Modern slavery: is your business ready to respond?

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Australia’s Modern Slavery Act 2018 (Cth) requires entities with an annual revenue of $100 million to publicly report on how they are managing the risk of modern slavery in their operations and supply chains. New South Wales has also introduced legislation for companies with annual turnover above $50 million.

Each entity is unique. Modern slavery related risks will depend on the sector, geographical reach and the work already done to assess and address human rights impacts.

The more complex your business operations, the more important it is to get ready now.

Modern slavery reporting: Understanding the requirements

Modern slavery practices are human rights violations.

Understanding modern slavery

Modern slavery refers to situations of exploitation where a person cannot refuse or is unable to leave a situation because of threats, violence, coercion, deception, and/or abuse of power. Behaviours and practices which constitute modern slavery constitute a serious violation of human rights . The statistics are alarming. The Global Slavery Index states that in 2016, 40.3 million people globally were in modern slavery, and on any given day, 15,000 people in Australia are living in conditions of modern slavery.

Australia's Modern Slavery Act provides the framework and support for businesses and government to drive change.

Risks to business

To manage human rights risks and impacts, business should identify and understand their risk exposure. Businesses face exposure in four domains:

Regulatory reporting requirements
Reputational damage and eroded public trust when rights related incidents are uncovered
Investor scrutiny of social impact credentials
Values alignment for employees.

Compliance

Mandatory public reporting on modern slavery risks is now law in Australia, with accountability of the accuracy of modern slavery statements resting with the Board. The financial threshold applied by the Commonwealth Modern Slavery Act requires entities with at least AUD $100 million in annual consolidated revenue to report, however; companies that fall outside the threshold are encouraged to demonstrate good practice by voluntarily 'opting in'.

Australian companies are required to report on seven mandatory criteria in their public annual modern slavery statements:

Identify the reporting entity.
Structure, operations and supply chains.
Risks of modern slavery practices in your operations and the supply chains of the entity and any entities owned or controlled by you.
Actions taken to assess and address modern slavery risks including due diligence and remediation processes.
How you assess the effectiveness.
The process of consultation with entities owned and/or controlled by you of the actions taken.
Any other information that you consider relevant.

Key steps

Actions taken now will form the foundation of your public modern slavery statement. Three key steps are needed to manage risk and get ready to report:

Assess your current risk management.
Implement actions.
Monitor, report and demonstrate continuous improvement.

The global trends are clear: regulators, investors, consumers and employees are all demanding better corporate reporting on human rights. The introduction of the Australian Modern Slavery Act will change the conversation here and bring human rights into the corporate mainstream.

Richard Boele
National Leader
KPMG Banarra Human Rights & Social Impact – Banarra

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KPMG's Human Rights & Social Impact team has put together guidance to help you understand the requirements of the impending mandatory modern slavery reporting requirements and the risks it may expose for your organisation. Download our guide to learn more.