Learning from the first Australian Modern Slavery Statements: what are companies doing well and how could they improve?
29 November 2020
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In this article, we share insights on where we see statements delivering strong disclosure as well as where we are seeing reporting gaps. [...]
Top 5 areas for improvement
Mandatory Criterion 1: Identify the reporting entity
[...] Some are providing long lists of related entities but are not stating which of those related entities are reporting entities. [...]
Mandatory Criterion 2: Structure, operations and supply chains
[...] In a number of cases, though, disclosures are not detailed enough to provide sufficient context for understanding their company’s modern slavery risks, particularly in relation to operations.
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Mandatory Criterion 3: Modern slavery risks
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There is currently a greater focus on how risks were identified, rather than identifying and describing the risks. [...]
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Mandatory Criterion 4: Actions taken to assess and address modern slavery risks
[...] some of the areas companies should consider include how they are assessing risks in their own recruitment, including the use of labour hire agencies, and their full range of business relationships [...] as well as core business activities. [...]
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Mandatory Criteria 5: Assessing the effectiveness of actions
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Many companies are describing the processes they have put in place to oversee, monitor and report internally on their implementation activities [...]. There is much less disclosure of the results of these processes, including through assurance processes, and recommended next steps to strengthen effectiveness.
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Mandatory Criteria 6: Consultation with owned and controlled entities
In many cases, consultation with owned and controlled entities appears to have been an afterthought rather than a considered part of companies’ modern slavery programs.
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COVID-19
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Many disclosures around COVID-19 have been high level, and do not describe in sufficient detail how the pandemic has changed the company’s modern slavery risk profile and the steps the company has taken to respond to those changes.
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