Why Is Modern Slavery Important

Modern slavery matters to Australian businesses because the obligation does not stop at the entities required to report. The Modern Slavery Act 2018 (Cth) applies to entities with A$100 million or more in annual consolidated revenue, and those entities then push the same questions down to every supplier they buy from.

That is how it reaches a business of thirty people. You meet it as a procurement questionnaire, a contract clause or a request for evidence, long before you meet it as a regulator. Selling to government makes it explicit. The Commonwealth Supplier Code of Conduct took effect on 1 July 2024 and is mandated through paragraph 6.12 of the Commonwealth Procurement Rules, which requires it in all Commonwealth forms of contract entered from that date. It sets minimum expectations of suppliers and their subcontractors covering ethical behaviour, corporate governance, business practices and employee welfare, and it places a positive duty on suppliers to act to prevent breaches. Where the Commonwealth asks, a supplier must be able to show the policies and frameworks behind its answers. Failing to adhere can lead to remedial action or termination.

So for most Australian businesses the consequence is commercial before it is legal. Losing a contract, or being unable to answer a buyer’s questionnaire credibly, is the realistic risk. Ground worth covering:

• Organising and evidencing compliance so answers are backed by records
• Conflicts of interest in supplier selection and contract award
• Competition and consumer law duties that sit alongside supplier conduct

Reporting thresholds are under statutory review and requirements change, so treat this as general information rather than legal advice. The Department of Finance guidance on the Commonwealth Supplier Code of Conduct is the primary source for anyone tendering to government. If training is the gap, start with Sentrient’s modern slavery course.