What is Modern Slavery?
Slavery is not only a problem from the past. The truth is that there are more people now in slavery than at any time in our history.
The Global Slavery Index of the Walk Free Foundation estimates that over 15,000 people were living in conditions of modern slavery in Australia, and 30 million people globally during 2016.
Many Australian companies may be unknowingly using forced, bonded or child labour through their international and domestic supply chains.
High-risk occupations in Australia include agriculture, domestic work, food services and construction, with particularly vulnerable groups including migrants, domestic workers and young people between 16-18.
The top 5 products imported by Australia from countries that are at risk of using modern slavery in the production of these goods are technology (laptops, computers and mobile phones); apparel and clothing accessories; fish; rice and cocoa.
However, modern slavery has been identified in everything from the manufacture of surgical gloves through to call centre operations.
Modern slavery is real in Australia, and the Commonwealth Government has enacted legislation that forces over 3,000 organisations to take responsibility for their purchasing decisions.
Modern slavery is defined in the Modern Slavery Legislation as including trafficking in persons, forced labour, forced marriage, slavery, debt bondage, deceptive recruiting for labour or services, servitude, and child labour. It does not include practices such as substandard working conditions or underpayment of wages.
What is the Modern Slavery Legislation?
In 2018, the Modern Slavery Act was passed by the Commonwealth, with a commencement date of January 1, 2019.
This legislation requires require entities with consolidated revenues over $100M to produce an annual, publicly available, Modern Slavery Statement outlining actions they are taking to understand, assess and address modern slavery risks within their operations and supply chain, both within and outside Australia.
Modern Slavery Statements must address specific mandatory criteria.
The intent behind the statements is to increase organisation transparency and public scrutiny, with an expectation that organisations will improve year-on-year.
Non-compliance with the reporting requirements will result in reputational and ethical damage. This will be particularly damaging for organisations that rely on a positive public image as part of their brand and goodwill offering. Without adequate action, scrutiny from vocal, high profile lobbyist bodies is a risk that many organisations are considering. The ramifications from poor media exposure will impact business and profit margins.
It is expected that over time, additional compliance measures and penalties may apply for failure to comply.
Modern Slavery in Australia – Case Study
Bo-Syun Chen and Yu-Hao Huang (2017): Servitude
Huang and Chen ran two fraudulent call centres out of residences in Brisbane. The call centres were staffed by other Taiwanese nationals who were forced to work 15 hours a day, seven days a week, for no pay.
The call centre operators each had to make up to 60 calls per shift which were designed to trick wealthy Chinese citizens into revealing their bank balances.
Huang and Chen received jail sentences and were then deported.
Modern Slavery in a Supply Chain – Case Study
Ansell Gloves: Debt Bondage and Forced Labour
The Nepalese workers at Top Glove (a supplier of Ansell gloves) were charged recruitment fees in their home country of about $US1,000. Recruitment fees charged to Bangladeshi workers working for Top Glove were as high as $US5,000. Fees were paid to recruitment agents offering high-interest loans in return for employment.
Workers slept 11 to a dorm room and shared the mattresses with the alternative shift.
Ansell subsequently implemented a new Foreign Workers Recruitment Policy in December 2018, enhanced training on slavery and conducted worker interviews and self-assessments in response to the specific risks raised in relation to labour practices in Malaysia.
What do entities need to do?
Organisations covered by the Modern Slavery Act need to understand the legislation, the reporting requirements, determine their level of compliance, identify the risks of modern slavery occurring within their organisation or supply chain, and commence addressing the risks.
They also need to prepare their Modern Slavery Statement in compliance with legislative requirements.
The first Modern Slavery Statements cover the period 1 July 2019 to 30 June 2020, with the statements due by 31 December 2020.
How we help with Modern Slavery Act Implementation
We work with organisations to help them:
Understand – We help you gain an understanding of where and how modern slavery could be impacting your organisation.
Respond – We help you determine and implement the optimal strategy for your organisation to identify and respond to potential risks.
Comply – We help you comply with legislative reporting requirements.
While there are mandatory requirements to be addressed in Modern Slavery Statements, individual organisations may select their own strategy for implementation of the requirements.
We can tailor a compliance strategy matched to your organisational values and business strategy, budget and overall business direction.
Option 1: Compliance
- Governance: Review contracts and tender templates; Update policies and procedures.
- Communication/Marketing: One-way, low investment communication strategy.
- Human Resources: Awareness training for key staff and management.
- Supply Chain Operations: Risk assessment of high spend/risk suppliers.
- Measurement and Reporting: Prepare a template Modern Slavery Statement.
Option 2: Advocate
- Governance: Review contracts and tender templates; Update policies and procedures. Integrating modern slavery risk mitigation strategies into organisational Risk Assessment processes. Provision of grievance and remediation mechanisms.
- Communication/Marketing: Stakeholder consultation and communication strategy.
- Human Resources: Awareness training for suppliers, key staff and management. Procurement specific training to assist employees when making procurement decisions. Roles and responsibilities reviewed and defined.
- Supply Chain Operations: Risk assessment for an agreed number of tier 1 (direct) suppliers with a detailed risk assessment for high-risk suppliers and consumables. Pre-supply audits of new suppliers to mitigate the risk of modern slavery.
- Measurement and Reporting: Prepare Modern Slavery Statement. Regular reporting on progress against performance measures.
Option 3: Leader
- Governance: Review contracts and tender templates; Update policies and procedures. Executive steering committee formed. Modern Slavery integrated into organisational Risk Assessment, Strategic Planning and Annual Report processes. Effective grievance and remediation mechanisms.
- Communication/Marketing: Stakeholder consultation and communication strategy. Resource library developed.
- Human Resources: Detailed training for suppliers, key staff and management. Procurement specific training to assist employees when making procurement decisions. Roles and responsibilities reviewed and defined.
- Supply Chain Operations: Risk assessment for an agreed number of tier 1-6 suppliers with a detailed risk assessment for high-risk suppliers and consumables. Assistance with supplier audits. Pre-supply audits of new suppliers to identify potential modern slavery.
- Measurement and Reporting: Prepare Modern Slavery Statement. Regular reporting on progress against slavery specific performance measures.
Get a Proposal
Call or contact us today for an obligation free proposal as to how End to End Consultancy Services will be able to mitigate the risk of modern slavery within your organisation and supply chain.