Three reporting lessons from the Modern Slavery Act Conference

Trish Hopper

06 Dec, 2019

Until recently, when we thought of slavery, our minds conjured grainy black and white images of a practice largely eliminated by the international community through the ratification of human rights treaties and national legislation. 

The uncomfortable reality is that slavery still exists and in some cases is thriving.

Modern slavery takes many forms. Women enslaved in baby factories to produce babies for sale. Men chained to the decks of commercial fishing boats in South East Asia. A maid to a wealthy family in Australia who has had her passport confiscated. This is what modern slavery looks like.

On 1 January 2019 the Modern Slavery Act 2018 came into force. The legislation requires businesses and other organisations (including ACFID members with an annual consolidated revenue of at least $100 million) to report annually on the risks of modern slavery in their operations and supply chains. While the mandatory threshold is $100 million there are several organisations (both NGOs and private sector) who intend to voluntarily report. Most of these agree that the public will expect to see action on slavery eradication, but first and foremost want to do the right thing.

A recent conference on this legislation, hosted by the Department of Home Affairs, detailed the Act’s impact on supply chains with panelists sharing their experiences and expertise.

Here are my three key insights from the Conference:

What good reporting looks like – don’t let perfect be the enemy of good

Reports should have meaningful disclosures. That is, you should provide information that honestly details the risks that are in your supply chains and operations, rather than taking a narrow compliance approach. Public opinion will likely take a negative view of any lack of effort in reporting.

Talk about what you are doing and what you are not doing. Explain why you have focused on, for example, only tier one of your supply chain.

It is advisable to prioritise which risk areas to include, particularly in your first report, considering this will be the first time most organisations will conduct this kind of mapping and review exercise.

You should be cautious when considering what details to disclose. Be mindful of privacy and security impacts on any alleged victims and implications for any active law enforcement investigations.

Not just a compliance exercise

Awareness and eradication of the very real issue of modern slavery is at the heart of the reporting regime. Remember – we’re talking about people, their human rights and living conditions.

When looking at the risks of modern slavery in your operations and supply chains, consider risk from the perspective of risk of harm to people - not risk to reputation or finances.

Collaboration is key

One of the biggest challenges will be managing your relationships with suppliers.

Suggestions from panellists included:

  • Introducing a Supplier Code of Conduct which should form part of the supplier contract
  • Working directly with suppliers to educate them about what modern slavery is and is not
  • Creating a safe space for suppliers to share what might be happening in their business or supply chains

Panellists encouraged organisations to work with their suppliers to achieve positive change for themselves and the people directly impacted.

Cross-sector collaboration was also recommended. This could include joining an industry group or ad hoc engagement with other similar organisations.

Sharing expertise within a sector is another valuable exercise. Organisations' reporting process would benefit from the experience of others in the industry.

Finally, collaboration within an organisation is also key. It's advisable to engage broadly across risk, compliance, legal and procurement to achieve “horizontal coherence”.

Ultimately, I encourage you to remember that this new legislation is all about people – individual victims – and working together is the best way to protect the most vulnerable from exploitation.

Learn more about the Modern Slavery Act 2018 and access key resources:

Photo: Anna Dubuis/DFID/Flickr. 

  • Trish Hopper
    Trish Hopper

    Trish Hopper is the Legal and Compliance Officer for The Fred Hollows Foundation as part of the Legal, Governance, Risk & Compliance team. Prior to The Foundation Trish spent 5 years as Legal Officer at Wesley Mission, a not-for-profit organisation based in NSW. She is enjoying the transition into the international development sector and has a particular interest in being involved in abolishing modern slavery and is looking forward to doing more in this space.

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