What is Ego's Reporting Entity, for the purpose of Australia's Modern Slavery Act 2018 (Commonwealth)?
Ego Pharmaceuticals Pty Ltd, 21 - 31 Malcolm Road, Braeside VIC 3195, Australia. ABN 86 005 142 361

Describe Ego's ownership and company structure.
Ego Pharmaceuticals Pty Ltd is a privately owned Australian company with subsidiaries in the UK, Malaysia, Taiwan, Singapore, Hong Kong, Malta and the United Arab Emirates, as well as representative offices in Saudi Arabia and Indonesia.

How long has Ego been in operation?
Ego was established in 1953.

What entities are controlled by or associated with Ego?
These entities are:

• Ego Pharmaceuticals Pty Ltd
• Ego Pharmaceuticals UK Limited
• Ego Pharm Malaysia Sdn Bhd
• Ego Pharmaceuticals Taiwan Pty Ltd
• Ego Pharmaceuticals Singapore Pte Ltd
• Ego Pharmaceuticals Hong Kong Limited
• Ego Pharmaceuticals Europe Ltd
• Ego Pharm Marketing Management LLC (in the UAE)

In which industry sector does Ego operate?
Health care and pharmaceuticals. Ego has led the way in the development, manufacture and marketing of innovative skin care products.

Where does Ego manufacture its products?
Ego develops and manufactures innovative skin care products at its own site in Braeside, Victoria, Australia. There are currently plans for the next phase of production for Ego - a new manufacturing facility at the Global Support Centre in Dandenong South, Victoria, Australia.

Which brands does Ego produce?
Ego produces well-known and trusted brands such as QV®, Aqium®, SUNSENSE®, MOOV®, DermAid®, Egoderm®, Elucent®, Numit®, Pinetarsol®, Resolve®, Sebitar®, SolvEasy®, SOOV® and Zatamil®.

Does Ego have a Board of Directors?
A board oversees the strategic direction of Ego, and includes its Managing Director, Alan Oppenheim and Scientific and Operations Director, Dr Jane Oppenheim, as well as independent non-executive directors.

How many people does Ego employ within Australia?
Within Australia, Ego has approximately 500 people across engineering, sciences, production, quality, people and performance, logistics, research and development, regulatory affairs, finance, ICT, legal, marketing and sales.

How many people does Ego employ outside of Australia?
Outside Australia, Ego has approximately 200 people in the Middle East, UK and Asia, in the areas of marketing, sales, finance and regulatory affairs.

Does Ego use casual or contract workers?
Ego has a small number of casual staff to supplement the permanent workforce.  These casual staff receive their full wage and condition entitlements and often go on to become permanent employees.

Does Ego produce a Modern Slavery Statement in Australia?
Ego is subject to the reporting requirements of the Commonwealth Modern Slavery Act 2018 and has produced a Modern Slavery Statement every year since the commencement of the Act. View Ego's most recent statement here.

Does Ego produce a Modern Slavery Statement in any other jurisdictions?
Ego is not currently required to produce a Modern Slavery statement in any other jurisdictions.

How does Ego comply with the requirements of the Australian Modern Slavery Act?
Ego has zero tolerance for any form of Modern Slavery and slavery-like practices.  Ego has established a number of governance practices to provide the necessary Board oversight of the implementation and subsequent phases of Modern Slavery compliance, as the identified approach and resources are embedded into the company's broader compliance requirements.
A Modern Slavery committee, headed by Alan Oppenheim (Managing Director) and Dr Jane Oppenheim (Scientific and Operations Director), oversees the ongoing activities around Modern Slavery compliance at Ego.
Ego's Business Partner Code of Conduct Policy sets out the standards by which the company operates.  This policy applies to Ego and its entities.  The key points of the policy are:

• Ego is a participant in the United Nations Global Compact, the world's largest corporate sustainability initiative.
• Ego supports the United Nations Universal Declaration of Human Rights and the International Labour Organisation Declaration on Fundamental Principles and Rights at Work.
• Ego does not employ children under the legal employment age in any country or local jurisdiction.
• Ego does not use any form of forced, bonded or involuntary labour.  Workers retain control of their identification documents and do not pay any fee connected to obtaining employment throughout the hiring process and the employment period.  Punishment and coercion are prohibited and all disciplinary policies are fair, clearly defined and openly communicated to workers.
• Ego complies with all applicable laws and industry standards regarding working hours, overtime, wages and benefits.  Ego pays workers in a timely manner.  Deductions from wages as a disciplinary measure are not allowed unless legally permitted.
• Ego employees and contract workers are free to leave employment on reasonable notice.

What is the risk of Modern Slavery within Ego and its entities?
From an Australian perspective, Ego is subject to some of the strictest employment laws anywhere in the world and follows all applicable laws and awards.  The risk of Modern Slavery within Ego is rated as very low.  The organisation has audited its international operations and their supply chains via desk audits and due diligence exercises, as well as on a combination of geographical and sector data; the likelihood of Modern Slavery is assessed as low.

What sort of training and awareness does Ego have to educate its staff on Modern Slavery?
There is a range of approaches to ensure that staff have a good understanding and awareness of Modern Slavery and how it impacts their roles and responsibilities.  These include:

• Formal training via an external training package - this has been delivered to key staff globally who interact with suppliers and who need to have a deeper knowledge of Modern Slavery and its implications for Ego - these include board members and executives, senior managers and staff in supply, procurement, finance, sales, logistics and packaging / sustainability
  
• Training in the Business Partner Code of Conduct Policy
• Publishing content in the company staff newsletter, the EgoGram
• Seminars and strategy meetings, both locally and internationally
• In house training for onboarding new staff, including a specific module on Modern Slavery
• Participation in external seminars and webinars

Is Ego audited or assessed by any third-party organisation such as Sedex or EcoVadis? 
No, Ego does not outsource these activities.

How much visibility does Ego have over its supply chain?
The supply chain of Ego has been mapped.  There are four segments of the supply chain where goods and services are sourced:

• Direct inputs - ingredients and packaging
• Production support - buildings, equipment, utilities, spare parts, laboratory supplies, laundry, training, warehousing, logistics, maintenance, contracts laboratory services, labour hire and waste management
• Marketing and sales - point-of-sale materials, marketing and advertising, repacking services, conference, travel, car fleet and sponsorships
• General support - office supplies, consumables, consultancy (legal, accounting, architecture, compliance), insurance, banking, regulatory, ICT, office rental, cleaning, recruiting, medical and government (regulatory approval, duties and taxes)

What controls does Ego have in place to mitigate exposure to Modern Slavery in its supply chain?
Ego has conducted due diligence on all ingredient and packaging suppliers, and on all other suppliers of goods and services in Australia and globally (excluding very small suppliers).
Ego has also implemented specific terms and conditions relating to Modern Slavery into purchase order terms and conditions and agreements.  These terms and conditions encompass child labour, forced labour, health and safety, discrimination, abuse, disciplinary practices, remuneration, employment conditions and freedom of association.
Due diligence relating to Modern Slavery is also part of the supplier onboarding process.

What are the main countries from which Ego sources materials?
The main countries for ingredients and packaging materials are Australia, USA, Germany, Italy, China, Singapore, Mexico, Hong Kong, Taiwan, India, Spain, Malaysia, Singapore, France and Thailand.

What is the risk of Modern Slavery within Ego's international supply chain?
Ego has rated the risk of Modern Slavery within its international supply chain as low.

How often does Ego intend to repeat its assessment of the risk of Modern Slavery within its supply chain?
Ego is committed to a rolling cycle of due diligence exercises, combined with risk analysis by geography and sector.  Ego also monitors and responds to particular industry and sector risks, as they emerge.

Does Ego ensure that prospective employees enter voluntarily into employment contracts?
Yes, this is part of the recruiting processes.

Are employees provided with a written employment contract, where terms of employment including wages and hours of work are clear?
Yes, this is part of the recruiting processes.

What steps are taken to ensure that contracts are available in a language that workers understand?
Employment contracts are in a language that the employee understands.  In some countries, legislation requires that the contracts are in dual languages.

Does Ego have processes to ensure that employees are legally permitted to work?
Yes, this is part of the recruiting processes.

Does Ego use forced labour in its business operations?
No.

Are Ego's employees free to lawfully resign their employment without restriction or penalty?
Yes.

Does Ego permit unions to operate and / or provide alternative means of employee representation?
Yes, Ego has positive and constructive relations with employees and the relevant union and does not attempt to influence employees to join or not join a union.  There is a high rate of employee engagement based on employee engagement surveys, which are conducted by a third party.

Does Ego negotiate with a lawfully recognised union?
Yes, within the required mechanisms.

Are Ego employees given clear information regarding changes to working conditions?
Yes, Ego has a robust consultation process.

Does Ego use child labour in its operations?
No.  While Ego does provide work experience for students under the appropriate conditions, the company does not use young employees below the minimum age set by legislation.

How does Ego ensure that employees' working hours are in line with normal industry standards as well as appropriate awards?
All employees' working hours are within the legal maximum and overtime is voluntary.  Ego understands that staff are at their best when they have enough time for family, rest and recreation.

How does Ego ensure that employees are paid appropriately?
Ego has links to relevant industry information and sources that provide timely updates to changes in laws and wages details.

How does Ego provide a healthy and safe work environment for its employees and contractors?
Ego is committed to maintaining a safe and healthy work environment for all people.  This committment is detailed in the Global Health and Safety Policy, which outlines goals, roles and responsibilities - including the provision of a mentally healthy workplace.  Ego has a comprehensive health and safety management system, based on ISO:45001, supported by trained and dedicated health and safety professionals.  This system ensures effective consultation with all relevant stakeholders and ensures compliance with local laws and promotes continual improvement.  Health and safety training is provided to all of Ego's people, and all visitors, contractors, and employees undergo an induction process and know how to report and raise any concerns. 

How does Ego manage the risk of harassment or bullying in the workplace?
Ego has a Workplace Behaviour policy and procedure for managing these risks and understands that good mental health is also a work health and safety matter.  The procedure covers unlawful discrimination, bullying, harassment, sexual harassment, vilification, occupational violence and victimisation.  Staff are trained in this procedure.  Ego recognises that every employee, contractor, visitor and volunteer has the right to work in an environment where they feel safe both physically and mentally.

Are Ego's employees, directors, officers, suppliers, supply chain members, contractors, third parties or the public able to report suspected instances of Modern Slavery?
Yes.  Apart from direct interaction with suppliers via the due diligence audit program, there are other supporting mechanisms to facilitate the reporting of suspected instances of Modern Slavery, including the Grievance Procedure and Whistleblower Policy.

How would Ego respond to an allegation of Modern Slavery in its supply chain?
Where a risk was identified, Ego would launch an internal investigation to understand the scope and validity of the allegation.  This might include site visits, interviews and documentation reviews.

What would Ego do if it found a breach in the above?
Ego would initiate identifying alternate sources of supply.

Does Ego encourage employees to do business honestly and ethically?
This is an important part of the Ego Values.  A commitment to these Values forms part of each employee's Employment Contract.  The organisation celebrates staff who demonstrate the Ego Values in their work on a daily basis.  All Ego employees are expected to comply with the Business Partner Code of Conduct Policy, which deals with bribery and corruption, trade regulation, money laundering and financial records, fair competition and conflicts of interest.  Ego has delivered training on Anti-Bribery and Anti-Corruption, including improper use of company funds, use of bribery or incentives, recording of financial transactions, reporting of gifts and conflicts of interest.

What is Ego's policy on diversity and employment of minority groups?  Does Ego take steps to ensure fair representation of women and minority groups in management and in the workforce overall?
Ego is an Equal Opportunity employer and complies with the following Australian legislation with regard to selection and recruitment - Fair Work Act, Equal Opportunity Act, Sex Discrimination Act, Racial Discrimination Act, Workplace Gender Equality Act and Privacy Act - as well as applicable legislation outside of Australia.  Ego values the diversity of its people and forbids discrimination regarding any protected attribute.

Does any part of Ego's business operations adversely impact on rights and interests of Indigenous people or the cultural heritage of Indigenous people?
No, this is contrary to Ego's Values.  Ego actively supports the indigenous Numbulwar community in Australia's Northern Territory with financial and material aid.

Does Ego make provision for the proper observance of religious festivals and prayer?
A space / time is made available for religious observance when requested.

What is Ego's commitment to the environment and sustainability?
To learn more about Ego's commitment to the environment and sustainability, click here.

Is Ego active in the community in the areas of health and education?
Ego actively participates in many local, state-based and national community events to promote health and education, as well as to benefit the community more broadly.  These events include:

• Eczema Awareness Month (in collaboration with the Eczema Association Australasia) to help bring awareness to the skin condition and how debilitating it can be
• The Eastern Health Nursing Sponsorship
• The QV Healthcare Practitioner Student Scholarship, supporting the next generation of healthcare practitioners
• The Australian Dermatology Nurses Association Fellowship Award, which sponsors a dermatology nurse each year to further their development
• Good360 Partnership, which matches charities, schools and community groups with businesses who donate surplus goods to people in need and reduce waste
• Donations to bushfire appeals
• Donations of products to organisations such as Food Bank
• A collaboration with the Numbulwar Community to raise funds and provide goods for disadvantaged Indigenous Australians in the Northern Territory
• Clean Up Australia Day - where Ego employees spend half a day each year removing rubbish from local bushland
• Ego is working with the local Kingston Council to assist in providing education to local businesses

Does Ego have a certified Quality Management System in place?
Yes - Ego complies with the PIC/S Guide to Good Manufacturing Practice for Medicinal Products PE009-14.  Good Manufacturing Practice (GMP) is a set of principles and procedures that when followed helps ensure that therapeutic goods are of a high quality.  PIC/S is the Pharmaceutical Inspection Co-operation Scheme, which aims to develop, implement and maintain harmonised GMP standards and quality systems of inspectorates in medicinal products across multiple nations.

Does Ego have a Licence to Manufacture Therapeutic Goods in Australia?
Yes - Ego is licensed by the Australian Government's Therapeutic Goods Administration, which oversees compliance with the manufacture of therapeutic goods in Australia.  Ego holds TGA Licence Number MI-04032005-LI-000458-2.

Does Ego have a policy or code of conduct covering Modern Slavery?
Yes - the Business Partner Code of Conduct Policy covers all aspects of Modern Slavery, which Ego, its employees and business partners are expected to comply with.

Does Ego have a policy on Ethical Sourcing?
Yes - the Business Partner Code of Conduct Policy sets out Ego's policy on Ethical Sourcing; in addition, the supplier onboarding process and ongoing due diligence audits ensure that this remains a focus for suppliers to Ego.  The Equipment Purchasing Policy specifically includes consideration of potential for Modern Slavery in the country of origin of the equipment, as well as of sourcing of components from regions with exploitative practices.

Does Ego have a policy on Health and Safety?
Yes - the Health and Safety Policy (Global) details Ego's commitment to providing a safe and healthy working environment in accordance with relevant legislative guidance and with ISO:45001 Occupational Health and Safety Systems.

Does Ego have a policy on Anti-Bribery and Anti-Corruption?
Yes - the Business Partner Code of Conduct Policy includes Ego's expectations regarding bribery and corruption, trade regulation, money laundering, financial records, fair competition and conflicts of interest.

Does Ego have a policy on Environmental Sustainability?
Yes - the Environmental Management Policy sets out Ego's commitment to environmental sustainability and the Sustainability Plan further supports this policy, detailing how Ego plans to achieve goals that create financial, societal and environmental improvements within the company.

Does Ego have a policy on Workplace Behaviour?
Yes - the Workplace Behaviour Policy describes Ego's commitment to providing a safe and friendly workplace, free from bullying, unlawful discrimination, harassment, sexual harassment, vilification, occupational violence and victimisation.  This is supplemented by the Workplace Behaviour Procedure, which details how to deal with instances of inappropriate workplace behaviour.

Does Ego have a Whistleblower policy?
Yes - the Whistleblower Policy explains how to raise concerns of wrongdoing and details the associated protections and support for whistleblowers.

Does Ego have a Grievance procedure?
Yes - the Grievance Procedure outlines the internal dispute resolution process for an employee to have a grievance addressed.

Which relevant organisations is Ego a member of?
Ego is a participant in the United Nations Global Compact (UNGC).  The UNGC aims to align company strategies to focus on the Ten Principles that sit within Human Rights, Labour, Environment and Anti-Corruption.  Ego is also a member of the United Nations Global Compact Network Australia (UNGCNA).
Ego has been a voluntary member of the Australian Packaging Covenant (APC) since 2010, and before that, the National Packaging Covenant (NPC).  Ego is also a signatory to the Australian Packaging Covenant Organisation (APCO).
Ego is a member of the ANZPAC Plastics Pact, a collaboration between Australia, New Zealand and the Pacific Islands working towards a circular economy for plastic, where plastic never becomes waste or pollution.
Ego undertakes various programs with the Australian Industry Group (AIGroup), such as the AIGroup Energy Efficiency program to connect with peers in industry and optimise efforts in the area of sustainability.
Ego is a member of Consumer Healthcare Products Australia, which requires compliance with the CHPA Code of Conduct.