top of page

Addressing Modern Slavery: A Business Imperative

Writer's picture: Carli DavisCarli Davis

The Modern Slavery Act 2018 is an Australian law that requires certain businesses to report on the risks of modern slavery in their operations and supply chains. The Act, which came into force in January 2019, aims to promote transparency and accountability in how companies address human rights abuses like forced labor and human trafficking. As modern slavery reporting requirements grow stricter, including the proposed penalties in the 2023 review of the Modern Slavery Act 2018, companies that fail to act risk significant legal and reputational damage​. 


Key Information

  • Companies with over AUD $100 million annual turnover must report on their efforts to mitigate modern slavery in their supply chains.

  • There are seven reporting requirements covering structure, operations, supply chains, risks, actions taken, effectiveness and consultation. 

  • As of 2023, over 10,000 mandatory reports and 683 voluntary reports have been submitted to the Modern Slavery Statements Register​.


The 2023 review of Australia’s Modern Slavery Act (2018) suggested significant updates:

  • Lowering the threshold for mandatory reporting from AUD 100 million to AUD 50 million.

  • Stronger enforcement: Introducing penalties for non-compliance, which were absent in the original Act.

  • Increased transparency: Enhanced reporting requirements, such as risk mitigation measures and supplier auditing.

  • Public registry: Improved monitoring and public accessibility to modern slavery reports.



What is needed across various sectors?

Agriculture sector

According to a 2021 report by the Walk Free Foundation, the agriculture sector is one of the top sectors in Australia identified with modern slavery risks due to the use of seasonal, migrant, and undocumented workers. What is needed?

  • Greater scrutiny on labour-hire practices, migrant worker protections, and working conditions across farms and plantations

  • Adequate staff training and worker contracts

  • Worker voice surveys, independent whistleblower hotlines, and effective grievance mechanisms


Retail sector

The retail sector deals with complex, global supply chains, which often include high-risk countries where forced labour is common. What is needed?

  • Supply chain mapping, stronger supplier audits, certifications, and collaborations with ethical sourcing programs

  • Fair pricing and payment terms

  • Staff and supplier training to build understanding

  • Safe reporting channels & remediation processes

  • Clear and simplified reporting


Clothing and textiles

67% of the clothing and textile imports into Australia come from countries with a high risk of forced labour, including Bangladesh, China, and Vietnam.  What is needed?

  • Supplier mapping, transparent labour conditions and production practices, work voice surveys

  • Reduction in audit fatigue through brand collaboration & industry certification programs

  • Investment into onshore manufacturing where the risk of modern slavery is far lower

  • Collaboration with NGOs


Compliance and beyond - why businesses must act against modern slavery

Compliance is not where it needs to be

  • A 2022 report by the Australian Government indicated that 77% of companies required to report had complied by submitting their modern slavery statements, yes there is minimal focus on remediation and few measurable outcomes

  • There are no financial penalties (yet) for failing to submit or poor-quality statements

Compliance can be costly

  • Complying with modern slavery reporting increases operational costs for businesses, as they invest in audits, supply chain mapping, and compliance programs

  • SEAOAK can help businesses on a budget navigate risk mapping, auditing, self-assessment questionnaires, work voice surveys, grievance mechanisms and reporting

Consumers are demanding ethically produced goods

  • A survey by Baptist World Aid Australia (2021) revealed that 81% of Australian consumers are concerned about modern slavery in the supply chains of the products they buy

  • 61% of Australian consumers indicated they would pay more for products that are guaranteed to be free from exploitation and modern slavery


How SEAOAK can support your business with modern slavery 

  • Risk Assessment and Supply Chain Mapping: Assist in identifying high-risk areas in supply chains via risk management and compliance software solutions.

  • Supplier Auditing and Management: Assist with audit policy development and supplier management.

  • Developing Due Diligence Frameworks: Help businesses build or enhance their due diligence systems, ensuring compliance with evolving regulations like Australia's Modern Slavery Act.

  • Training and Education: Provide tailored training programs to raise awareness among staff and suppliers about modern slavery risks.

  • Reporting Compliance: Guide businesses in preparing comprehensive Modern Slavery Statements, ensuring they meet legal reporting requirements.

  • Collaboration & Partnerships: Foster long-term partnerships with external stakeholders, NGOs, and industry bodies to strengthen ethical practices across industries.


Interested in understanding more about potential impacts to your business, or partnering with SEAOAK on a project? We would love to hear from you!

Carli Davis 

Chief Sustainability Officer

+61 478 164 360

Northern Rivers, NSW


Ebony Greaves

Chief Executive Officer

+61 412 103 291

High Country, VIC

Sunshine Coast, QLD


Ian Duvenage

Partner - Sustainable Agriculture Advisor

+61 478 164 360

Brisbane, QLD

Cairns, QLD


Download the PDF version of this article









Recent Posts

See All

コメント


©2025 by SEAOAK Consulting

​

SEAOAK Consulting acknowledges the traditional owners of the land in which our office is located and we pay our respect to their Elders, past, present and emerging. We recognise the ancient and on-going presence of the Dhudhuroa on this Country and acknowledge their unique and continuing connection to the lands, waters and culture of this region.

bottom of page