2025 ESG Commitments and Initiatives

Hacer ESG Statements

We acknowledge the Traditional Owners of Country where we build, and their continuing connection to land, sea, and community.

We pay our respects to all Aboriginal and Torres Strait Islander peoples, their cultures and their Elders past, present and emerging.

EHSQ Systems & Certifications

ESG Commitments & Initiatives

Hacer acknowledges that as a business it has a crucial role in creating more sustainable communities, alongside its clients and partners, through resource efficient and climate conscious design & construction.

Our approach to sustainability is summarised below.

Sustainability Framework – “We Build Sustainably” As one of our core values, we work to make sustainability business as usual.

Our Sustainability Framework sets the stage for how we integrate sustainability into Our Operations, Our People, and Our Projects.

EHSQ Systems & Certifications

ESG Commitments & Initiatives

Our Operations Good Governance Our Values guide everything we do - from how we run our business day to day, to how we grow and develop our people, to how we drive positive outcomes in our value chain.

We ensure

We build

We openly

safety is paramount

and commit to

communicate and develop

everywhere.

highest quality standards.

respectful, trustworthy teams.

We work

We follow

We build

to make sustainability

through on our responsibilities

close relationships with our people,

business as usual.

and commitments.

clients and the industry.

Our values are supported by key internal policies including our: •

Code of Conduct

•

Whistleblower Policy

•

Safety Policy

•

Anti-Discrimination & Equal Employment Opportunity Policy

•

Harassment & Bullying Policy

•

Workplace Diversity Policy

•

Sustainability Policy

•

Modern Slavery Policy

•

Environmental Policy

•

Quality Management Policy

These policies are reviewed and updated on a regular basis to reflect changes in our standards, expectations, and regulations.

EHSQ Systems & Certifications

ESG Commitments & Initiatives

Our Accreditations We are committed to Safety, Quality and Environmental responsibility in everything we do.

The Hacer EHSQ Management System is ISO 14001, ISO 45001, and ISO 9001 accredited.

Responsible Procurement & Supply Chains Hacer recognises that our operations can have a direct and indirect impact on people and the environment, and that we have a responsibility to avoid causing or contributing to modern slavery and environmental degradation.

Upholding this responsibility means collaborating with our stakeholders across our value chain.

We are creating change throughout our business to focus on and address modern slavery risks, and to improve transparency across our direct and indirect supply chains.

We have adopted Informed360 as the primary means of assessing and managing modern slavery risks . The platform, developed by the Property Council of Australia (PCA) in collaboration with 17 of the largest property companies in Australia (collectively known as the Consortium) provides a digital means of collecting and collating supplier and subcontractor data relating to their modern slavery exposure in operations and supply chains. It has also allowed us to collaborate with experts and stay up to date on the latest developments on modern slavery risks and risk remediation strategies.

Hacer recognises that ending modern slavery and improving environmental outcomes will not occur overnight. We are therefore committed to long-term continuous improvement in our operations.

Hacer is a reporting entity for the purposes of the Modern Slavery Act 2018. Accordingly, copies of our Modern Slavery Policy and our most recent Modern Slavery Statement are attached.

Climate Mitigation & Adaptation In 2021, Hacer undertook a LowCO2 audit with the Carbon Reduction Institute to determine our carbon footprint and set our emissions baseline. Building on this audit, we are developing an Emissions & Resources Inventory and associated processes, that will help us to identify and reduce emission and resource use across our operations.

We are also exploring the impacts of climate change to the building and construction industry – this will further help us refine our emission and resource use reduction initiatives.

EHSQ Systems & Certifications

ESG Commitments & Initiatives

Our Culture Reconciliation In 2023, Hacer officially commenced our reconciliation journey with a formal endorsement by Reconciliation Australia, of our inaugural Reflect Reconciliation Action Plan (Reflect RAP).

The Reflect RAP helps us set strong foundations for meaningful long-term engagement and reconciliation with Aboriginal and Torres Strait Islander Peoples across 4 dimensions – Relationships, Respect, Opportunities, Governance.

Our RAP working group has increased our teams’ understanding and appreciation of Aboriginal and Torres Strait Islander cultures and heritage, through cultural awareness training and engagement in National Reconciliation and NAIDOC week activities, among other initiatives.

We are also exploring opportunities to engage with Aboriginal and Torres Strait Islander businesses in our supply chain with the support of Kinaway.

A copy of our Reflect RAP is attached.

Diversity, Inclusion & Belonging Hacer is committed to providing all employees with a workplace culture that builds respect, fosters inclusiveness, promotes diversity, and embraces the unique skills and qualities of all our employees.

Our aim is to manage workplace diversity by recognising and embracing the diversity each employee brings to our workplace; and creating an environment built on trust, mutual respect and appreciation.

Setting these foundations enables us to fully benefit from the significant skills and talent that exists within our workforce.

To challenge the male stereotype and support women in the construction industry, we introduced a female specific scholarship with RMIT in 2019. The scholarship guarantees a female undergraduate a place in the Hacer Graduate Programme as well as $7,000 towards their study.

Additionally, Hacer has received organisational compliance with the Workplace Gender Equality Act 2012 year on year since reporting commenced in 2019.

A copy of our Workplace Diversity Policy and Gender Pay Gap Statement are attached.

EHSQ Systems & Certifications

ESG Commitments & Initiatives

Safety & Wellbeing Hacer understands the importance of focusing on both physical and psychosocial safety. By taking reasonably practicable steps to identify, assess and effectively control risks within our workplace, we are providing an environment that is safe, productive and engaged.

The Hacer EHSQ Management system ensures our policies, procedures and systems are regularly audited, maintaining and upholding our high standards.

All our teams have access to our Employee Assistance Program (EAP) provided through Acacia EAP. We also offer first aid and mental health first aid courses for our teams.

Social Impact At Hacer we want to play our part in supporting the communities in which we live, work and play. Every year we fundraise, volunteer and support our communities with financial and in-kind support.

Some of the ongoing initiatives include: •

Run4theKids

•

Australia’s Largest Morning Tea – Cancer council

•

FareShare Volunteer Kitchen

•

Good Friday Appeal

•

Salvation Army Christmas Appeal

In 2021, Hacer completed a pro bono project in Iramoo dedicated to young people experiencing homelessness.

A purpose-built facility was constructed to accommodate infants and families to give young people aged 15-25 a chance to grow into adult independence with a level of support they did not otherwise have. We were proud to collaborate with Melbourne City Mission and Property Industry Foundation.

EHSQ Systems & Certifications

ESG Commitments & Initiatives

Our Projects Hacer is collaborating with clients and partners, to embed sustainability considerations into our projects.

Building design and materials selections are one of the biggest ways to reduce and eliminate carbon from buildings.

By leveraging our experience with Green Star projects we can work with clients to identify ways to dematerialise buildings and select low carbon materials.

We are exploring way to deliver sustainability outcomes at our project sites, including: •

Using GreenPower for sites amenities, where connected to a permanent power source

•

Deliver leading waste management practices in partnership with Bingo Industries, with all construction sites having a minimum 90% recycling rate

•

Trialling new technologies and applications: o

Mobile Solar & Battery system

o

Peak Demand Battery

Recognition 17 Spring Street ◊

2024 MBV Special Commendation Excellence in Highrise Apartment Buildings

Nightingale Village ◊

2023 MBA National Master Builders National Sustainability in a Commercial Building Award

◊

2023 MBV Excellence in Construction: Best Sustainable Project

Burwood Brickworks Shopping Centre ◊

2020 MBV Excellence in Construction: Best Sustainable Project

◊

2022 Living Building Challenge® Petal Certification

◊

5 Star Green Star

The Social Quarter at Chadstone - The Fashion Capital ◊

First development in Australia to achieve a Green Star Designed assessment with the new Green Star Buildings tool

Botanicca 3 ◊

Design & As Built V1.1

10 Nexus Court ◊

Office Design V3

EHSQ Systems & Certifications

Modern Slavery Policy

MODERN SLAVERY POLICY

INTRODUCTION This policy applies to all Hacer Group people; internal employees, on-hire employees, independent contractors, volunteers, or visitors entering a Hacer Group worksite (“People”).

Hacer Group is committed to operating our business lawfully and ethically with People that are aligned to our values. We expect all Hacer Group People to act in accordance with all applicable modern slavery laws including those prohibiting human slavery and slavery like practices, human trafficking and child labour.

This policy sets out the minimum standards of behaviour and conduct that Hacer Group expects its People to meet in respect of modern slavery.

POLICY WHAT IS MODERN SLAVERY? Modern slavery includes eight types of serious exploitation: (a)

trafficking in persons;

(b)

slavery;

(c)

servitude;

(d)

forced marriage;

(e)

forced labour;

(f)

debt bondage;

(g)

deceptive recruiting for labour or services; and

(h)

the worst forms of child labour (referring to situations where children are subjected to slavery or similar practices, or engaged in hazardous work).

Hacer Group is formally committed to reducing the risks of modern slavery occurring within our company operations and supply chains in accordance with the Modern Slavery Act 2018 (Cth). This includes publishing an annual publicly accessible ‘Modern Slavery Statement’ that outlines the steps taken by Hacer Group to deal with modern slavery risks in its operations and supply chains

GENERAL OBLIGATIONS Hacer Group expects that its People will comply with the principles and values set out in this policy.

These include an expectation that all employees will:

Page 1 of 2

EHSQ Systems & Certifications

Modern Slavery Policy

(a)

comply with all applicable laws, regulations and industry codes of practice in relevant jurisdictions relating to modern slavery, including the Modern Slavery Act 2018 (Cth);

(b)

promptly report any breaches of applicable laws, regulations and industry codes of practice in relevant jurisdictions relating to modern slavery;

(c)

manage their individual contributions to risk, governance and compliance relating to modern slavery appropriately; and

(d)

participate in training offered by Hacer Group and engage with educational materials supplied in relation to modern slavery.

BREACH

Hacer Group expects employees to report non-compliance with this policy to your relevant Director or the Modern Slavery Committee.

Hacer Group takes this policy seriously and any material non-compliance by an employee may result in the termination of the individual’s employment with Hacer Group.

RESPONSIBILITIES All Hacer Group People.

REFERENCES

Modern Slavery Act 2018 (Cth) and Hacer Group’s most recent Modern Slavery Statement.

FURTHER INFORMATION For further information please contact: (a)

the Modern Slavery Committee; and

(b)

your relevant Director.

Signed: Name:

Mark Lewis Director

Date:

July 2023

Page 2 of 2

Hacer Modern Slavery Statement FY23

About this statement This is a joint Modern Slavery Statement for the financial year ended 30 June 2023 (Statement). This statement is prepared for Hacer Group Pty Ltd (ACN 091 032 530) and the following associated entities are identified as the reporting entities for the purposes of the Act: Hacer Australia Pty Ltd (ACN 650 862 721, ABN 90 650 862 721) Hacer Group Pty Ltd (ACN 091 032 530 as trustee for the Hacer Group Unit Trust, ABN 86 972 049 616 ) Hacer Group QLD Pty Ltd (ACN 142 880 975, ABN 87 142 880 975) Hacer Group NSW Pty Ltd (ACN 604 377 282, ABN 99 604 733 282) Hacer Group Australia Pty Ltd (ACN 612 663 831, ABN 69 612 663 831) Arc Metal Group Pty Ltd (ACN 615 321 438, ABN 72 615 321 438) Hacer Group WA Pty Ltd (ACN 604 376 632, ABN 48 604 376 632) Hacer Group SA Pty Ltd (ACN 605 304 514, ABN 66 605 304 514) herein references to “Hacer”, “Group”, “us”, “we”, or “our” in this Statement are references to the Hacer Group and each of the reporting entities unless specified otherwise.

Hacer Group’s registered office is located at 222 High Street, Kew, 3101 Victoria.

Consultation In preparing this Statement, Hacer Group’s General Counsel actively engaged and consulted with the relevant business units and entities which form part of the Group.

This was undertaken by (i) collaborating with the relevant business units, entities and boards to provide an overview of the Modern Slavery Act 2018’s reporting requirements, (ii) providing information regarding the actions we intend to take to address these requirements including relevant updates, and (iii) seeking feedback from relevant business units, entities and the board with respect to modern slavery matters. This report is the consolidation of the outputs from those efforts.

We acknowledge the Traditional Owners of Country throughout Australia where we work, and their continuing connection to land, sea and community.

We pay our respects to all Aboriginal and Torres Strait Islander peoples, their cultures and to their Elders past, present and emerging.

4

Hacer Group

Modern Slavery Statement

5

Contents

01

02

03

04

05

Introduction

Structure, Operations and Supply Chain

Approach to Risk Management

Addressing and Mitigating Risks

Measuring Effectiveness

Next Steps

Hacer Modern Slavery Statement 08

1.1 Hacer Overview 12

2.1 Risks in Property and Construction 16

3.1 Governance 22

4.1 Last year’s commitments and performance 30

5.1 Future Commitments 32

1.2 Supply Chain 14 Key Achievements FY23 10

3.2 Policies 24 2.2 Risks in our Operations 18 3.3 Due Diligence Process 25 2.3 Supply Chain Risk Assessment 19 3.4 Capability and Awareness 25 2.4 Prioritisation 21 3.5 Partnerships 26 2.5 Priority Risk Areas 21 3.6 Grievance Systems 27 3.7 Remediation Process 28

6

Hacer Group

Modern Slavery Statement

7

Introduction Hacer Modern Slavery Statement

Addressing modern slavery in our supply chain remains a priority for our business.

49.6 41K Approximately

million people around the world1

at least

people in Australia1

continue to live in slavery-like conditions.

At Hacer, we value the social wellbeing of the communities we work in and the people we work with.

For Hacer, these numbers are unacceptable and highlight the need to continue taking meaningful steps towards eliminating slavery practices.

In publishing this statement, we recommit to continuously improving our approaches with the goal of contributing to a global economy in which human rights are protected and modern slavery no longer exists.

This Statement was approved by the Hacer Board of Directors on 20 December 2023. The Statement was approved on behalf of the group reporting entities.

1

8

Hacer Group

Modern slavery is present in every country and within most industries. While we operate primarily in Australia, where modern slavery is less common, we acknowledge our reliance on supply chains which extend across higher risk geographies and industries. Factors including long and complex supply chains, tight margins and strict timelines, the use of raw materials and high rates of unskilled labour all contribute to a higher risk of modern slavery in the building and construction industry.

alkfree 2022, Global Slavery Index (Country Study: Modern Slavery in Australia), Walkfree, Australia (Accessed from: W https://www.walkfree.org/global-slavery-index/country-studies/australia/)

Modern Slavery Statement

9

Introduction Key Achievements FY23

Key Achievements FY23

10

Hacer Group

Due Diligence We undertook an independent review of our systems and defined areas to improve them.

Capability and Awareness We extended our baseline awareness training to all employees via our e-Learning module.

Management

Governance

Risk

We established clear roles and responsibilities for Modern Slavery Risk Management.

We established a new Contracts Manager role to better support the oversight and management of our subcontracting practices and the associated risks.

We engaged Edge Impact to undertake a spend-based risk assessment and work with our staff to define our priority risk areas.

Modern Slavery Statement

11

01 Structure, Operations and Supply Chain

Structure, Operations and Supply Chain

1.1 Hacer Overview

Employment Status (at 30 June 2023)

Company Statistics

Hacer, a privately held construction company, first ‘broke ground’ in Melbourne in 2000, quickly growing into a multi-faceted business by offering clients a fullyintegrated end-to-end design and construct service.

2000 450m

Over the past 23 years we’re proud to have completed landmark buildings for some of Australia’s best-known corporations and enterprises, winning multiple awards for building excellence.

70%

With offices in Melbourne and Sydney, Hacer continues to grow a reputable portfolio of work across a diverse range of sectors.

With a strong emphasis on quality, we deliver long-standing developments as well as longstanding relationships.

Hacer specialises in the construction and delivery of low, medium and high-rise mixed-use residential, retail, office and commercial developments, shopping centres, hotels, hospitals and medical centres and commercial fit outs.

Additionally, Hacer holds a ‘controlling interest’ over Arc Metal Group Pty Ltd (Arc Metal). Arc Metal specialises in the design, fabrication and fitting of metal architectural products, which are incorporated into a diverse range of construction projects across Australia.

With end-to-end responsibility comes end-toend accountability and our clients depend on us to construct with reliability.

12

Hacer Group

Operational Location

Full time Year Established

Annual Revenue

Repeat Client Work

167 17

Permanent1 Employees

Fixed Term2 Employees

42

Day Hire Employees

Part time

230+ 12

Team Members

Sites Currently Under Construction

1bn+ 350+

Works Under Construction

Projects Completed

8 5

Permanent1 Employees

Victoria 12 locations

Sydney 3 locations

Fixed Term2 Employees

Nil

Casual3 Employees

239

Permanent employees are employed by Hacer on a full time (38 hours per week) or part time basis (less than 38 hours per week).

2 Fixed term employees are employed by Hacer for a fixed term (their employment has an agreed end date).

3 Casual employees are paid on an hourly basis.

1

Total Hacer Headcount

Modern Slavery Statement

13

01 Structure, Operations and Supply Chain

Our supply chain can be described in three key segments: Labour, Material Inputs and Corporate Procurement.

1.2 Supply Chain Hacer’s supply chain is a complex network made up of many stakeholders, materials and activities. Our network provides the labour and material inputs for our construction projects and extends across Australia and overseas. We engage directly with approximately 1,328 subcontractors and suppliers. Similarly, these subcontractors and suppliers engage with, and purchase, thousands of products and services from, their own sub-subcontractors and sub-suppliers which then make up our extended supply chain.

Labour To be successful in delivering our projects we require a diverse set of skills and expertise. As a result, labour is a critical component in our supply chain. For each project, in addition to our employees, we will typically engage professional consultants, engineers, skilled and unskilled labourers and various subcontractors and suppliers. This decentralised model can lead to a complex network of labour relationships.

FY23 Procured Goods and Services

$350.7 Million 1,328 Direct Suppliers

Maintaining worker protections, including fair wages, safe working conditions, and compliance with labour laws, are critical priorities for Hacer. The fragmented nature of the construction labour market requires us to be vigilant in ensuring clear and consistent practice of these protections across all stakeholders.

Total Spend by Category and Country

Country

Australia

China

Concrete Metal Works Excavation Structural Steel Joinery

Ceramic Tiling Carpentery

Precast Concrete Building Fit Outs

Many of the goods and services used to facilitate our day-to-day operations and business functions are acquired through our corporate procurement supply chain.

Corporate procurement includes goods and services to support functions such as professional services, IT and communications, marketing, travel, cleaning, security and insurance.

Efficiency, cost-effectiveness, quality and reliability are key considerations in relation to our corporate procurement. Our corporate supply chain is underpinned by strong relationships, which are regularly evaluated to ensure that the goods and services being acquired are contributing positively to Hacer’s overall objectives.

7%

Fire Services Roofing 0M

Hacer Group

Our projects use a significant amount of construction materials, including (without limitation) concrete, steel and composite materials like joinery and facades. Supply chains for these materials will typically involve numerous suppliers, manufacturers, and distributors. Feasibility and resource pressures often mean that these materials will be sourced from outside of Australia.

Much like labour, our materials supply chain is decentralised and supported by subcontracting.

This introduces various challenges in terms of supply chain transparency in relation to component materials.

Mechanical Services

14

Corporate Procurement

While the majority of our tier one materials suppliers are based in Australia, Hacer also procures some construction materials directly from overseas based suppliers and manufacturers. Materials such as joinery and facades make up the majority of imported goods within our supply chain.

Electrical Services

Figure 2 - Hacer Spend by category

Material Inputs

20M

40M

60M

80M

of total spend comprises products and materials sourced from China directly Modern Slavery Statement

15

02 Approach to Risk Management

2.1 Risks in Property and Construction The property and construction sector employs

and is responsible for approximately

7% 18% of the global workforce

Approach to Risk Management

This section outlines the development in our understanding of modern slavery risks in our supply chain.

In developing our understanding, we have looked at the risks in the property and construction industry at a macro level and have undertaken an assessment to identify risks specific to Hacer. As part of our focus on ‘priority risk areas’ we have also taken further steps to identify where these risks may occur within our supply chain.

22%

Hacer Group

of these victims2 are forced into labour to support the production of essential raw materials.

Lack of transparency within the industry further exacerbates the problem, making it challenging to trace the origins of materials and ensure ethical and sustainable production practices.

Why does Modern Slavery occur?

Complex root causes Complex root causes including poverty, conflict and crisis, cultural perspectives and lack of protective safeguards and legislation.

Deception & Coercion Perpetrators using tactics such as intimidation, coercion, manipulation, and deception to entrap individuals.

Vulnerable Migrants​ Individuals taking risky decisions in search of opportunities to provide for their families.

Globalisation Long opaque supply chains, with decreasing levels of transparency.

Purchasing Practices Unrealistic cost and time pressures on suppliers, including sudden changes in demand.

Shifting Risk Passing on responsibility – “it’s not our issue, it’s the supplier’s problem”.

Varied Worker Protections When labour protections are weak, workers are more vulnerable to exploitation and abuse, including forced labour and human trafficking.

Figure 3 - Modern Slavery Root Causes

2

16

of modern slavery victims

The ability to monitor and address exploitative practices within the supply chain is often made difficult by the fragmented structure created through use of multiple subcontractors and their respective suppliers.

Additionally, the production of construction inputs relies heavily on low-skilled, low-paid, and often migrant workers, who are increasingly vulnerable to exploitation due to circumstances such as lack of legal rights, language barriers, and limited access to information and support. High demand for construction materials and services can drive down prices, which can lead to cost-cutting measures that can result in exploitation, including forced labour.

Australian Human Rights Commission 2020, Property, Construction and Modern Slavery, Australian Human Rights Commission, Australia

Modern Slavery Statement

17

02 Approach to Risk Management

2.3 Supply Chain Risk Assessment In 2023 Hacer engaged Edge Impact to conduct a Social Life-Cycle Assessment (S-LCA) analysis of our spend data against a number of internationally recognised risk, media and literature databases (including the Social Hotspot Database, Global Slavery Index). This type of analysis ranks procurement categories according to inherent modern slavery risk, and by spend, to summarise the hotspots and their drivers. The aim of conducting an S-LCA, is to cut through the opacity of complex global supply chains to identify and to prioritise our focus on the most salient risks to our people. Our hope is that this approach will assist us to take more targeted actions to mitigate these risks in a manner that is consistent with our commitment to the United Nations Guiding Principles on Business and Human Rights (UNGP).

Our S-LCA helped us to identify those areas within our supply chain at the highest risk of modern slavery. This was done through consideration of both high-risk geographies and industries, and was priority weighted based on our annual spend.

We seek to adopt the principles outlined in the UNGP to assess our modern slavery risks, in alignment with the Australian Government’s recommended approach. We analyse our potential involvement in modern slavery and other human rights violations through three perspectives: as a ‘Cause’, a ‘Contribute’, or ‘Direct Linked’ to the harm. This breakdown enables us to understand and address the various dimensions of our association with human rights risks (and helps us to understand and develop our approach to remediation upon the identification of harm).

2.2 Risks in our Operations In FY23, the modern slavery risks in our direct operations remained comparatively low. Our employees operate within Australia, primarily delivering site-based construction and project management services and other office-based services related to construction; and are employed in accordance with Australian workplace law. Our employees have the right to join a union and 20 per cent of our workforce is employed under an Enterprise Bargaining Agreement. We recognise that in some contexts, non-permanent workers and workers who hold visas may be more vulnerable to exploitation. As can be seen in Section 1.1, most of our workforce are permanent employees.

We have a comprehensive suite of policies that contribute to a safe and fair working environment. Our policy framework, outlined in Section 3.3, applies to all employees.

18

Hacer Group

Cause A business may cause modern slavery or other human rights harm where its actions directly result in the occurrence of modern slavery.

Contribute A business may contribute to modern slavery or other human rights harm where its actions or omissions facilitate or incentivise modern slavery.

Directly Linked A business may be directly linked to modern slavery through its services, products or operations. This includes situations where modern slavery may occur in a business’ extended supply chain.

The findings from our S-LCA are presented below:

Inherent Risk

No. of Categories

No. of Suppliers

Very High

33

761

High

25

404

Medium

29

344

Low

28

368

Modern Slavery Statement

19

02 Approach to Risk Management

Updated Risk Assessment

2.4 Prioritisation

In FY23, Hacer recognised that we would be most effective prioritising our activities around the categories in relation to which we have the most opportunity for impact. The drivers of modern slavery risks are constantly evolving and we identified a need to establish a comprehensive understanding of our priority areas.

Spend in high modern slavery risk categories

To address this, Hacer engaged Edge Impact to undertake a Social Life Cycle Assessment (S-LCA), a spend-based risk assessment, to provide some insight into those stages in our supply chain which pose the greatest risk to Hacer and to give some greater clarity on our high priority risk areas.

44% 56%

The findings from our S-LCA informed the prioritisation of activities and initiatives to support Hacer in focusing on some more targeted risk controls. We are currently developing a three-year implementation roadmap to support the roll out of these controls.

Much of our focus was on areas and categories within our supply chain where our ability to influence change was relatively high. This included a focus on those subcontractors and suppliers with whom our spend was relatively high as well as a better understanding of how ‘close’ the risk was to Hacer within our supply chain. Our team recognised limitations in leverage with smaller subcontractors and suppliers and deeper points within our supply chain.

Through this process, we identified the following priority risk areas for Hacer.

2.5 Priority Risk Areas All other Spend High and Very High Risk

Risk Category

Figure 4- Percentage of spend in high modern slavery risk categories

Categories with high inherent risk

Subcontracted Labour

Logistics from overseas supply chain

Manufacturing

Operations

Brickworks

Brickworks

Brickworks

Brickworks

Metalworks

Metalworks

Metalworks

Landscaping

Joinery

Demolition

Carpentry

Carpentry

Professional Cleaning

Concrete

Concrete

Plaster

PPE

Joinery

Limited labour market promotes a reliance on temporary or migrant workers Increased vulnerability to exploitation and modern slavery.

Supply Chain

20

Hacer Group

Construction Materials

(Indirect – Via local subcontractors and suppliers)

(Direct – Via overseas suppliers and manufacturers)

Complex and opaque supply chains

Reliance on lower skilled labour

Use of third-party recruitment

Difficulty in tracing the origin of materials minimises the ability to identify and manage modern slavery risk.

Increased risk of exploitation in the manufacturing process.

Potential for exploitation in recruitment processes.

Links to high-risk geographies Geographical locations with higher prevalence of modern slavery.

Corporate Procurement

Complex supply chains Difficulty in monitoring and ensuring ethical practices throughout the supply chain.

Our Relationship to Risk Directly linked/ Contribute

Figure 5- Modern slavery supply chain risk by category

Construction Materials

Key Risk Factors

Raw materials extraction

Joinery

Our S-LCA highlights specific aspects of our supply chain where potential human rights implications are most prevalent. However, we have recognised that there is an opportunity for us to have a greater impact across our supply chain, including in lower risk areas. Using our risk assessment outcomes, we worked with Edge Impact to facilitate a series of workshops to explore our existing business practices and any perceived influence over our subcontractors and suppliers, and to identify opportunities for meaningful interventions.

Operations

Failure to adequately monitor subcontractors may contribute to exploitation risks, directly contributing to modern slavery. Regular audits and engagement are crucial to mitigate this risk.

Directly linked We have limited control over local subcontractors and suppliers but are committed to transparency and due diligence to address the indirect risks associated with complex supply chains.

Directly linked/ Contribute

Directly linked/ Contribute

Our sourcing practices are directly linked with the risk of modern slavery.

Prioritising ethical sourcing and conducting due diligence are crucial risk mitigants.

Unethical procurement practices directly contribute to modern slavery risks.

Implementing transparent procurement processes and engaging with suppliers are essential.

Table 1 - Hacer Priority Risk Areas

Modern Slavery Statement

21

03 Addressing and Mitigating Risks

Addressing and Mitigating Risks

3.1 Governance Every member of Hacer has a role to play in addressing modern slavery.

We believe in shared responsibility and clear accountability, because real change happens when everyone is on board.

At Hacer, we are working towards integrating modern slavery risk management into our existing approaches.

It’s not just a policy; it’s how we do business.

Stakeholders

Government and Regulators

Financers

Business Partners

Suppliers

Key Risk Factors Hacer Board of Directors Maintain oversight of human rights (including risks related to modern slavery) across Hacer’s operations and business processes.

Executive Audit and Risk

Executive

Responsible for oversight of Hacer’s response to human rights and providing guidance to the Board.

Accountable for the implementation of Hacer’s human rights strategy and approach.

Working Group Modern Slavery Working Group Promotes information exchange across Hacer in relation to implementation of modern slavery risk management.

Business Processes Human Resources

General Counsel

Procurement

Project Managers

Accountable for ensuring employees are subject to relevant awards and industrial instruments; is one of the officers responsible for triaging concerns from Hacer’s whistleblower system.

Responsible for ensuring compliance with relevant laws and regulations related to modern slavery; is one of the officers responsible for triaging concerns from Hacer’s whistleblower system.

Accountable for the identification and response to modern slavery risks within Hacer’s supply chain.

Accountable for the identification and response to modern slavery risks within Hacer’s projects.

Business Processes All staff Responsible for the identification of modern slavery risks within our supply chain, consistent with Hacer’s values.

Table 2 – Modern Slavery Governance Framework

22

Hacer Group

Modern Slavery Statement

23

03 Addressing and Mitigating Risks

Case Study

3.3 Due Diligence Process

Governance Mapping

Creation of the Contracts Manager Role

We believe modern slavery risk management is a shared responsibility, so we have worked with Edge Impact to map modern slavery roles and responsibilities against our existing functional roles, by business unit.

In FY23 we introduced a new ‘Contracts Manager’ role within Hacer to increase oversight in procurement and subcontractor and supplier award recommendations.

This role will enhance modern slavery risk management and the integration of relevant risk management initiatives across Hacer.

This framework aims to provide better clarity to our employees, which will inform the development of future policies and training programs.

At Hacer, we are working towards improving our human rights due diligence process. In FY23, Hacer has continued to roll out the implementation of Informed 365, a key tool involved in the real-time collation of Modern Slavery related data and metrics.

The use of Informed 365 allows Hacer to track the proportion of subcontractors and suppliers that have taken steps towards mitigating modern slavery risk within their respective supply chains. Subcontractors and suppliers can provide Hacer with their related modern slavery documentation including: – – – – –

Policies Code of conduct Due diligence processes Risk data Other relevant efforts.

Our policies and how they support our approach to modern slavery.

2 Prioritise suppliers and categories: Risk level will determine the due diligence approach and documentation required.

3 Manage due diligence efforts: Set KPIs and monitor progress.

Mandatory Employee Modern Slavery Awareness e-learning

Recruitment Policy

Modern Slavery Policy

Procedure for Purchasing

Outlines processes to ensure that the recruitment of employees is conducted ethically.

Establishes a clear commitment to understanding and reducing the risk of modern slavery within our supply chain, outlining Hacer’s expectations in relation to compliance with all laws relating to modern slavery.

Guides the purchasing process to assess and mitigate risks associated with suppliers and contractors, ensuring that procurement decisions consistently align with Hacer’s commitments to non-price attributes (including social risk).

Subcontractor Agreement

Grievance Policy

Whistleblower Policy

Embeds contractual obligations related to modern slavery prevention, to ensure subcontractors comply with modern slavery legislation and take appropriate measures to reduce the risk of modern slavery within their respective supply chains.

Establishes a mechanism for individuals, including employees, independent contractors, volunteers and visitors entering a Hacer worksite, to raise concerns, ensuring that grievances are addressed promptly and effectively.

Encourages a mechanism for individuals, employees, independent contractors, volunteers and visitors entering a Hacer worksite, to report any suspected wrongdoing, misconduct or unethical behaviour within Hacer , providing protection for whistleblowers and fostering a culture of transparency and accountability.

Sets minimum standards of behaviour and conduct, ensuring that employees are aware of and commit to ethical practices.

1 Plan and understand risk: Based on the risk assessment we have conducted of Hacer’s supply chain and our categorisation of High/Medium/Low risk subcontractors and suppliers.

3.4 Capability and Awareness

3.2 Policies

Code of Conduct

In subsequent years, we are looking to develop a due diligence framework, where we will:

All Hacer employees are required to complete a bespoke, modern slavery e-learning module to help facilitate proactive action and positive change towards modern slavery.

Training

Baseline Awareness Training Overview: Defines modern slavery, its relevance to the construction industry, risks related to our supply chain and the approach Hacer takes to mitigate these risks; online training module.

Audience: Compulsory for all staff

The module identifies various modern slavery risk indicators using practical examples relevant to products and services across the construction industry. The practical examples demonstrate how Hacer might cause, contribute, or be directly linked to modern slavery through our supply chain.

In addition, the module articulates Hacer’s governance arrangements, including our escalation and reporting channels for suspected modern slavery breaches so that incidents, once identified, can be directed to the appropriate person(s) within the business.

Table 4 - Hacer Modern Slavery Training Framework

24

Hacer Group

Modern Slavery Statement

25

03 Addressing and Mitigating Risks

3.5 Partnerships

3.6 Grievance Systems

Better Sydney (Advisors, expertise)

Edge Impact (Advisors, expertise)

Better Sydney provides trusted professional advice to Hacer in relation to our modern slavery strategy and has also co-facilitated modern slavery training sessions.

Edge Impact provides trusted professional advice to Hacer in relation to our modern slavery strategy. Edge Impact has performed our Social Life-Cycle Assessment (S-LCA) risk assessment, has undertaken a review of our due diligence tools and systems, has hosted several workshops with our employees and has assisted in the drafting of this modern slavery statement.

Informed 365 (Technology providers)

Property Council of Australia (Industry peers, knowledge sharing)

Informed 365 provides a customised, cloud-based application, which Hacer uses to manage, monitor and engage with our supply chain. Informed 365 will be developing educational training resources, which Hacer intends to extend to our subcontractors and suppliers.

Property Modern Slavery Working Group through Informed 365 provides industry specific guidance and resources that inform our risk management approaches.

26

Hacer Group

Hacer upholds high standards of conduct and aims to create a culture that welcomes feedback from all stakeholders including affected parties to ensure we are operating in alignment with our goals and policies across our supply chain. We recognise that giving feedback isn’t always straightforward, so we have created easy to access systems which allow individuals to readily and provide feedback or highlight concerns about modern slavery, potential human rights issues, or unethical behaviour.

Hacer has two key pathways for raising a grievance; both have defined policies to support the person raising the grievance including; – Maintaining anonymity, if they choose; – Being treated fairly and with respect as their claim is heard and understood; – Accessing remedy for identified harm; and – Being protected from reprisal for raising a concern.

Mechanism

Grievance System Purpose, audience and access: Allows all internal employees, on-hire employees, independent contractors, volunteers, or visitors entering a Hacer worksite to have concerns heard and addressed in-house, in a timely and confidential manner. This approach minimises the need for employees to go outside of Hacer for assistance. Feedback provided through this system is provided directly to our HR Manager, or to the immediate supervisor of the relevant employee.

Mechanism

Whistleblower System Purpose, audience and access: Allows any employee, officer, their relatives and dependants, suppliers of goods or services to Hacer and their employees and workers) to confidentially report genuine concerns about wrongdoing, misconduct or unethical behaviour, including as they relate to potential exploitative practices on our worksites or in our supply chains, without fear of reprisals. This system can be accessed by Hacer employees via an anonymous feedback link in our internal portal.

Other stakeholders can direct their concerns through Hacer’s website or directly to the relevant whistleblowing officer.

Modern Slavery Statement

27

03 Addressing and Mitigating Risks

3.7 Remediation Process If, through investigating a grievance, Hacer determines that we have caused or contributed to modern slavery or slavery like conduct, we acknowledge our responsibility and take proactive steps to remediate the issue and address the impact.

Our Modern Slavery Working Group has developed a ‘remediation framework’, which has been incorporated into Hacer’s general remediation processes. We understand that in order to be effective, a grievance process must be “trusted and confidential”. This was a primary consideration when updating our general remediation processes.

The key purpose of our remediation plan is to ensure that any victim of modern slavery is protected, and to provide some guidance to Hacer in relation to the most appropriate pathway in supporting a victim to return to their personal circumstances prior to modern slavery. Our remediation framework is based on the following principles: – – – – – – –

Victim centred Context specific Transparent Accessible Responsible Collaborative Action focused

The remediation framework outlines the following steps: Process already developed and documented​ Information gathering

Process to be developed

Escalate to the Modern Slavery Working Group

Incidences that can be resolved with employer​

Incidences linked with violence or criminality​

Corrective action with subcontractor or supplier

Corrective actions not undertaken, or issue is complex and requires input from experts or authorities​ Easily remedied incidences​

Refer to Australian Federal Police​

Rehabilitation, material support, restitution or compensation​

Prevention: addressing root causes, providing resources to educate and support subcontractors and suppliers, and improving grievance mechanism​

Figure 6 - Hacer's Remediation Process

28

Hacer Group

The Modern Slavery Working Group members have been deemed the ‘first responders’ for modern slavery related grievances. The Group’s response and implementation of the remediation framework will depend on the specific circumstances and Hacer’s causal link to the adverse impact, which will be considered in alignment with the UNGP. Where Hacer determines a modern slavery breach has occurred, we will contact the Australian Federal Police.

We will then look to action appropriate measures to prevent such a breach occurring in the future.

Hacer’s response will depend on the circumstances of the individual case, but may include any of the following: – Information gathering to understand the full scope of the modern slavery risk; – Taking steps to ensure the harm caused by modern slavery is mitigated and will not occur again; – Communicating the modern slavery risk to appropriate authorities; – Stopping activities that cause or contribute to modern slavery, including taking action under its subcontractor and supply arrangements; – Issuing companywide alerts and updating subcontractor and supplier registers serving to notify all business units that a systemic modern slavery issue with a subcontractor or supplier has been identified; and – Providing resources to educate and support subcontractors and suppliers to ensure harm does not reoccur.

Modern Slavery Statement

29

04 Measuring Effectivements

Measuring effectiveness

4.1 Last year’s commitments and performance Area

Commitment

Progress

Governance

Modern Slavery Committee: Ensure internal Committee meetings continue to be held regularly, minutes are taken and action items updated.

We have developed the terms of reference for this committee and have increased the participants to become a broader Modern Slavery Working Group, but we have not yet established a routine cadence for these meetings.

Creation of the new Contracts Manager role.

The new role of Contracts Manager has been created to enhance oversight. Contracts Managers are now actively involved across all of our projects.

Modern Slavery Policy: Make the Modern Slavery Policy available to all employees including during the induction of new employees and through publishing on the internal portal.

Our Modern Slavery Policy continues to be distributed to new employees during induction and is accessible to existing employees via our internal portal.

Training and Education: Arrange a further company-wide training session, focusing on modern slavery risks specific to our industry/business. Distribute module to all new staff members.

We have extended our baseline awareness training to all employees via our e-learning module.

Strengthening Contracts: Continue to screen documents to ensure modern slavery clauses are included in all relevant contracts.

Ongoing screening of documents to ensure inclusion of modern slavery clauses in relevant contracts. Regular review of clauses to align with legal developments.

Policies and Processes

Hacer is committed to long term action.

Our commitment to long term action requires us to regularly track and report on our actions and progress. In doing so we are better able to understand the effectiveness of our interventions and identify any gaps or areas for improvement.

Targeted training for key roles is still in development.

Periodically review clauses to ensure any developments in the law are appropriately reflected.

Supplier Engagement

Remediation

Risk Assessment: Continue monitoring the risk assessment/risk rating tools available on the Informed 365 platform as we focus on getting more subcontractors/suppliers to respond.

Ongoing monitoring and risk assessment. We are also currently reviewing our use of the Informed 365 platform with a view to embedding it into our subcontractor and supplier due diligence processes.

Modern Slavery Declaration: Continue engaging suppliers to provide data during the Investigation Stage via Informed 365.

We are currently reviewing our use of the Informed 365 platform with a view to embed it into our supplier due diligence processes.

Education for Subcontractors/Suppliers: Utilise the training and education programs embedded within Informed 365 platform to educate subcontractors/suppliers.

We engaged Edge Impact to assist in identifying our priority risk areas. The communication plan to support this is still in development.

Remediation Framework: Ensure all staff are aware of how to access and utilise the modern slavery risk remediation framework. Run a trial to ensure there are no gaps in the framework.

Our review has identified the need to tailor it further to meet the needs of vulnerable whistleblowers.

We did not progress to a trial of our systems.

Table 7 - Update on last year’s commitments

30

Hacer Group

Modern Slavery Statement

31

05 Next Steps

Next Steps 5.1 Future Commitments

Area

Governance

Risk Management

Risk Management

Capability and Awareness

Grievance and Remediation

Collaboration

Commitment

Create a 3 year modern slavery roadmap.

Commence supply chain mapping in one key priority risk category.

Continue to refine and develop our Modern Slavery Working Group, consisting of employees across multiple teams.

rovide Board and executive P level training in relation to modern slavery (including explanations of Hacer’s approach).

Investigate opportunities to extend grievance accessibility.

Consider opportunities to work with industry bodies to build subcontractor and supplier leverage in the medium term.

ontinue to implement the C modern slavery awareness training module as part of the new employee induction.

Publish the modern slavery guide for subcontractors and suppliers: A guide that provides subcontractors and suppliers with clear guidance on Hacer’s expectations regarding modern slavery, outlining the steps they should take to better understand modern slavery risks and to reduce the risk of modern slavery within their own supply chain.

I ntegrate modern slavery risk management into the Sustainability Framework and Action Plan.

Formalise a due diligence and risk assessment process.

Undergo a prioritisation activity to identify and articulate Hacer’s salient modern slavery/human rights risks and priorities.

Create an action plan for subcontractors and suppliers under these categories.

Success Criteria

Hacer considers social and human rights impacts as part of its overall commitment to sustainability.

Supply chain mapping of tier one subcontractors and suppliers is complete. rovide a list of high-risk P sourcing regions and product categories. isclose due diligence D methodology and process.

Educate and equip commercial and design team members with a communication and action plan to communicate modern slavery risks to subcontractors and suppliers.

All new employees have undertaken the modern slavery awareness training module.

Design and commercial team members feel equipped to start engaging with subcontractors and suppliers in relation to modern slavery risks.

Subcontractors receive clear instructions and are educated on next steps to reduce modern slavery risk within supply chains.

Continue the roll out and encourage use of the remediation framework.

Run a trial to ensure there are no gaps in the framework.

Grievance and remediation framework has been trialled, with employees clear on its use.

I dentified opportunities for collaboration with other industry bodies in the medium term.

Table 8 - Our future roadmap

32

Hacer Group

Modern Slavery Statement

33

Hacer Group

Hacer Melbourne

Hacer Sydney

hacer.com.au

222 High Street, Kew, VIC 3101

Suite 6.06, Level 6, 55 Miller Street, Pyrmont, NSW 2009

@hacergroup

T 03 9810 6888 E vic@hacergroup.com.au

T 02 8570 1300 E nsw@hacergroup.com.au

This Statement was approved by the Hacer Group Board of Directors on 20 December 2023.

The Statement was approved on behalf of the joined reporting entities.

Paul Toleman Director

Mark Lewis Director

Vin Sammartino Director

© Hacer Group 2023

Reflect

Reconciliation Action Plan September 2023 - March 2025

Reconciliation Action Plan

Acknowledgement of Country Hacer Group acknowledges the Traditional Owners and Custodians of the lands on which we live and work. We celebrate the oldest living culture and respect the land on which we build.

We pay our respect to Elders – past, present and future – and we strive together to embrace an optimistic outlook for our future in harmony, across all of Australia and for all of its people.

Our Reflect Reconciliation Action Plan (Reflect RAP) considers Aboriginal and Torres Strait Islander peoples across Australia. This includes factors that directly and indirectly affect the wellbeing, cultural and socio-economic outcomes of Australia’s First Nations Peoples.

We deeply appreciate and acknowledge the Aboriginal and Torres Strait Islander people who provided their time, knowledge and perspectives throughout the development of our Reflect RAP.

2

2023 - 2025

Contents Statement from CEO of Reconciliation Australia

4

Message from the Hacer Directors

6

Bio from CEO of The Killara Foundation

7

About Hacer 8 Our Approach 9 Company Values 11 Our RAP Artwork 12 About the Artist - Meet Emma

14

Our Reconciliation Working Group

17

Our Reconciliation Action Plan •

Relationships 18

•

Respect 20

•

Opportunities 22

•

Governance 24

Contact Us 26

3

Reconciliation Action Plan

CEO, Reconciliation Australia

Statement Reconciliation Australia welcomes Hacer to the Reconciliation Action Plan (RAP) program with the formal endorsement of its inaugural Reflect RAP. Hacer joins a network of more than 1,100 corporate, government, and not-for-profit organisations that have made a formal commitment to reconciliation through the RAP program.

Since 2006, RAPs have provided a

The RAP program’s strength is its

framework for organisations to leverage

framework of relationships, respect, and

their structures and diverse spheres

opportunities, allowing an organisation

of influence to support the national

to strategically set its reconciliation

reconciliation movement. The program’s

commitments in line with its own

potential for impact is greater than ever,

business objectives, for the most effective

with close to 3 million people now working

outcomes.

or studying in an organisation with a RAP. These outcomes contribute towards the The four RAP types — Reflect, Innovate,

five dimensions of reconciliation: race

Stretch and Elevate — allow RAP partners

relations; equality and equity; institutional

to continuously develop and strengthen

integrity; unity; and historical acceptance.

reconciliation commitments in new ways.

It is critical to not only uphold all five

This Reflect RAP will lay the foundations,

dimensions of reconciliation, but also

priming the workplace for future RAPs and

increase awareness of Aboriginal and

reconciliation initiatives.

Torres Strait Islander cultures, histories, knowledge, and leadership across all sectors of Australian society.

4

2023 - 2025

This Reflect RAP enables Hacer to

Congratulations Hacer, welcome to the

deepen its understanding of its sphere of

RAP program, and I look forward to

influence and the unique contribution it

following your reconciliation journey in the

can make to lead progress across the five

years to come.

dimensions. Getting these first steps right will ensure the sustainability of future RAPs

Karen Mundine

and reconciliation initiatives and provide

Chief Executive Officer

meaningful impact toward Australia’s

Reconciliation Australia

reconciliation journey.

5

Reconciliation Action Plan

Hacer Group Directors

Message Hacer’s first Reflect Reconciliation Action Plan (RAP) marks an important milestone in our 23-year history. We’re committed to a positive future in reconciliation and recognise the importance this paves for the next generation.

Reconciliation is a journey for all

Strait Islander-owned businesses.

Australians, and we all have a part to play.

We believe that reconciliation is

We are committed to developing respectful

not just a moral imperative, but a

relationships and creating meaningful

strategic imperative. A commitment to

opportunities with Aboriginal and Torres

reconciliation helps us to build stronger

Strait Islander peoples. With the support

relationships with the communities in

of the Killara Foundation, our initial efforts

which we operate, better understand the

will focus on improving cultural awareness

needs and perspectives of our customers

for all employees and subcontractors.

and stakeholders and build a more inclusive and diverse workforce.

We’ll strive to increase employment

6

and educational opportunities in the

We are proud to launch Hacer’s Reflect

construction sector for Aboriginal and

Reconciliation Action Plan (RAP) and look

Torres Strait Islander peoples and build

forward to working with our employees to

partnerships with Aboriginal and Torres

help accelerate reconciliation in Australia.

2023 - 2025

CEO, The Killara Foundation

Bio Kyle Vander-Kuyp is an Olympian and proud Yuin and Woromi man, dedicated to mentoring and driving initiatives related to Indigenous mental health and wellbeing; and bridging the education and workplace gap for Indigenous Australians.

Kyle is passionate about giving back to the

incorporate what they have learned into their

community and has worked with various

leadership and teambuilding skills.

organisations as a mentor for Indigenous youth throughout the course of his career.

Kyle also sits on the Koori Court as an Elder/

In 2019, Kyle co-founded the Killara

Respected Person, where he works alongside

Foundation to bring to life his vision for

the Magistrate and Courts Victoria to provide

excellence in the lives and careers of young

support, cultural and personal advice to

Aboriginal and Torres Strait Islander people

Aboriginal and Torres Strait Islanders who

and is currently the CEO and Director.

have come into the justice system. With a strong understanding of complex relationship

In 2020, Kyle co-founded the Tjungu Project

management, Kyle aims to be an inspiring

to reconnect Aboriginal people to Country

and positive role model for Indigenous people

and to take corporate groups out on

across the country, including his own family,

Country to truly connect to and understand

whom he looks forward to seeing grow and

the Culture. Also, to teach them how to

achieve their own dreams.

7

Reconciliation Action Plan

About Hacer

Who We Are With offices in Melbourne (Wurundjeri land) and Sydney (Gadigal land), Hacer Group continues to grow a reputable portfolio of work across a diverse range of sectors. With a strong emphasis on quality, we deliver long-standing developments as well as long-standing relationships.

When Hacer Group first launched its

We build end-to-end, giving our clients

Victorian operation in 2000, we became

consistency and cost efficiency. We

one of the first retail construction firms

build quality – striving for excellence in

to offer a fully integrated design and

every job we take on. Above all, we build

construct service.

confidence.

Our focus was on achieving excellence

We’re renowned for the highest level

and innovation in end-to-end property

of expertise and experience, having

development. Nothing has changed. Hacer

successfully managed and completed

Group still delivers top-quality projects,

projects for a range of major Australian

while maintaining optimum cost and time

companies, and winning multiple awards

efficiency.

for excellence in building. Hacer Group employs over 220 staff; while the number

We offer a range of project delivery

of Aboriginal and / or Torres Strait Islander

systems, from fixed-price contracts

staff is currently not known, we will work

to construction management, design

within this RAP to determine culturally

and construct, and early contractor

appropriate ways to understand this.

involvement.

We build for a range of industries including residential, retail, commercial, mixed-use, build-to-rent, medical and recreation.

8

2023 - 2025

Looking Ahead

Our Approach We have established an internal RAP

dialogue with Aboriginal and Torres Strait

committee and will continue to partner

Islander people to understand their cultural

with Aboriginal and Torres Strait Islander

practices and perspectives.

consultants such as Killara Foundation to ensure the appropriate delivery of

3.

Engaging a First Nations artist:

our RAP. We will develop relationships

In 2023, we engaged Emma Hollingsworth

and partnerships with Aboriginal and

to provide a custom painting using the

Torres Strait Islander businesses and

Hacer values (refer to page 11 for details).

organisations.

4.

NAIDOC Week/National

Implementing our RAP requires a

Reconciliation Week activities: We will

commitment to meaningful and tangible

work both with our internal committee

actions that fosters reconciliation. Our

and with external organisations to

aim is to take a balanced approach

participate in NAIDOC Week / National

combining both top-down and bottom-up

Reconciliation Week such as internal First

perspectives to roll out our RAP. This will

Nations colouring competitions, attending

ensure a more meaningful, well-rounded

community events, and engaging guest

conversation is had at all levels in the

speakers.

business.

Some of the ways in which we aim to implement our Reflect RAP, in addition to the items mentioned in our Reconciliation Action Plan commitments, are below:

Our RAP Champions Members of our senior management including our Managing Director (Mark Lewis) and HR Manager (Claire Wall) actively demonstrate strategic leadership commitment to reconciliation. They are

1.

Cultural Training: Continue

providing cultural awareness training for our employees, engaging our partner Killara Foundation, to create a shared knowledge base.

supported by our RAP Committee who implement our actions. The purpose of this group is to raise awareness, learn more about cultures and listen to Aboriginal and Torres Strait Islander voices to make better, informed decisions.

2.

Smoking Ceremonies: Our aim is

to actively listen, learn and engage in open 9

Reconciliation Action Plan

Smoking Ceremony at Richmond Quarter commencement of works

10

2023 - 2025

Company

Values Our values are a representation of who we are and what we’re accountable for. They encompass our passion and drive to ultimately achieve success as a team.

We ensure safety is paramount everywhere.

We build and commit to highest quality standards.

We openly communicate and develop respectful, trustworthy teams.

We work to make sustainability business as usual.

We follow through on our responsibilities and commitments.

We build close relationships with our people, clients and the industry.

11

Reconciliation Action Plan

Our RAP

Artwork This art piece represents connection and community, and it honours the Land that we all reside on, and its first people who have been Custodians over it for thousands of years.

This land provides for us, and we in turn must nurture it. The ‘u’ shapes in the artwork represent mob living on Country and caring for it. The concentric circles represent Hacer paying their respects and meeting with mob to yarn and speak about important things. The lines going outwards represent Hacer’s journey to understanding and building relationships with the First Nations people of this country.

This artwork acknowledges and pays respect to the many Aboriginal and Torres Strait Islander peoples and serves as a reminder that the Land always was and always will be Aboriginal Land.

12

2023 - 2025

13

Reconciliation Action Plan

About the Artist

Meet Emma Emma Hollingsworth is a Kaanju, Kuku Ya’u, Girramay woman who grew up in tropical far north Queensland. Her work tells her own story of a young Indigenous woman growing up and paving a path in a modern world, and all of the trials and tribulations that go in hand with that.

From a young age, I knew I wanted to be

colours because I am inspired by how I

an artist. My mother said that before I could

see the world. I paint about the Land and

even walk, I was drawing on just about

waterways, the animals, the peoples and our

anything I could find - including the walls

traditions, and I paint about how all of those

- and when I came of age, I began taking

things are intrinsically connected.

it more seriously. It took me a few years to learn and develop my own style, but

My art is contemporary and it has evolved

eventually I reached the point where I could

over the years. I am proud to now have my

paint intuitively.

own style of creativity that tells my story and brings my culture and peoples to life through

My artworks tell the story of my life. I paint about things I have experienced and things that inspire me, I also paint with vibrant 14

art.

2023 - 2025

Photography by Michelle Swan

15

Reconciliation Action Plan

Opening Ceremony at Richmond Quarter Coles and retail precinct

16

2023 - 2025

Our Reconciliation

Working Group Our working group is responsible for ensuring the actions outlined in the RAP are implemented.

17

Kyle Vander-Kuyp

Mark Lewis

CEO, Killara Foundation

Director, General Manager

Worimi and Yuin People

Hacer Group

Jillian West

Claire Wall

Killara Foundation

HR Manager

Bunurong and Palawa

Hacer Group

People

Matt Love Talent Acquisition Coordinator Hacer Group

Matt Hyams Senior Project Manager Hacer Group

Daniela Pizarro

Andie Leggett

Brand Marketing Manager

Post Construction Manager

Hacer Group

Hacer Group

17

Reconciliation Action Plan

Our Action Plan

Relationships We are committed to fostering meaningful relationships with Aboriginal and Torres Strait Islander peoples. Through our Reflect RAP commitments, we will actively learn best-practice approaches to help build relationships with greater courage, respect and a commitment to listen and to learn.

18

Richmond Quarter smoking ceremony

2023 - 2025

Action

1. Establish and strengthen mutually beneficial relationships with Aboriginal and Torres Strait Islander stakeholders and organisations.

2. Build relationships through celebrating National Reconciliation Week (NRW).

Deliverable Identify Aboriginal and Torres Strait Islander stakeholders and organisations within our local area or sphere of influence.

Research best practice and principles that support partnerships with Aboriginal and Torres Strait Islander stakeholders and organisations.

Commission an Aboriginal or Torres Strait Islander artist to create a unique painting for Hacer, reflecting our values and display in our office with plaque detailing art piece information.

Circulate Reconciliation Australia’s NRW resources and reconciliation materials to our staff.

RAP Working Group members to participate in an external NRW event.

Encourage and support staff and senior leaders to participate in at least one external event to recognise and celebrate NRW. Engage community involvement (e.g employee families) in activities to celebrate NRW. Communicate our commitment to reconciliation to all staff.

3. Promote reconciliation through our sphere of influence.

4. Promote positive race relations through anti-discrimination strategies.

Identify external stakeholders that our organisation can engage with on our reconciliation journey.

Identify RAP and other like-minded organisations that we could approach to collaborate with on our reconciliation journey.

Research best practice and policies in areas of race relations and antidiscrimination.

Conduct a review of HR policies and procedures to identify existing antidiscrimination provisions, and future needs.

Timeline

Responsibility

October 2024

HR Manager

October 2024

HR Manager

October 2023

HR Manager

May 2024

HR Manager

27 May 2024 3 June 2024

HR Manager

27 May 2024 3 June 2024

HR Manager

27 May 2024 3 June 2024

HR Manager

June 2024

HR Manager

June 2024

HR Manager

June 2024

HR Manager

December 2024

HR Manager

June 2024

HR Manager

19

Reconciliation Action Plan

Our Action Plan

Respect Respect and recognition are foundational to our business. We aspire to embed deep cultural knowledge in our team members, too - so we all understand the histories, cultures, customs and beliefs of Aboriginal and Torres Strait Islander peoples.

20

Opening Ceremony at ECQ XL - Stage 2 NSW

2023 - 2025

Action

1. Increase understanding, value and recognition of Aboriginal and Torres Strait Islander cultures, histories, knowledge, and rights through cultural learning.

2. Demonstrate respect to Aboriginal and Torres Strait Islander peoples by observing cultural protocols.

3. Build respect for Aboriginal and Torres Strait Islander cultures and histories by celebrating NAIDOC Week.

Deliverable

Timeline

Responsibility

Develop a cultural development document for increasing understanding, value and recognition of Aboriginal and Torres Strait Islander cultures, histories, knowledge, and rights within our organisation.

October 2024

HR Manager

Smoking Ceremonies to be conducted for new projects

July 2024

HR Manager

Introduce cultural training

February 2024

HR Manager

Conduct a review of cultural learning needs within our organisation.

December 2024

HR Manager

December 2024

HR Manager

April 2024

HR Manager

July 2024

Brand Marketing Manager

June 2024

Brand Marketing Manager

First week in July 2024

Brand Marketing Manager

Develop an understanding of the local Traditional Owners or Custodians of the lands and waters within our organisation’s operational area.

Increase staff’s understanding of the purpose and significance behind community and cultural protocols, including Acknowledgement of Country and Welcome to Country protocols.

Raise awareness and share information amongst our staff about the meaning of NAIDOC Week.

Introduce our staff to NAIDOC Week by promoting external events in our local area.

RAP Working Group and other staff to participate in an external NAIDOC Week event.

21

Reconciliation Action Plan

Our Action Plan

Opportunities By deepening relationships with Aboriginal and Torres Strait Islander peoples, we strive to improve economic, employment and educational outcomes with these communities.

22

Richmond Quarter smoking ceremony

2023 - 2025

Action

1. Improve employment outcomes by increasing Aboriginal and Torres Strait Islander recruitment, retention and professional development.

2. Increase Aboriginal and Torres Strait Islander supplier diversity to support improved economic and social outcomes.

Deliverable Research effective employment and retention strategies in similar organisations to understand best practice for our future employment and retention strategy.

Build understanding of current Aboriginal and Torres Strait Islander staffing to inform future employment and professional development opportunities.

Research effective procurement strategies in similar organisations to understand best practice for our future First Nations procurement strategy.

Investigate Supply Nation and Kinaway membership.

Timeline

Responsibility

December 2024

Talent Acquisition Coordinator

December 2024

Talent Acquisition Coordinator

December 2024

HR Manager

October 2024

HR Manager/ Procurement Manager

23

Reconciliation Action Plan

Our Action Plan

Governance Our consultation and governance processes are both rigorous and authentic. We will continue to develop them to inform and guide us as we put our RAP into action.

24

Opening Ceremony at ECQ XL - Stage 2 NSW

2023 - 2025

Action

1. Establish and maintain an effective RAP Working Group (RWG) to drive governance of the RAP.

2. Provide appropriate support for effective implementation of RAP commitments.

3. Build accountability and transparency through reporting RAP achievements, challenges and learnings both internally and externally.

4. Continue our reconciliation journey by developing our next RAP.

Deliverable

Timeline

Responsibility

Maintain a RWG to govern RAP implementation.

May 2024

HR Manager

Review and update Terms of Reference for the RWG.

June 2024

HR Manager

Maintain and strengthen Aboriginal and Torres Strait Islander representation on the RWG.

May 2024

HR Manager

Continue to review resource needs for RAP implementation.

February 2024

HR Manager

Continue to engage senior leaders in the delivery of RAP commitments.

May 2024

HR Manager

May 2024

HR Manager

November 2023

Brand Marketing Manager

June annually

HR Manager

1 August annually

HR Manager

30 September, annually

HR Manager

March 2025

HR Manager

Review the progress of our senior appointed RAP Champion and their internal engagement.

Define appropriate systems and capability to track, measure and report on RAP commitments.

Contact Reconciliation Australia to verify that our primary and secondary contact details are up to date, to ensure we do not miss out on important RAP correspondence.

Contact Reconciliation Australia to request our unique link, to access the online RAP Impact Measurement Questionnaire.

Complete and submit the annual RAP Impact Measurement Questionnaire to Reconciliation Australia.

Register via Reconciliation Australia’s website to begin developing our next RAP.

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Reconciliation Action Plan

Contact Details For enquiries about our RAP please contact Claire Wall, HR Manager Email: Cwall@hacer.com.au Phone: +61 3 9810 6888

26

2023 - 2025

27

EHSQ Systems & Certifications

Workplace Diversity Policy

WORKPLACE DIVERSITY POLICY INTRODUCTION This policy applies to all Hacer People; internal employees, on-hire employees, independent contractors, volunteers, or visitors entering a Hacer worksite.

At Hacer, we are committed to providing all Employees with a workplace culture that builds respect, fosters inclusiveness, promotes diversity and embraces the unique skills and qualities of all our Employees.

Our aim is to manage workplace diversity by recognising and embracing the diversity each Employee brings to our workplace; and creating an environment built on trust, mutual respect and appreciation. Setting these foundations enables us to fully benefit from the significant skills and talent that exists within our workforce.

EXPECTATIONS Managers: • • • •

Ensure all new and current Employees, contractors and volunteers are familiar with this policy.

Lead by example and ensure that each Employee’s performance, capability and potential is assessed fairly, providing opportunities that allow individuals to reach their full potential irrespective of individual background or differences.

Promptly deal with any complaints of breaches of the policy.

Support a culture which upholds our company values and the integrity and good reputation of our business.

Employees: • • •

Familiarise yourself with this policy and understand company expectations.

Treat Employees, Clients, Contractors, Visitors and Volunteers with fairness, irrespective of individual backgrounds or differences.

Behave at all times, in a way that upholds our company values and the integrity and good reputation of our business.

POLICY •

Workplace diversity is about developing strategies that recognise and accommodate differences in backgrounds, perspectives and family responsibilities of our workforce.

•

The concept of workplace diversity retains the principles of Equal Employment Opportunity (EEO). EEO addresses continued disadvantage experienced by particular groups of people in the workplace, including women, Indigenous Australians, people with disabilities and those who suffer disadvantage on the basis of race or ethnicity.

•

Workplace diversity principles should be incorporated into all aspects of our business e.g. workforce planning, recruitment and selection, performance management, learning and development, leadership development, workplace health and safety and workplace relations.

•

Hacer is committed to the principles of workplace diversity and equity in our workplace, which includes but is not limited to recognising, respecting and valuing individual differences, such as: o gender o age o language o ethnicity o cultural background o disability Page 1 of 3

EHSQ Systems & Certifications

Workplace Diversity Policy

o o o

sexual orientation religious beliefs family responsibilities

•

Diversity also refers to other ways in which people are different, such as: o educational level o life experience o work experience o marital status o socio-economic background o personality

•

Employees should be rewarded and promoted based on individual merit through assessments on performance, capability and potential.

•

At Hacer we will continue to provide opportunities that allow Employees to reach their full potential irrespective of individual background or difference.

PROCESS •

We will achieve a workplace culture that embraces diversity through the following actions and objectives: o

Leaders at all levels within the organisation should actively encourage and promote workplace diversity.

o

Recruitment & Selection: ▪ Employees and those seeking employment with Hacer are treated without bias in accessing employment opportunities and in the selection processes.

▪ Creating a workforce that mirrors the diversity in our community e.g. women, indigenous Employees, Employees with a disability, younger Employees, mature aged Employees. Refer to the Recruitment & Selection Policy for further information.

▪ Embedding diversity initiatives into our broader talent management processes in order to support the development of all talent, and to increase the representation of women across the business.

o

Integrate workplace diversity principles into the performance management process. For example: ▪ Identifying specific career development needs and supporting development opportunities for diversity groups.

▪ Continuing to create programs that prepare women to take on senior roles within the business, both in operational and specialist support areas.

▪ Being aware of issues for Employees with disabilities when relocation is being considered.

RESPONSIBILITIES All Hacer People REFERENCES Recruitment and Selection Policy Respect@Work Act 2022

Page 2 of 3

EHSQ Systems & Certifications

Workplace Diversity Policy

FURTHER INFORMATION For further information about our leave policy or related issues, please contact: • Human Resources Manager • Your immediate Line Manager • Your Construction Manager/Director;

Signed: Name:

Mark Lewis Director

Date:

July 2023

Page 3 of 3

Gender Pay Gap Statement 2024 | HACER Group

Our commitment and approach to achieving gender quality Gender Pay Gap Statement

That’s why we made gender diversity a strategic imperative in 2020 – with the launch of our first Gender Diversity and Equality Strategy.

By actively challenging entrenched perceptions of the construction industry, we’re not only shaping a more equitable industry, we’re paving the way for a more diverse and inclusive future.

Hacer’s Gender Diversity and Equality Strategy is underpinned by our commitment to social and industry responsibility. It takes the long view. And recognises that when it comes to closing the gender pay gap, sustainable change is more important than short-term, short-lived wins.

At Hacer, we know the value of diversity in all its forms.

This year’s gender pay gap data from the Workplace Gender Equality Agency (WGEA) tells us we still have a long way to go. But we’re committed to staying the course, delivering enduring changes that will encourage women to enter construction – and stay.

At its core, it brings a variety of perspectives to our workplace. Perspectives that enrich our team culture and morale – bolstering productivity, innovation and our competitiveness as a business.

But we also know we’re operating in an industry clouded by stereotypes of male dominance, which have very real consequences on our sector’s ability to attract and retain women. Ultimately, this contributes to a wide gender pay gap.

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2024 Gender Pay Gap Statement | 3

A note about the gender pay gap and equal pay Gender Pay Gap Statement

Our gender pay gap Gender Pay Gap Statement

The gender pay gap is not the same as equal pay.

The WGEA uses two measures to quantify Hacer’s gender pay gap:

Equal pay is where women and men are paid the same for performing the same role or different work of equal or comparable value.

1. Average remuneration

Hacer does not have any pay parity gaps.

Gender pay gaps are not a comparison of like roles. Instead, they show the difference between the average or median pay of women and men across organisations, industries and the workforce as a whole.

2. Median remuneration (the middle figure in our list of remuneration values)

The results show that Hacer’s average total remuneration gender pay gap is 35.1%, and the median is 38.4%.

To put that into context, this is slightly higher than the industry average: the total remuneration gender pay gap of the Industry Comparison Group is 30.8%, and the median is 36.7%.

While challenging to confront, these figures are not a surprise to us at Hacer.

In fact, they are the reason we self-initiated and implemented the Hacer Gender Diversity and Equality Strategy in 2020.

As a result, we’ve achieved some wins in our mission to reduce gender inequality in our organisation, including a rise in the number of women employed, from 7% in FY18/19 to 23% in FY22/23.

But there is still a long way to go, which is why we remain committed to: • Lifting the average tenure of women in our business • Increasing the percentage of women in our upper and upper middle pay quartiles

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2024 Gender Pay Gap Statement | 5

Our gender pay gap Gender Pay Gap Statement

Drivers of our gender pay gap Gender Pay Gap Statement

Shifting our attention to the top

Our gender pay gap reflects a complex interplay of historical, societal and industry-specific factors, like:

To get a clearer picture of where we’re closing our gender pay gap – and where we need to focus our efforts – it helps to break down our gender pay gap data by roles.

• Entrenched stereotypes that, historically, have led to disproportionate numbers of men to women in leadership and higher-paying positions

The below data set shows that while reducing our gender pay gap at the managerial level needs more attention, our gender pay gap is well below the industry average at the professional, clerical and administrative levels.

• Limited awareness or implementation of gender- equitable policies and practices

Managers Hacer Gender Pay Gap 2022–2023

Industry Comparison Group Gender Pay Gap 2022–2023

All managers

33.5%

22.4%

Other executives/general managers

41.7%

24%

Senior managers

35%

14.8%

Other managers

32.1%

25.1%

Hacer Gender Pay Gap 2022–2023

Industry Comparison Group Gender Pay Gap 2022–2023

Overall non-managers

33.3%

27.4%

Professionals

18%

22.4%

-14.06%

15.5%

Role

Together, these factors created an industry that struggled to attract and retain women over the years, leading to fewer female professionals in higherpaying positions – or available to be recruited into executive roles.

Non-managers Role

Clerical and Administrative

This also means fewer female role models to help young women envisage themselves as construction professionals. And this perpetuates the gender pay gap.

• Inflexible construction site schedules that hinder capacity for flexible work roles that fit around family commitments ` • Limited exposure at the high school level to STEM as a career path for girls

At Hacer, our gender pay gap is largely driven by these historical factors. We have a low number of women represented in our upper and upper middle pay quartiles. And we have an imbalance in the number of women and men employed part-time, with women making up 88% of parttime employees.

We’ve come a long way, both as a business and as an industry. And the early results from the implementation of our Gender Diversity and Equality Strategy (discussed in the next section) show that. But there’s still a long way to go. We remain committed to being part of the change.

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2024 Gender Pay Gap Statement | 7

Our plan to address our gender pay gap Gender Pay Gap Statement

At Hacer, we’ve been actively tackling our gender pay gap since 2020 with the release of our Gender Diversity and Equality Strategy.

The strategy recognises that addressing our gender pay gap requires a multifaceted approach. Therefore, it includes initiatives to: •

Foster a more inclusive and diverse workplace culture

•

Promote equal opportunities for career advancement

•

Actively work at the grassroots level to attract more women into the industry

With that said, the strategy has empowered us to initiate a series of significant short-term wins, including: • Shifting to gender-neutral titles like ‘foreperson’ instead of ‘foreman’ • Introducing gender-specific work gear to give women more comfortable clothing options • A partnership with Our Watch Institute, Australia’s leading team of violence prevention and gender equality experts, to educate our employees on embedding gender equality at work – and prevent violence against women in the workplace and community

We know that competition for female talent at the executive and managerial levels will remain fierce for some time. This makes it difficult to achieve dramatic shifts in representation on our executive level in the short term.

So the strategy sets our sights firmly on the future, investing heavily in initiatives targeted at high school and tertiary students.

• Introducing Well™ – an education platform for promoting psychological safety in the workplace • A partnership with RMIT to provide female students with a scholarship and a guaranteed place in our graduate program • Introducing paid parental leave for primary and secondary carers • Introducing six months of paid superannuation for primary carers • Introducing flexible working conditions for returning primary carers – which was taken up by 100% of eligible staff While all significant, the changes to parental leave were incredibly successful – resulting in a 100% return rate for those who went on parental leave.

The current strategy is set for renewal in 2027. It will drive any further opportunities to reduce our gender pay gap following the release of this latest dataset.

Our goal is to build a sustainable pipeline of female talent over the next 5 to 10 years.

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2024 Gender Pay Gap Statement | 9

Our plan to address our gender pay gap Gender Pay Gap Statement

This Statement was approved by the Hacer Board of Directors in February 2024.

Closing the gender pay gap within our business, and the construction industry more broadly, is no easy feat.

But we’re committed to being part of the shift so that we can help build a more equal and attractive industry.

Paul Toleman

Mark Lewis

Vin Sammartino

Hacer Group Victoria 222 High Street Kew, VIC 3101 T +61 3 9810 6888 New South Wales Level 6, 55 Miller Street Pyrmont, NSW 2009 T +61 2 8570 1300 hacer.com.au @hacergroup

10 | HACER Group