July 2020

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The Act requires annual reports to be made by Australianbased entities and those operating in Australia that have a minimum consolidated revenue of $100 million (reporting entities). Other entities can elect to report voluntarily.

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Each year, reporting entities must submit a 'modern slavery statement' to the Minister for Home Affairs. This will occur through a publicly accessible registry soon to be launched by Australian Border Force's Modern Slavery Business Engagement Unit.

The modern slavery statement must describe the risks of modern slavery in the operations and supply chain of the reporting entity (and entities it owns or controls). The statement must also include information about actions taken to address those risks.

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In order to produce a modern slavery statement, a reporting entity will need to engage various functions within the entity. The first step may be to build awareness of what modern slavery is in practice and how it may be relevant to the organisation.

The functions that procure finished goods, use contractors, hold events, provide food and supplies to the business, or invest, to name a few, must all examine their activities and supply chains to evaluate risk. Further, entities within the corporate group, and outside organisations such as suppliers, unions, contractors and other stakeholders should also be consulted.

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The Commonwealth has issued guidance for reporting entities. This includes guidance on how to lodge a joint statement if a reporting entity has multiple related entities that themselves fit the threshold.

Due to increased risks of modern slavery during Covid-19, the Commonwealth has published additional specific guidance.