In light of the bipartisan support for a Modern Slavery Act, it is likely that the legislation will be passed in the House of Representatives and the Senate in the new year. Now is therefore an ideal time to review your business’s operations and supply chains for human rights impacts.
Having regard to the reporting criteria, companies and other legal entities ought consider the following steps:
- Mapping the organisation’s structure, businesses and supply chains.
- Formulating policies in relation to modern slavery – this will involve collating current policies, identifying gaps, adapting existing policies and formulating new policies, as needed.
- Carrying out a human rights risk assessment – identifying those parts of the business operations and supply chains where there is a risk of modern slavery taking place.
- Assessing and managing identified risks – this may include carrying out further due diligence in the entity’s operations and supply chains and reviewing contract terms and codes of conduct with suppliers.
- Considering and establishing processes and KPIs to monitor the effectiveness of the steps taken to ensure that modern slavery is not taking place in the business or supply chains, including by way of corporate giving.
- Carrying out remedial steps where modern slavery is identified.
- Developing training for staff on modern slavery risks and impacts.
By undertaking these steps, businesses will be well placed to respond effectively to new regulations and show that they are committed to eradicating modern slavery, in Australia and overseas, and taking concrete steps to achieve that objective.
Norton Rose Fulbright is a global law firm, with 63 offices across Europe, the USA, Canada, Latin America, Asia Pacific, the Middle East and Central Asia. We have experience in Australia and globally assisting clients with modern slavery risk management and reporting, as well as broader business and human rights advice. We made a submission to the Inquiry (No. 72) and participated in the public hearing held in Sydney on 23 June 2017. Click here to download our paper. We also have been actively participating in the Attorney-General’s Department national consultation process to refine the Government’s proposed Modern Slavery in Supply Chains Reporting model.
For more information, contact Abigail McGregor, JP Wood or Greg Vickery to discuss how modern slavery legislation may impact on your business and ways to manage your supply chain risks