Modern Slavery Statement Retirement Living

Modern slavery risks in operations, supply chains and controlled subsidiaries In the course of its operations, LLRL Trust is able to draw on the systems and processes of the Lendlease Group’s modern slavery risk supplier assessment and mitigation measures in operations. Refer to section 3 of the Lendlease Group Modern Slavery Statement for further details. There are however some modern slavery risk issues specific to the Retirement Living sector, shown in the following graphic and outlined below. Indirect labour (Supply Chain) / casual workforce is a key modern slavery risk for LLRL Trust through the: • Engagement of small construction contractors • Exposure to small contractors or sole traders with informal enterprise or labour arrangements for maintenance and capital upgrades • Production of materials and consumables sourced for construction and operation of retirement village sites • Provision of cleaning, security, care and hospitality services through labour hire providers The following diagram identifies key areas vulnerable to modern slavery risks. Modern SlaveryRisks –Retirement LivingTrust Construction Smaller scaled construction contractors may experience higher volaility in work pipeline and may lack sufficient resources/capability to screen for sub- contractors operating informal enterprises. Village Operations Facility management services for village operations engage in highly competitive markets for outsourced agreements in cleaning, reactive maintenance, landscaping, hospitality and security services, with contractors using low skilled and casual labour. Capital Upgrades In regions experiencing a shortage of skilled local labour, labour may be recruited by sub-contractors through labour hire, or risk engaging contractors operating with informal labour agreements. Materials & Consumables Lack of visibility in multi-tiered manufacturing supply chains for construction materials and village consumables eg plumbing, electrical, mechanical components, masonry/ tiles, sanitary ware, raw materials, soft furnishings/ textiles, marketing merchandising, PPE, uniforms, stationery, catering. Indirect Labour The Australian construction sector has experienced longstanding demand for low-skilled, manual, often migrant labour. It has been recognised, the indirect use of site labour utilising low skilled manual work recruited for sub-contractors through labour hire agencies, is an area requiring greater transparency. This is particularly relevant within Retirement Living as opposed to other areas like office or apartments, given the more likely use of tier 2 builders for some smaller projects. Intense industry competition, tight cashflow and profit margins experienced by smaller, localised contractors may render workers (particularly casual workers) vulnerable to accepting informal work arrangements in terms of pay and conditions, which may not meet the minimum legal requirements. There may also be limited resources and capacity for those small businesses in turn to appropriately risk assess for modern slavery risks across their own supply chain. The aspects of the retirement living services often involves sourcing temporary labour from labour hire providers. For retirement village operations, soft and hard services such as cleaning, catering, property maintenance and security, exist in a price competitive low-margin market, sometimes relying on low-skilled migrant labour for viability. This creates preconditions for vulnerable workers to be exposed to a range of labour exploitation practices, including wage theft, underpayment, and unpaid entitlements. In light of some of the supply chain and operational challenges across this sector, LLRL Trust has identified a number of Modern Slavery Risk mitigation strategies and actions, which are outlined the next section below (Section 4). In addition, LLRL Trust has recently introduced Payments on Time reporting, where we have made available information to village managers of all invoices and their payment dates, to ensure all small suppliers are paid in a timely manner. APPF Commercia l Modern Slavery Statement 11 10