Jacqueline T.
Jackie Thornley

Modern slavery can occur in any industry and any sector. The United Nations estimates that there are approximately 40 million victims worldwide.

Large public sector entities now need to explain what they are doing to assess and address modern slavery risks in their operations and supply chains. They need to show how they are taking meaningful action to assess risks and how they plan to improve over time.

Modern slavery is where offenders use coercion, threats or deception to exploit victims and undermine their freedom. It can include slavery, human trafficking, servitude, forced labour, bonded labour, forced marriage and the worst forms of child labour1. But it does not include practices such as substandard working conditions or underpayment of workers1.

Reporting requirements relating to modern slavery apply to entities that have consolidated revenue of at least $AUD 100 million and are either an Australian entity or a foreign entity carrying on business in Australia at any time during the reporting period. Entities required to comply with the reporting requirements must prepare annual Modern Slavery Statements2.

These statements must set out the reporting entity’s actions to assess and address modern slavery risks in their operations and supply chains. Each statement covers seven mandatory criteria:

  1. Identify the reporting entity.
  2. Describe the reporting entity’s structure, operations and supply chains.
  3. Describe the risks of modern slavery practices in the operations and supply chains of the reporting entity and entities it owns or controls.
  4. Describe the actions taken by the reporting entity and any entities it owns or controls to assess and address these risks, including due diligence and remediation processes.
  5. Describe how the reporting entity assesses the effectiveness of these actions.
  6. Describe the process of consultation with any entities the reporting entity owns or controls.
  7. Provide any other information that the entity considers relevant.2

The Australian Government will make these statements publicly available through an online central register. The first reporting period for modern slavery commenced on 1 July 2019, with statements due no later than 31 December 20202.

Where to next

  • Identify those areas of your entity where there may be a risk of modern slavery—namely operations and supply chains.
  • Create and issue new policies or update existing policies to include anti-slavery practices.
  • Ensure appropriate action is undertaken if your entity identifies any potential slavery practices.
  • Ensure appropriate monitoring practices are put into place.


1. Department of Home Affairs, Modern slavery

2. Department of Home Affairs, Commonwealth Modern Slavery Act 2018 – Guidance for Reporting Entities