Modern Slavery Statement
At Eucalyptus, we believe everyone deserves access to good healthcare to last a lifetime, whether you’re in a city, regional town or the other side of the world. As part of this mission, we strive to create a safe working environment for all of our staff and to work with suppliers that demonstrate a similar commitment to the prevention of modern slavery in supply chains globally.
Eucalyptus does not condone any form of modern slavery in our operations. We recognise that addressing modern slavery does not only mean the prevention of the exploitation of our direct employees but also addressing the potential risk to our extended workforce and those of our suppliers in providing the products and services that we procure for our business operations. This statement serves to outline the modern slavery risks we have identified within our business operations and supply chain in the region and the initiatives we are seeking or otherwise planning to implement in order to minimise such risks.
This Statement is published by Euc Management Pty Ltd ABN 54 631 013 860 (“Euc”) in accordance with section 54 (Transparency in Supply Chains) of the Modern Slavery Act 2015 (UK) (the “UK Act”) and section 14 of the Modern Slavery Act 2018 (Cth) (the “AU Act”) (the UK Act and AU Act together, the “Acts”). For the purposes of this Statement, Eucalyptus Group or Eucalyptus refers to Euc and its wholly owned and controlled subsidiaries, including those listed on the following page.
This Statement and its findings were approved by the Board of the Eucalyptus Group on 24 December 2024 for the purposes of the Acts with respect to the financial year ending 30 June 2024 (“Financial Year”) and is signed by the Chief Executive Officer, who is also a member of the Board.
Tim Doyle
Director
Euc Management Pty Ltd
Disclosure
This is a joint statement made on behalf of itself and each Australian reporting entity (listed below), as defined in section 5 of the AU Act:
This Statement also fulfils the requirements of section 54 of the UK Act, and has been prepared and published on behalf of:
About Eucalyptus
Eucalyptus has operated in Australia since 2019. We engage over 400 people across our operations, each of whom proudly delivers on our mission to “Make good health last a lifetime”. Eucalyptus has serviced over 1 million people through practitioner consultations as of this Statement’s date. Entities have been incorporated in Australia, Germany, Japan, Ireland, the Netherlands and the UK.
Eucalyptus operates five digital health clinics in Australia. One of these clinics, Juniper, has operated in international markets since the launch of the clinic in the UK in 2022 and has since expanded operations into Germany and Japan in 2023. Juniper uses scientifically proven GLP-1 medications alongside ongoing health coaching, health tracking, clinical consultations and a dedicated support team to deliver a new and highly effective method of weight management.
STRUCTURE
The reporting entity for this Statement is Euc Management Pty Ltd (ABN 54 631 013 860), the parent company of the Eucalyptus Group. This Statement forms our second report submitted under the UK Act and our first report submitted under the AU Act.\
The Eucalyptus Group consists of several private entities for each digital health clinic and service companies supporting brand operations. With a global presence, Eucalyptus acknowledges the vital contributions we make to the communities we serve. This begins with an unwavering commitment to our employees, providing them with a workplace that is safe, fair and fulfilling. We are headquartered in Sydney, with further offices in London, Tokyo, Berlin and Manila.
Our Australian workforce consists of approximately 400 workers employed by Euc Services Pty Ltd and Euc Fulfilment Pty Ltd ACN 678 229 724). Fill Function Pty Ltd (ABN 644 566 174) and Euc Fulfilment Pty Ltd (ACN 678 229 724) are responsible for our retail and pharmacy-related operations in Australia. Fill Function UK Ltd (CN 13739688) employs approximately 80 workers across the UK business, forming the second largest market.
CONSULTATION WITH ENTITIES OWNED AND CONTROLLED
Consultation between the parent company Eucalyptus and its subsidiaries and affiliates in the preparation of this Statement took place via the Board and shared Eucalyptus Group resources. Eucalyptus considers it reasonable and appropriate as the parent company to provide this joint statement on behalf of all reporting entities in the Eucalyptus Group as they are wholly owned subsidiaries, including a consolidated description of their actions to address modern slavery risks.
SUPPLY CHAIN AND OPERATIONS
In order to resource the many areas of our business, our direct supply chain consists of a range of businesses and partners, who enable our services with a pharmaceutical distribution network, office supplies, food and beverages and information and communication technology (ICT) hardware and software.
The key supply component of our Australian and UK operations is the procurement and delivery of GLP-1 prescription medications and related goods (including packaging, sharp bins and needles) to patients from our associate pharmacies.
Risks of Modern Slavery and Actions Taken
Eucalyptus is committed to identifying possible instances of modern slavery within our operations and supply chains and managing these risks. The majority of our operations take place in countries with a low inherent risk of human rights violations and modern slavery, and we reinforce this commitment through rigorous monitoring and auditing of our practices. While we have not been made aware of any specific concerns relating to modern slavery in our operations or supply chains, nor have we received any whistleblower reports on modern slavery risks during the 2023/2024 financial year, we recognise the need for the company to remain vigilant.
In assessing the modern slavery risks across our business in the financial year, we have focused on (A) risks to internal staff and (B) risks through our external supply chain. We have also considered the key risk indicators identified in the International Labour Organisation’s report on modern slavery.
A. INTERNAL STAFF
1 This report considers sectors in which modern slavery has been found to take place, including high-risk industries and work practices. According to the report, services (excluding domestic work) and manufacturing sectors account for two largest shares of adult forced labour exploitation. Global Estimates of Modern Slavery: Forced Labour and Forced Marriage Report 2022. International Labour Organisation: https://www.ilo.org/wcmsp5/groups/public/@ed_norm/@ipec/documents/publication/wcms_854733.pdf
a. Risks
We appreciate that a failure to educate employees on such procedures and policies, and/or empower them to utilise such policies and procedures without fear of adverse consequences, can result in inconsistency in supplier engagements and failure to escalate identified modern slavery risks. Our Global Whistleblower Policy supports transparency by encouraging employees and stakeholders to report any concerns regarding sub-standard employment practices, human rights violations, or modern slavery. All team members on-boarded are provided guidance on our policies and procedures, maintaining access to these policies at all times through their company accounts within our internal HR software. To date, no such reports have been received, reflecting our ongoing commitment to upholding ethical standards across all levels of our operations.
Further, our dedicated People & Culture team monitor legislative and market changes to ensure all workers within the Eucalyptus Group are provided with entitlements in compliance with the law. Every 6 months, Eucalyptus Group performs a full review of salary and other remuneration benefits across all offices to ensure all staff are paid appropriately and are receiving their full entitlements. We will continue to monitor remuneration and working conditions on a regular basis.
b. Policies
Below is a summary of Eucalyptus’ policies that operate to manage risks in our business, including modern slavery:
B. EXTERNAL SUPPLY CHAIN
a. Risks
The Eucalyptus Group’s top suppliers of medications and related goods are reputable companies and we consider the risk of modern slavery in contracting with these top suppliers to be low. However, we recognise there is an inherent risk in the fact that we do not have full visibility over the practices of intermediaries and suppliers with whom we do not have a direct relationship within the supply chain process.
b. Due Diligence Controls
In 2023-2024, the Eucalyptus Group has continued to apply diligence processes for assessing our suppliers. Controls have included undertaking site visits, reviewing contract terms for modern slavery obligations and conducting test orders. During these site visits, a supplier may be requested to provide documentation on adherence to labour law, regarding hours, wages and overtime. Enquiries may be made as to grievance mechanisms for workers as well as measures to ensure ethical sourcing of materials and components. These processes are designed to assess the legitimacy and professionalism of the supplier and intervene when risks are identified.
Assessing the Effectiveness of Actions
While we are taking proactive steps to assess and address modern slavery risks going forward, ongoing monitoring on a risk-based approach has taken place within our broader governance framework throughout the reporting period. In this financial year, we did not become aware of any incidents or concerns relating to modern slavery or forced labour.
- No reports were made under the Whistleblower or Grievance policies with respect to modern slavery and/or human trafficking.
- No remedial actions were required in the last 12 months.
As we look to future reporting periods, further investment in this space may include:
- standardising our supplier onboarding program across jurisdictions;
- developing processes for regular engagement with manufacturing partners and suppliers to discuss modern slavery risks;
- building on our existing work to gauge the effectiveness of our policies, processes and controls; and
- continuing to monitor modern slavery legislative developments and prepare for anticipated amendments to the AU Act.
We will continue to work with our suppliers to identify any risks, and should such risks be identified, they will be investigated appropriately. Should modern slavery risks be identified in our supply chain, appropriate remedial actions would be taken such as terminating engagement with the supplier and informing government authorities. We are committed to further developing our modern slavery governance to improve the identification and mitigation of these risks as our business matures across markets.