This consultation paper outlines the Australian government’s proposed model for a Modern Slavery in Supply Chains Reporting Requirement. The proposed reporting requirement will require large corporations and other entities operating in Australia to publish annual statements outlining their actions to address modern slavery in their operations and supply chains.
Key elements of the Government’s proposal include the following:
- The introduction of a requirement to produce an annual Modern Slavery Statement
- The reporting requirement would be applicable to a range of entities:
- with a proposed revenue threshold no lower than $100 million total annual revenue, and
- headquartered in Australia or that have any part of their operations in Australia
- Entities will be required to report on their actions to address modern slavery in both their operations and supply chains (including beyond first tier suppliers)
- Entities will be required to report, at a minimum, against four criteria (which cover the optional criteria set out in the UK Modern Slavery Act):
- the entity’s structure, its operations and its supply chains
- the modern slavery risks present in the entity’s operations and supply chains
- the entity’s policies and processes to address modern slavery in its operations and supply chains and their effectiveness (such as codes of conduct, supplier contract terms and training for staff), and
- the entity’s due diligence processes relating to modern slavery in its operations and supply chains and their effectiveness
- Modern Slavery Statements would need to be approved at board level and be signed by a director
- Entities would be required to publish their Modern Slavery Statement within five months after the end of the Australian financial year
- Entities would be required to publish their Modern Slavery Statements on their websites, with the Government also proposing a publicly accessible central repository
- Punitive penalties for non-compliance are not proposed but options for oversight are being considered
- The Government will provide guidance and awareness-raising materials for business
The Commonwealth Attorney-General’s Department will lead a national consultation process with business and civil society to refine the Government’s proposed model over August – December 2017.
Submissions for the consultation will close on 20 October 2017.