Modern slavery is a complex issue with serious consequences for the people involved. As a business owner, you have an obligation to ensure your supply chains do not engage with any forms of modern slavery. With the globalisation of modern supply chains, ensuring modern slavery is not part of your business can become extremely difficult as supply chains reach around the globe and back. This blog will look at ways you can minimise your business’s risk of engaging in modern slavery and the benefits of aligning your business with the Modern Slavery Act 2018.

What is the Modern Slavery Act 2018?

The Modern Slavery Act 2018 is a piece of Federal legislation requiring certain Australian entities to report on any risks of modern slavery within their supply chains and operations as well as the actions they’re taking to address those risks.

What is modern slavery?

Modern slavery is the serious exploitation of workers, distinct from other harmful practices such as underpayment of wages or substandard working conditions. Modern slavery can happen in any industry with serious consequences for the workers and entities involved.

Modern slavery practices include:

• Debt bondage
• Forced labour
• Forced marriage
• Human trafficking
• Slavery
• Servitude
• The worst forms of child labour

Every entity is responsible for ensuring its operations and supply chain remain free from all forms of modern slavery and mitigating any modern slavery risks associated with their business.

Modern slavery and supply chains

It’s not enough to avoid modern slavery practices in your own business operations. Under the Modern Slavery Act 2018, you are required to actively avoid modern slavery risks throughout your supply chain. Below are some simplified examples of modern slavery in supply chains.

Even in this simple example, it becomes clear that with so many moving parts modern slavery practices can easily slip through the cracks when enterprises don’t do their due diligence and examine every stage of the supply chain.

What are the modern slavery reporting requirements in Australia?

The Modern Slavery Act 2018 established a national Modern Slavery Reporting Requirement. Certain Australian entities and entities conducting business in Australia must publish Modern Slavery Statements annually under the requirement.

Who has to report under the Modern Slavery Act?

Every business or other entity on the Australian market which earns AUD$100 million or more in consolidated revenue annually must report under the Modern Slavery Act 2018 including Government agencies.

If my business earns less than 100 million do I still need to report under the modern slavery act?

You are not legally obliged to comply with the Modern Slavery Reporting Requirement if your business earns under AUD$100 million each year. However, you are expected to manage the risks of modern slavery in your operations and supply chain. Voluntary modern slavery statements can be submitted by any Australian entity or entity that carries out business in Australia regardless of annual earnings.

Modern Slavery Statements

Modern Slavery Statements describe the actions an entity is taking to assess and address risks of modern slavery within their supply chain and operations.

Why should I submit a Modern Slavery Statement?

Even if you’re not legally obliged to submit a Modern Slavery Statement there are a range of benefits to complying with the Modern Slavery Act 2018.

#1. Avoid damaging your reputation

You could currently be engaging in modern slavery practices without realising it. Once a business has been publicly associated with modern slavery the reputational damage can be difficult or even impossible to recover from. Being associated with any form of modern slavery can be extremely damaging to your reputation, even if the incident of slavery occurs far own your business’s supply chain. By preparing a Modern Slavery Statement you’ll identify risks of modern slavery in your supply chain and put in place strategies to mitigate those risks.

#2. Lower your risk of prosecution

While human trafficking and modern slavery prosecutions are thankfully rare in Australia with 20 modern slavery prosecutions laid from 2004 to 2017, the consequences of knowingly or unknowingly engaging in modern slavery can be severe. By complying with the Modern Slavery Act 2018 you’re giving your organisation the best chance of avoiding prosecution.

#3. Increase your attractiveness in tenders

A Modern Slavery Statement is a concrete way of proving your commitment to avoiding modern slavery in your operations and supply chain. Government departments are required to adhere to modern slavery requirements in all procurements. By preparing a modern slavery statement you’ll tick another box for government tenders and be more likely to win vital contracts.

Modern Slavery Statement examples

You can view over 2,000 modern slavery statements on the Australia Border Force’s modern slavery register.

Click to view sample statements from:

• Coles Group
• Qantas
• Suncorp Group

Modern Slavery Statements can include the following sections:

• Statement Overview
• Business Overview
• Operations
• Policies
• Modern Slavery Risks
  • banking
  • finance
  • wealth
  • investments
  • workforce
  • supply chain
• Actions taken to address risks
• Remediation
• Assessment of effectiveness
• Future commitments

How often do I need to report under the Modern Slavery Act 2018?

If you are required to report under the Modern Slavery Act you will need to provide a Modern Slavery Statement annually.

Will my Modern Slavery Reports be accessible to the public?

Yes. The Australian Government publishes every correctly submitted report on its modern slavery statements register. All statements may be accessed freely by the public. It’s important to note that the publication of your statement on the register does not automatically indicate compliance with the Modern Slavery Act 2018.

How to comply with the Modern Slavery Act 2018

By taking an intentional and structured approach to modern slavery prevention you can swiftly bring your enterprise into line with the Modern Slavery Act 2018.

Build internal support — provide the frameworks and staffing to address modern slavery risks. Support your company’s senior executives, engage all relevant departments including procurement, IT, HR and more, define your goals and create an action plan.

Conduct gap analysis — Review your current codes of conduct and policy documents to assess whether provisions are made for modern slavery risks.

Identify modern slavery risks — create a comprehensive map of your supply chain and identify modern slavery risks. Are there any categories in your company that are particularly high risk? Do you operate in any high-risk countries or within a high-risk industry?

Engage with contractors and suppliers — assess your suppliers and contractors to make sure they comply with your modern slavery requirements. Provide training and assessment where necessary.

Address modern slavery within your organisation — take a victim-centred approach to addressing modern slavery practices in your organisation and report them to the relevant authorities if required. In Australia, all modern slavery practices should be reported to the Australian Federal Police.

Assess actions — take stock of the impacts of your actions by performing a thorough analysis of your modern slavery preventative actions. You will need to put a thorough monitoring system in place to ensure your actions can be accurately measured and improved upon.

Provide solutions and remedies — implement grievance mechanisms such as anonymous whistleblower hotlines to ensure modern slavery in your company and supply chain can easily be identified and remedied.

Prevention — avoiding high-risk modern slavery practices is the safest and most effective way to stay compliant with the Modern Slavery Act 2018. By putting in place preventative measures your company will avoid having to deal with modern slavery practices.

How your quality management system can help with Modern Slavery Act compliance

Your quality management system can help streamline your company’s modern slavery risk identification and prevention processes. In the Mango HSEQ management system, for instance, the supplier management module provides practical supplier screening tools which can be used to ensure each of your suppliers has modern slavery policies in place.

Your company’s policies and procedures can also be updated and stored in Mango and made accessible to your entire company via the Mango app. Your employees can access training and documentation regarding your modern slavery policy to help ensure company-wide compliance.

Supply chain management is extremely complex, and keeping track of every supplier can become unwieldy without smart management technology in place. If you’re concerned about your current compliance with the Modern Slavery Act 2018 and need practical assistance to bring your company into line, we can help. Our experienced business consultants can provide you with tailored advice and solutions to help you achieve Modern Slavery Act Compliance.

Get in touch today to learn more about Mango and how it can assist in managing supply chain and operational modern slavery risks

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