Which businesses must report under the Modern Slavery Act?

Entities with annual consolidated revenue of $100 million or more must submit a Modern Slavery Statement. The Australian Government must also report. Entities below the threshold can report voluntarily. The threshold is assessed at the consolidated group level, so subsidiaries of large groups may be captured.

What are the penalties for non-compliance with the Modern Slavery Act?

Currently, there are no financial penalties under the Act. The government relies on a "comply or explain" approach with the power to publicly name non-compliant entities. However, the Act is under review and the introduction of financial penalties is being actively considered, as recommended by the statutory review.

How do you identify modern slavery risks in supply chains?

Key approaches include mapping supply chains to identify high-risk geographies and industries, conducting supplier questionnaires and audits, monitoring media and NGO reports, using risk assessment tools that consider country, sector, and product-level risks, and engaging with workers and communities in supply chain locations.

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Modern Slavery Compliance

Also known as:modern slavery reportingslavery complianceethical supply chain compliance

Obligations under the Modern Slavery Act 2018 (Cth) requiring large businesses to report on modern slavery risks in their operations and supply chains and actions taken to address those risks.

In-Depth Explanation

Modern slavery compliance in Australia is governed by the Modern Slavery Act 2018 (Cth), which requires entities meeting certain thresholds to publish annual Modern Slavery Statements detailing their efforts to identify and address modern slavery risks.

Key obligations:

Reporting threshold: Entities with annual consolidated revenue of $100 million or more
Voluntary reporting: Available for entities below the threshold
Reporting period: Statements must be published within six months of the end of the reporting period
Mandatory criteria: Statements must address seven specific criteria set out in the Act

The seven mandatory reporting criteria:

Identify the reporting entity: Structure, operations, and supply chains
Describe operations and supply chains: Including subsidiaries and overseas operations
Identify risks: Modern slavery risks in operations and supply chains
Describe actions: Steps taken to assess and address identified risks
Assess effectiveness: How the entity assesses the effectiveness of its actions
Consultation process: How the entity consulted with owned or controlled entities
Other relevant information: Any additional information the entity considers relevant

Forms of modern slavery include:

Trafficking in persons
Slavery and slavery-like practices (servitude, forced labour, forced marriage, debt bondage)
The worst forms of child labour
Deceptive recruiting for labour or services

The Act is currently under review, with potential amendments including financial penalties for non-compliance, an Anti-Slavery Commissioner, and lowering the reporting threshold.

Business Context

Businesses must address modern slavery risks in their supply chains to meet legal obligations, protect their reputation, and respond to growing stakeholder expectations around ethical sourcing.

How Clever Ops Uses This

Clever Ops helps Australian businesses automate modern slavery risk assessment across their supply chains. We build supplier due diligence questionnaires, risk-scoring frameworks, and statement preparation workflows that streamline compliance with the Modern Slavery Act.

Example Use Case

"A retail company automates supplier risk assessments using questionnaires and third-party data to identify and prioritise modern slavery risks across its multi-tier supply chain."