Steps To Prevent Modern Slavery

The steps to prevent modern slavery are not hard to list. The difficulty is the order. Most Australian organisations start by commissioning training or drafting a policy, because those produce something visible quickly. Both are the wrong first move, and both tend to produce documents that nobody maintains once the launch is over.

A sequence that holds up looks closer to this:

• Name one owner who can stop a purchase. Not a working group. Someone with the authority to hold up a supplier decision, and a named executive they escalate to. Everything after this step depends on somebody being able to say no.
• Read what comparable organisations have already published. The Modern Slavery Statements Register is searchable by entity, ABN and keyword, and filterable by industry sector, revenue band and reporting period. Reading a dozen statements from your own sector is the fastest way to see what is treated as adequate and what is treated as filler.
• Decide up front how you will judge whether any of it worked. Assessing effectiveness is one of the things reporting entities have to describe, and it is far harder to invent afterwards than to design at the start.
• Then write the policy, the contract wording and the training. Each of these encodes decisions already made. Producing them first means encoding decisions nobody has taken.

One caution on the second step. The Attorney-General’s Department publishes every statement properly submitted, compliant and non-compliant alike, under section 19(2) of the Act, precisely so that entities are publicly accountable. Appearing on the Register is not a mark of approval, so read published statements as examples of practice rather than as templates to copy.

This work sits across governance, risk and compliance and policy management rather than inside any single team. Obligations differ by entity and change over time, so treat this as general information rather than legal advice.

Sentrient’s modern slavery course sits at step four, alongside the wider compliance training courses.