"Regulating transparency and disclosures on modern slavery in global supply chains: a "conversation starter" or a "tick-box" exercise?", March 2019

INTRODUCTION

...This project offers... an empirically-informed analysis of the existing and emerging issues, perceptions and concerns around the new Australian Act, studied in the context of the UK’s experience (and lessons from other schemes).

RESEARCH QUESTIONS

... our project’s research had two primary aims:

• To evaluate the evolving model of legislative disclosure or reporting regimes focusing on modern slavery risks and to ask if, and how promoting statutory reporting requirements ('transparency' aim) might contribute to substantive human rights improvement ('accountability' aim).

• To conduct empirical research (through survey and interview) to examine emerging practices (in Australia and the UK) as to what might constitute best practice in addressing modern slavery risks in supply chains.

CONCLUSION

... Several advocacy and consultancy actors observed that the Act is hardly a single solution and will not necessarily measurably reduce modern slavery but has a longer-term role to play including in raising awareness and driving changes in corporate behaviour....

...[T]here remains some risk either that broader corporate responsibility and business-human rights issues are neglected, or that reporting becomes an end in itself without generating wider changes....

...[L]egislating for mandatory reporting is only one instrument to address the profound challenge around modern slavery. As noted by the Australian Government, ‘there is no silver bullet to end modern slavery. Government, business, and civil society all have a role to play, and we need to work collaboratively ‘.

...Governments are right and smart to act in ways that enroll corporate and financial actors (and the consumer public itself) in this undertaking. However, while business is rightly under pressure to show its human rights credentials and credibility, governments cannot entirely outsource the regulation of human rights. While the focus of the Act is on what companies do and report, this ought not obscure that it is public authorities in sourcing and consuming states that ultimately remain responsible for mitigating and remedying human rights risks associated with business actors and activities.