How To Prevent Modern Slavery

Preventing modern slavery in a supply chain is mostly a procurement job rather than an HR one. The practical starting point is not a supplier list but a spend analysis, because the categories where you spend the most and pay the least are where severe exploitation is most likely to sit, usually well below the tier one supplier you actually hold a contract with.

Under the Commonwealth Modern Slavery Act 2018, entities above the reporting threshold must describe the risks of modern slavery in their operations and supply chains and the actions taken to assess and address those risks. The Act is a transparency law rather than a prohibition, so what gets scrutinised is the quality of the work you describe, not whether you can claim a clean result.

Four practices tend to do the most work:

• Start with spend by category, not with supplier headcount. High volume, low margin, labour intensive and offshore is the profile worth opening first.
• Treat contract renewal as the moment of leverage. Requirements raised mid-term are requests. The same requirements written into a tender are conditions.
• Ask questions whose answers can be checked. “Do you engage labour hire, for which roles, through which agencies” tells you more than “do you comply with the Act”.
• Decide in advance what happens when something is found, and who owns that call, so a buyer is not improvising it under commercial pressure.

The due diligence guidance published by the Australian National Contact Point, run from Treasury, describes this work as risk-based, with effort proportionate to the severity and likelihood of harm, and as ongoing rather than an annual exercise. Australian transport operators will recognise the reasoning from chain of responsibility duties, and it overlaps with ESG disclosure and everyday risk management. Obligations differ by sector and 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 work.