Modern Slavery Warning Signs And The Culture That Finds Them

Preventing Modern Slavery Starts Closer to Home Than Most Organisations Think

Modern slavery is exploitation serious enough that a person is not free to leave. Coercion, threats or deception remove the choice.

It is not the same thing as poor pay or long hours, though those often sit alongside it.

Most Australian guidance treats it as a supply chain question, and understandably so.

The obligation to report was built around supply chains and the worst risks often sit offshore, concentrated in the Asia Pacific region where prevalence is highest globally.

That framing has a blind spot. The Modern Slavery Act 2018 covers operations and supply chains, and an organisation’s own operations include its labour hire, its on-site contractors in cleaning and security, its franchise network and anyone working on its premises under someone else’s payroll.

Those are the workers your people see every day, and they are the ones your existing due diligence process is least likely to reach.

For what modern slavery is, the eight types recognised under Australian law, who has to report and what a statement must contain, see our full guide to modern slavery and how to prevent it in your organisation. This article is about the part a statement cannot do for you.

Modern Slavery as a Human Rights Issue, and Why That Framing Changes What You Do

Modern slavery is the most severe end of a human rights problem, and treating it that way changes where an organisation looks.

A compliance framing asks whether you have met an obligation.

A human rights framing asks whether people connected to your work are being harmed, which is a wider question and a more useful one.

It takes in the cleaner on your site at 4am, the labour hire picker on a farm you buy from, and the international student on your night shift, whether or not any of them appear in your reporting scope.

That is why a workplace culture that promotes human rights is not a soft complement to your compliance work. It is the part that notices.

International due diligence standards make the same point: the obligation is to understand risk to people and act proportionately to it, not to generate documents.

Practically, a human rights framing means three things. You look at everyone affected by your operations rather than only your employees.

You treat the severity of harm to a person as the thing that sets your priority, rather than the size of the contract.

And you accept that finding a problem is a success, because the alternative is that it was there and nobody saw it.

Modern Slavery Risk in Australian Workplaces: What the 2026 Data Shows

In May 2026 the Migrant Justice Institute published the largest survey of its kind in Australia, led by Associate Professor Bassina Farbenblum at UNSW and Associate Professor Laurie Berg at UTS, funded under the Commonwealth Attorney-General’s Department National Action Plan to Combat Modern Slavery.

An important distinction. Underpayment is not modern slavery. Most of those two thirds are wage cases, not slavery cases, and treating every underpayment as trafficking would be both wrong and unhelpful.

What underpayment is, is a red flag. Modern slavery does not usually arrive announced.

It sits at the far end of a spectrum that starts with wage theft, unpaid trial shifts and deductions nobody can explain, and it concentrates in exactly the same conditions: temporary visas, language barriers, and an employer who controls whether the work continues and whether the visa survives.

The AFP figures are the other half of the picture. Fewer than fifty reports a year nationally, against a survey showing exploitation at this scale, is not a measure of how much is happening. It is a measure of how little is being seen.

Why Culture, Not Paperwork, Is What Finds Modern Slavery

The Australian Anti-Slavery Commissioner has put this more bluntly than most: “The busy work of paper shuffling does not correlate with real impact.”

Good due diligence, in his framing, is about understanding risk and acting proportionately to it, rather than generating compliance material.

That lands directly on the weakest part of most modern slavery statements.

Describing what you did is straightforward.

Showing that it worked is the criterion organisations most often fail, and it is the one that will matter most if a failure to prevent offence is introduced.

Detection is what closes that gap, and detection is a human process.

No policy has ever noticed that a cleaner arrives and leaves in the same vehicle as six other people.

No supplier questionnaire has noticed that one worker never speaks for themselves.

The people who notice are the ones standing next to them, and whether anything happens next depends entirely on whether they know what they are looking at and believe raising it will lead anywhere.

The Modern Slavery Warning Signs Your People Can Actually Notice

The Australian Federal Police publish indicators of forced labour. These are the ones an ordinary worker or supervisor could observe without any investigation.

How the Person Lives and Moves

• Living in unsuitable places, such as agricultural or industrial buildings
• Overcrowded or unsafe accommodation, with no choice about where they live
• Never leaving the work premises without an employer escort
• Being unable to move freely

Money and Documents

• No access to their own earnings or savings
• Unlawful wage deductions, or being made to pay for their own tools
• Being disciplined through fines
• An employer unable to produce employment documents or wage payment records
• No labour contract

Conditions and Treatment

• Excessively long hours that are not a choice
• Insults, abuse, threats or violence
• No protective equipment, or equipment that is poor quality or missing
• No basic training provided by the employer
• Workplace information only in a language the worker does not read, and no health and safety notices
• Evidence of labour law breaches
• Work equipment designed or modified to be operated by a child

Where Modern Slavery Risk Sits Inside Your Own Operations

Risk concentrates wherever a power imbalance meets weak visibility. In an Australian organisation’s own operations, that usually means:

• Labour hire and on-hire arrangements, where you direct the work but someone else pays the wages and holds the records
• On-site contracted services, particularly cleaning and security, often performed outside normal hours with no client staff present
• Subcontracting layers, where the entity you contracted is not the entity whose people turn up
• Franchise and licensee networks operating under your brand but outside your payroll systems
• Seasonal and peak work in horticulture, food processing, construction and logistics
• Roles filled by temporary visa holders, where the employer influences both the work and the visa

The common feature is that your own managers rarely see these workers, and your own reporting channels rarely reach them. That is the gap culture has to close.

Building a Workplace Culture That Prevents Modern Slavery

A workplace culture that promotes human rights is not a values statement.

It is a set of specific conditions that make exploitation harder to sustain and easier to surface.

1. Put It in the Policies People Actually Use

Your policy set should name modern slavery and human rights alongside bullying, harassment and discrimination, so it reads as workplace conduct rather than a procurement topic.

State the standard clearly, state that raising a concern is expected rather than optional, and state that nobody will be disadvantaged for doing so.

2. Make Expectations Reach Beyond Your Payroll

Say in your contracts, inductions and site rules that the standard applies to everyone working on your sites, including labour hire, contractors and subcontractors. Give those workers the same induction and the same reporting information as employees.

3. Set Penalties and Apply Them

A workplace culture that promotes human rights has teeth or it has nothing. Stated consequences for exploitation, and for retaliation against anyone who reports it, only mean anything if a supplier has ever actually lost work over them. Where you can, keep the option to end an engagement and be willing to use it.

4. Reduce the Isolation

Exploitation is easier to hide where workers are alone, out of hours, or unable to communicate. Overlapping shifts, translated materials, a named contact who is not their own supervisor and simple physical visibility all cut the risk.

5. Look at Your Own Buying Behaviour

Price pressure, last-minute volume swings and recruitment fees passed down the chain create the conditions exploitation grows in. A culture that promotes human rights and a procurement practice that squeezes suppliers to the point of failure cannot both be true.

6. Comply Properly, and Treat the Statement as an Output

Meeting your obligations under the Act matters. It is the floor rather than the goal, and an organisation that treats the annual statement as the work has usually stopped doing the work.

Modern Slavery Training as a Detection Control, Not a Tick Box

Training is where the warning signs above become something an organisation can act on, and it is worth being specific about who needs what.

• All workers need to recognise the indicators and know that reporting a concern about someone who is not their colleague is welcome.
• Supervisors and site managers need to know what to do with a report in the first hour, and specifically not to raise it with the worker’s own employer before they have advice.
• Anyone who buys or engages labour needs to understand how recruitment fees, subcontracting layers and price pressure create risk.

Sentrient’s modern slavery and human rights training course covers the worker level, and completion records sit in the same compliance system as your policies and reports, which is what lets you answer the effectiveness question in your statement with evidence rather than description.

Speaking Up: Making a Modern Slavery Report Possible

A worker in an exploitative arrangement is, by definition, the person least able to complain. So the channel has to be built for someone who is frightened, may not speak English well, and may believe their visa depends on staying quiet.

• A route that does not go through their own employer or supervisor
• Available in the languages your workforce actually speaks
• Open to anonymous reports and to third-party reports from colleagues who noticed something
• Reaching contractors and labour hire workers, not just employees
• Explicit that immigration status will not be used against the person raising it
• Clear about what happens next, and honest about what you cannot promise

External channels should be on the poster too. The Australian Federal Police take reports on 131 AFP, which is 131 237, and through a confidential online form.

The Australian Red Cross Support for Trafficked People Program can be reached on 1800 113 015. In an emergency the number is 000.

The Australian Anti-Slavery Commissioner, and What It Is Not

Australia now has an Anti-Slavery Commissioner, established in 2024 by amendment to the Modern Slavery Act 2018.

The functions are to promote compliance with the Act, to support businesses to address their risks, and to support collaboration within and across sectors.

Worth knowing clearly: the role is not regulatory, not investigative and not law enforcement. It is not somewhere to report a suspected case, and it will not be inspecting you.

That makes the Commissioner a source of guidance rather than a compliance risk, and it means suspected exploitation still goes to the police, and serious underpayment still goes to the Fair Work Ombudsman.

How Preventing Modern Slavery Connects to Your Reporting Obligations

Entities with annual consolidated revenue of at least $100 million must publish an annual modern slavery statement describing what they have done about risks in their operations and supply chains.

The statement is a description of actions, not a declaration that no slavery exists.

The criterion organisations most often struggle with is effectiveness: showing that what you did made a difference.

Culture and detection are what generate the evidence for it.

Training completion by role, reports received and how they were resolved, changes made to a supplier arrangement, an induction extended to contractors. Those are answers. A policy document is not.

Reform has been announced but not enacted. A failure to prevent offence with a reasonable steps defence, and civil penalties for reporting breaches, were announced in July 2026 and remain at proposal stage.

If that offence arrives, the reasonable steps defence will be built out of exactly the material described on this page.

Organisations under the threshold have no reporting obligation and still have the same work health and safety duties, the same obligations under the Fair Work Act, and the same reputational exposure. Preventing modern slavery is not a large-entity activity.

A Modern Slavery Culture and Detection Checklist

• Your policy set names modern slavery and human rights alongside bullying, harassment and discrimination
• The standard is stated in contracts, inductions and site rules for everyone on your sites
• Labour hire and contracted workers get the same induction and reporting information as employees
• Workers have been trained on the warning signs and know a concern about a non-colleague is welcome
• Supervisors know what to do in the first hour and not to tip off the worker’s employer
• Buyers understand how price pressure, recruitment fees and subcontracting create risk
• A reporting channel exists that bypasses the worker’s own employer
• That channel works in the languages your workforce speaks and accepts anonymous reports
• External numbers are displayed where contracted workers can see them
• You record training completion, reports received and what changed as a result
• You can point to a decision where a supplier arrangement changed because of what you found

The last item is the one that answers the effectiveness question. Everything above it is preparation.

Where to Start

Walk your own site at the hour the cleaners or the night shift are there, and ask yourself whether you could name who employs them, whether they have been inducted, and how they would raise a concern.

If the answer to any of those is no, that is the gap. It is closer than the supply chain and it is entirely within your control.

Frequently Asked Questions

1. Is Preventing Modern Slavery Only a Supply Chain Issue?

No. The Modern Slavery Act 2018 covers operations as well as supply chains, and an organisation’s operations include labour hire, on-site contractors, subcontractors and franchise networks. Those workers are often the least visible to existing due diligence.

2. Is Underpayment the Same as Modern Slavery?

No. Underpayment is a wage compliance issue and most cases are not modern slavery. It is a red flag, because exploitation concentrates in the same conditions, so persistent underpayment in a workforce of temporary visa holders is worth looking at more closely.

3. What Are the Warning Signs of Modern Slavery at Work?

The AFP’s forced labour indicators include no access to earnings, no labour contract, unlawful deductions or fines, controlled or overcrowded accommodation, never leaving the premises without an escort, excessive hours, threats or violence, and an employer unable to produce wage records. No single sign proves anything, but several together are worth reporting.

4. Where Do You Report Suspected Modern Slavery in Australia?

To the Australian Federal Police on 131 AFP, which is 131 237, or through their confidential online form. The Australian Red Cross Support for Trafficked People Program is on 1800 113 015. Call 000 in an emergency. The Anti-Slavery Commissioner is not a reporting body.

5. What Does the Australian Anti-Slavery Commissioner Do?

The office was established in 2024 by amendment to the Modern Slavery Act 2018 to promote compliance, support businesses to address their risks and support collaboration across sectors. It is explicitly not regulatory, investigative or law enforcement.

6. Does My Organisation Have to Report If We Are Under $100 Million?

No, the reporting obligation applies to entities with annual consolidated revenue of at least $100 million. Smaller organisations still have work health and safety duties, Fair Work obligations and the same exposure if exploitation is found in their operations.

7. How Does Culture Help With the Effectiveness Criterion?

Effectiveness is the criterion most statements handle poorly, because describing actions is easier than showing they worked. Training completion by role, reports received and resolved, and changes made to supplier arrangements are evidence that something functioned. Policies alone are not.

8. What Training Do Our Workers Actually Need?

All workers need to recognise the indicators and know reporting is welcome. Supervisors need to know how to handle a report in the first hour. Anyone engaging labour needs to understand how recruitment fees, subcontracting and price pressure create risk.

Read More About Modern Slavery:

• Modern slavery in Australia: the Act, reporting and prevention
• The types of modern slavery your employees need to be safeguarded against
• What is forced labour and how to prevent it
• Deceptive recruitment for labour or service, and how training helps
• Why modern slavery training is a must for your organisation
• 7 ways we can stop modern slavery