In 2018, the Commonwealth Modern Slavery Act was established. The passing of this legislation added Australia to a list of countries determined to mitigate modern day slavery in supply chains.

Modern Slavery Overview

The United Nations (UN) and Walk Free Foundation estimate there are approximately 40 million victims of modern day slavery around the globe, and 16 million victims are exploited through private economy supply chains.

The term modern slavery is an umbrella term that encompasses various human rights problems. Human trafficking, forced labor, child slavery, and bonded labor are some of the most pervasive modern day slavery abuses that are found in supply chains.

Commonwealth Modern Slavery Act

Much like the UK Modern Slavery Act and California SB 657, the Commonwealth Modern Slavery Act was created to mitigate modern slavery being present in the supply chains of companies doing business in Australia – here’s an overview of the legislation:

  • The act applies to approximately 3,000 entities in Australia. These entities have to prepare an annual modern day slavery statement that outlines their due diligence efforts for modern day slavery risk mitigation.
  • The statement must be approved by the board of directors of a company, and signed by a board member.
  • Companies who log AU$100 million in fiscal year revenue are in-scope of the regulation and have to submit an annual statement.
  • The statement must include seven different elements:
    1. Company identification
    2. Company structure, operations and supply chain
    3. Summarize any associated risks with the business structure, operations and supply chain
    4. Summarize due diligence efforts around assessing supply chain and uncovering risk
    5. Summarize the process behind due diligence and whether or not it is effective
    6. Summarize communication with any partners, subsidiaries or other companies connected with the principle company
    7. Additional relevant information
  • Companies must provide a modern day slavery statement to the Australian government for publication on a centralized website.

The Australian government also said it will review the Commonwealth Modern Slavery Act every three years to ensure effectiveness. More details can be found here.

How to Implement a Modern Slavery Supply Chain Assessment

In short, ask the right questions. Global organizations and special interest groups have created “de facto” standards around human rights measurements that are included in regulations and followed by the world’s largest brands. The International Labor Organization (ILO) and the Organization for Economic Co-operation and Development (OECD) are two of the most prominent thought leaders in the space and have created globalized frameworks for workers rights and enterprise supply chain due diligence.

Each group has an extensive set of criteria they consider critical, but there are a few commonalities within each group’s focus areas. Here are 5 broad elements to be included in human rights assessments:

  1. Worker Compensation
  2. Worker Restrictions
  3. Workplace Safety
  4. Child Labor and Womens Rights
  5. Company Policies

Click here to see detailed information for each of the 5 elements.

Keep in mind – this is a brief overview and a strong human rights due diligence program goes in depth on each one of the following topics. The Corporate Human Rights Benchmark Limited (CHRB Ltd.) recently published a 2018 key findings report on human rights in multinational enterprise supply chains, which goes into detail on the following areas. Click here to view the report.

Modern Slavery in supply chains resources

The above are all elements of a rigorous human rights program. By no means are they the only measurable elements, and each element described above can go further into detail.

They are, however, starting points. If you’d like to learn more, follow the resources below to learn about the deployment of assessments, data collection best practices, risk frameworks, and reporting on your findings.

How to: Design an ethical sourcing risk management program

Anti-Human Trafficking 101: How to minimize risk

Compliance Program: WhistleBlower hotline

Cloud-based Risk Management: Desktop assessments

Compliance Program: Anti-human trafficking

Supplier Data Management: Source Intelligence Platform

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