's bank of choice, and we believe our success is driven by our purpose - to feed into the prosperity of our customers and communities, not off it.

Through our portfolio of brands, our principal activities are the provision of banking and other financial services including lending, deposit taking, leasing finance, superannuation and funds management, insurance, treasury, foreign exchange services (including trade finance), and trustee services.

Our reach comprises a national network of proprietary and Community Bank owned branches, joint ventures, partner distribution networks, wealth release products for senior Australians, and a network of mutual financial institutions to release capital and service members.

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