Aristocrat recognises the obligation and opportunity we have to contribute to ethical practices through our global supply chain. This extends to the way we work with our suppliers, and encourage them to operate in a manner that meets appropriate ethical, environmental, community and societal standards.

We take an active and collaborative approach with our suppliers, and seek to help them identify, mitigate and resolve potential ethical sourcing risks in their supply chains.


To ensure our standards are met, and with a view to continuous improvement in the way we work with our suppliers, in 2019 we begun updating our supply chain contracts to require suppliers to comply with all applicable Modern Slavery, Conflict Minerals and related laws. Contracts are being updated on a priority basis, with supplier criticality and contract duration being key considerations. We are planning to have all current and new supplier agreements updated within 2-3 years. During 2019, we issued four new supplier agreements incorporating the updated provisions, and audits are being conducted of the balance of our existing top 30 suppliers to ensure these contain the required provisions.

An Aristocrat Supplier Code of Conduct is also under development, and is intended to provide further guidance and clearly set expectations for our suppliers.

The Supplier Code of Conduct will capture our ethical sourcing principles and reinforce our commitment to conducting business with the highest levels of integrity and in compliance with both the letter and spirit of all applicable laws and expectations. Aristocrat’s Supplier Code of Conduct will require suppliers to:

  • Operate in manner which is not unethical or compromising;
  • Not enter into any agreements that reduce competition;
  • Not enter into any agreements that impose resale or pricing on resale;
  • Refuse money, cash equivalents, gifts of more than nominal value, excessive hospitality, loans, or other special treatment from present or prospective suppliers that might influence, or appear to influence, business or purchasing decisions;
  • Comply with all applicable laws and regulations in the countries in which they operate, including in terms of human rights, modern slavery and conflict minerals.


Aristocrat complies with all applicable Conflict Minerals regulations, including the US Dodd Frank Act (Section 1502), and the EU’s Regulation 2017/821 concerning minerals originating from conflict zones and high-risk areas. We require our suppliers to also:

  • Supply conflict free materials and products;
  • Respond to requests for information on sources of supply; and
  • Perform due diligence on their own suppliers and sources of materials for products to be supplied to Aristocrat.


Aristocrat requires key suppliers to take steps and provide periodic self-assessments to ensure human rights violations are not occurring within their operations. We will also require completion of a Modern Slavery Survey during 2020 by all key suppliers. The survey is aimed at ensuring suppliers:

    • Maintain policies and procedures to safeguard key human rights, including freedom from discrimination, child and forced labour;
    • Treat their employees and contractors with dignity and respect and
    • Provide safe working conditions, reasonable working hours and fair remuneration.

Read our UK Modern Slavery Statement

Audits of responses to supplier self-assessments are conducted by Aristocrat’s internal Global Strategic Sourcing (GSS) team.


An Ethical Sourcing training course is under development, and will be deployed to all employees working in our global supply chain and procurement functions during 2020. The course is tailored to our business, and aims to educate and upskill our employees to understand our ethical sourcing obligations and commitments, as well as to partner with and assess suppliers effectively to drive improvements.