Woolworths Group (ASX:WOW) operates within Australia’s mandatory Food and Grocery Code of Conduct, which establishes requirements governing relationships between large grocery businesses and their suppliers.

Supplier pricing negotiations, range reviews, product delisting and dispute-resolution procedures are among the areas covered by the Code. Woolworths’ FY2026 Code Mediator report also provides information on supplier interactions during the year, including matters involving range reviews, pricing requests and delisting decisions.

Supplier Matters

During FY2026, Woolworths’ independent Code Mediator was contacted by 28 suppliers seeking information about matters covered by the Code.

The topics raised included Woolworths’ obligation to deal with suppliers lawfully and in good faith, grocery Supply agreements, range reviews, delisting decisions, supplier cost-price increase requests, promotional arrangements and fresh-produce negotiations.

The Code Mediator also assisted with the informal resolution of matters involving range reviews, delisting decisions, cost-price increase requests and promotional pricing proposals.

The report does not establish that these interactions represented breaches of the Code. It recorded one formal complaint for investigation during FY2026 relating to a fresh-produce sourcing review. The investigation had not been completed by the end of the reporting period.

Mandatory Grocery Code

The remade Food and Grocery Code of Conduct came into effect on 1 April 2025 and is mandatory for large grocery businesses, including Woolworths.

Transitional arrangements initially applied to some grocery supply agreements entered into before the new Code commenced. That transition period ended on 1 April 2026, meaning the Code’s requirements now apply to grocery supply agreements regardless of when they were entered into. (ACCC)

The Code requires large grocery businesses to deal with suppliers lawfully and in good faith and establishes rules covering supply agreements, price negotiations, range reviews, delisting, payments and dispute resolution. Breaches of relevant provisions can result in civil penalties. (Federal Register of Legislation)

Product Delisting

The Code establishes specific requirements for removing a supplier’s products from a retailer’s range.

A large grocery Business may delist a product only in accordance with its grocery supply agreement and for genuine commercial reasons. Such reasons can include failure to meet agreed quality or quantity requirements, sales or profitability targets contained in the agreement, or persistent failure to meet delivery requirements.

Before a product is delisted, suppliers generally must receive reasonable written notice explaining the commercial reasons for the decision. The notice must also provide information about available review and complaint procedures. (ACCC)

Large grocery businesses must also provide suppliers affected by a range review with information about the purpose and criteria of the review and give affected suppliers a reasonable opportunity to discuss its outcome. (ACCC)

Supplier Price Negotiations

Supplier pricing is another area governed by the Code. Large grocery businesses are subject to requirements for responding to supplier requests for cost-price increases and conducting negotiations.

Woolworths reported 2,395 reportable notifications relating to supplier price increases during FY2026. Of these, 867 progressed to further negotiations after the initial response. Four initial responses were provided outside the prescribed 30-day period.

The report also showed that 637 of the 867 negotiations requiring further discussions took longer than 30 days to conclude, including negotiations that remained ongoing at the end of the reporting period. These figures describe the duration of the negotiation process and do not by themselves establish non-compliance.

Supplier Dispute Processes

The Code requires large grocery businesses to appoint a Code Mediator who can assist suppliers with complaints and disputes.

Woolworths identifies its Code Mediator as an independent channel through which suppliers can raise formal or informal concerns. The company also maintains processes allowing trade partners to raise issues directly and states that it has a zero-retribution policy covering suppliers exercising their rights under the Code. (Woolworths Group)

During FY2026, the Woolworths Code Mediator reported that some supplier matters were resolved informally through measures such as reviews of delisting decisions, adjustments to range-review outcomes and discussions between Woolworths and suppliers.

Additional Pricing Rules

Australia’s grocery regulatory framework was expanded again from 1 July 2026. Under amendments to the Food and Grocery Code, very large retailers, currently including Woolworths, are prohibited from engaging in excessive pricing of grocery products for retail sale.

The ACCC is responsible for enforcing the Food and Grocery Code, including the excessive-pricing provisions. (ACCC)

The framework therefore covers both Woolworths’ dealings with grocery suppliers and specified requirements applying to retail pricing practices.

Supplier Framework

Woolworths continues to conduct supplier pricing negotiations and product range reviews within the requirements of the mandatory Food and Grocery Code.

Official FY2026 reporting shows that suppliers contacted the company’s Code Mediator on matters including range reviews, delisting, price negotiations and other commercial arrangements. It also records processes used to address some concerns informally.

The available official material does not establish a general finding that Woolworths breached the Code in relation to these supplier matters.