Modern Slavery compliance obligations started 1 January 2019

By Graham Noriskin - July 16, 2019

The Modern Slavery Act 2018 outlines the requirement of large businesses and other entities in Australia to develop annual reports on the actions they are taking to address modern slavery risks in their operations and supply chains. The Act commenced on 1 January 2019.

For Australian corporations and entities, the first reporting year will be 1 July 2019 to 30 June 2020, with reports due by 31 December 2020.

There is no financial penalty for failure to lodge a statement or for lodging an incomplete statement. However, all reports will be published in a public register, so companies that do not report properly can potentially be “named and shamed” by non-government organisations.

Who will be affected?

  • All businesses that operate in Australia with a minimum consolidated revenue of $100 million or $50m in NSW must report.
  • Entities which fall below the threshold, may be requested by a reporting entity to provide confirmations and reporting in respect of goods and services they provide to the reporting entity.
  • Smaller businesses will be able to report voluntarily, which can enhance their standing.

What is ‘Modern Slavery’?

The Act uses principles from ‘The United Nations Guiding Principles on Business and Human Rights’ which provides an outline of the responsibility of businesses to respect human rights and provide remedies wherever they operate. ‘Modern Slavery’ refers to any scenarios involving exploitation of a person who cannot refuse or leave work because of threats, violence, coercion, abuse of power or deception.

What is required to comply with the Act?

Affected entities must develop a Modern Slavery Statement which reports on:

  • the entity’s structure, operations and supply chains;
  • the risks of modern slavery in their operations and supply chains;
  • the action they have taken to assess and address those risks; and
  • the effectiveness of their response.

There is an expectation that businesses conduct appropriate assessments, implement policies and conduct training of employees in relation to their obligations. Business must include risks in their global supply chain, not just those in Australian operations. Corporate groups should obtain specific advice in relation to which entities are required to report and how joint reporting can work

Annual Modern Slavery Statements must be approved by the board of directors or equivalent and signed by a director.

New South Wales requirements

New South Wales also passed its own Modern Slavery Act which will take effect on 1 July 2019. This act imposes a lower revenue threshold of $50 million and allows for penalties to be issued for businesses that do not comply of up to A$1.1 million. The Act also establishes an Independent NSW Anti-Slavery Commissioner.

How can Pitcher Partners assist?

Pitcher Partners can assist in the following areas:

  • Assessment of your Modern Slavery Compliance Framework, supporting process and risk assessment
  • Assistance in developing a Framework, policy, processes and risk assessment
  • Provide training to staff and company management
  • Independent validation of Modern Slavery Statement
  • Investigation into allegations or reported incidents of modern slavery breaches
  • Assistance with remediation of modern slavery non-compliances or breaches

If you would like to discuss the new Modern Slavery Act requirements and how we can help you, please contact your Pitcher Partners expert.

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