Identify And Report Risks Of Modern Slavery Training

Training that teaches people to identify and report modern slavery risks has to answer two questions, not one. Spotting the risk is the easier half. Knowing where a report goes, who is allowed to receive it, and what protection the person reporting has is where most Australian programmes stop short.

That gap matters, because reporting to the wrong person can cost someone their legal protection. Under Part 9.4AAA of the Corporations Act, whistleblower protections attach when a disclosure goes to an eligible recipient. That means a director, company secretary, officer or senior manager, the auditor or actuary, a person the organisation has formally authorised to receive disclosures, ASIC or APRA, or the discloser’s own lawyer. Telling a supervisor who holds none of those roles is not the same act in law. A course that says “report it” without naming the actual recipients in your organisation leaves people more exposed than they realise.

Two points that rarely make it into a course:

• Suppliers sit inside the regime. Someone who supplies goods or services to your organisation, or who works for one of your suppliers, paid or unpaid, can be an eligible whistleblower about your organisation.
• A report can be anonymous and still protected, and causing or threatening detriment to someone for making one is both a criminal offence and a civil penalty.

Modern slavery offences carry sentences well beyond the twelve month threshold that brings a Commonwealth offence within the whistleblower subject matter, so a well founded suspicion will usually be in scope. Not every organisation is covered, and a purely personal work-related grievance is not. ASIC sets out the criteria in Information Sheet 238, reissued in June 2026. Whether a particular disclosure qualifies is a legal question worth checking rather than assuming, and this is general information rather than legal advice.

Posts tagged here look at what that training covers and why it earns its place. See Sentrient’s whistleblower course and modern slavery course, the incident management software that records what was raised and when, and further reading under incident reporting.