How To Manage Modern Slavery

Managing modern slavery risk is an annual cycle with named owners, not a document produced once a year. Under the Commonwealth Modern Slavery Act 2018 a reporting entity’s statement must address the seven mandatory criteria in section 16, and it must describe what the entity actually did during that reporting period. Work done after the period closes does not count towards it.

That one rule decides how the year should run. Four things follow from it:

• Start with criterion five, effectiveness. It is the hardest to evidence and cannot be reconstructed late, because it needs a baseline set before the actions are taken.
• Capture evidence as you go. A dated file of supplier responses, site visits, training completions and decisions made beats a scramble in the final month.
• Book the board slot early. The statement must be approved by the principal governing body and signed by a responsible member under sections 13 and 14, so the approval date is a hard constraint on the drafting timetable.
• Consult the entities you own or control across the year, which is criterion six, rather than circulating a draft for comment at the end.

The Attorney-General’s Department is blunt about the limits of a paper exercise. Its guidance says it is not sufficient to outsource compliance through contracts or to rely on statements from suppliers, and there is deliberately no statement template, because the point is that an entity thinks through its own risks. Where an entity does not comply, the department says it will work with them first, and in particularly bad cases the entity may be named by the Minister after written notice.

Run it with the same records and review discipline you apply to governance, risk and compliance, records management and policy management. The Modern Slavery Statements Register publishes the department’s guidance on each criterion. Obligations change over time, so treat this as general information rather than legal advice.

Sentrient’s modern slavery course and the wider compliance training courses cover the awareness half of the programme.