How To Prevent Modern Slavery In Supply Chain

Preventing modern slavery in a supply chain starts with accepting that you cannot see all of it. Most Australian businesses hold contracts with tier one suppliers and have little visibility past them, while the severe exploitation risk usually sits further down, in raw materials, processing and subcontracted labour. Prevention is a prioritisation problem before it is a coverage problem.

The OECD framework Australia follows says as much. Due diligence is risk-based, and the measures a business takes should be proportionate to the severity and likelihood of the potential harm. Where both are high, more extensive work is expected. That is permission to go deep on a few high risk categories rather than thin across every supplier, which is where questionnaire-driven programmes usually end up.

The guidance sets out four processes running across a business’s own operations, its supply chain and the wider value chain:

• identifying actual and potential adverse impacts
• preventing and mitigating them
• monitoring implementation and results
• communicating how impacts are being addressed

The sequence matters, and so does the fact that it repeats. Due diligence is described as ongoing, responsive and evolving, with feedback loops, rather than a project that finishes when the annual statement is signed. Australian transport operators will recognise the logic from chain of responsibility duties, where accountability follows the commercial relationship instead of stopping at the contract boundary, and it sits alongside wider ESG reporting expectations.

None of this makes a supply chain clean, and no programme should claim to. What it gives you is a defensible account of where you looked and why. The Australian National Contact Point, run from Treasury, publishes this guidance and also handles complaints about businesses said to have acted inconsistently with it. 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 that work.