The Australian Modern Slavery Act 2018
The Australian Modern Slavery Act 2018 requires many companies to conduct due diligence of their supply chains for modern slavery. Companies subject to the Act are required to submit a modern slavery statement to the Australian Border Force.
The Modern Slavery Act 2018 has established Australia’s national Modern Slavery Reporting Requirement. Reporting is due by December 2020.
If you have a minimum annual consolidated revenue of $100 million your company qualifies under the Act as a reporting entity and you need to prepare a report and Modern Slavery statement. Covering the following:
- Identify the reporting entity then:
- Describe the reporting entity’s structure, operations, and supply chains
- Describe the risks of modern slavery practices in the operations and supply chains of the reporting entity and any entities it owns or controls
- Describe the actions taken by the reporting entity and any entities it owns or controls to assess and address these risks, including due diligence and remediation processes
- Describe how the reporting entity assesses the effectiveness of these actions
- Describe the process of consultation with any entities the reporting entity owns or controls (a joint statement must also describe consultation with the entity giving the statement), and
- Provide any other relevant information.
But there is more than just reporting. Companies need to develop a due diligence system and show how they will mitigate any identified risk. They need continually review and update the system especially if things change.
Finally, The Act aims to drive continuous improvement from reporting entities over time. You may need advice on ongoing activities that will help your company meet this requirement for continual improvement. All of this points towards a documented management system approach.