Do you support slavery? The answer may surprise you

Damian Clarke

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Image: Supply Chain School

Who do you have working on site?

By 31 March 2020 next year businesses with a turnover $100 million a year need to upload a modern slavery statement to the Commonwealth Government’s Modern Slavery Register. But smaller businesses can also upload a voluntary statement. It’s a good idea and highly recommended the experts say. Here’s our guide to modern slavery and what your business needs to know.

In Australia, about 15,000 people live and work in “conditions of modern slavery”. That’s the view of Nicholas Bernhardt, chief executive officer of Informed 365, quoting the Global Slavery Index.

Bernhardt, an advisor to the Property Council of Australia, among other major businesses and organisations, says immigrant construction workers in Australia, often working through labour hire companies, are particularly vulnerable to exploitation through forced labour and non-payment of entitlements.

You need to know if your business employs any of these people on your projects. How can you be sure?

How clean is your supply chain?

Robin Mellon, CEO of Better Sydney who’s worked intensely on the modern slavery issue, included as former CEO of Sustainability Supply Chain School, says overseas supply chains are also at risk of having slave labour at their root.

He points to reports such as The Dark Sites of Granite which exposed the rampant exploitation of workers in the South Indian granite industry – the source of many Australian high-spec bench tops.

Exploitation takes the forms of debt bondage, child labour, unsafe and unhealthy working and living conditions, low wages, non-payment of overtime and even denying workers access to clean drinking water.

Is your stonework tainted?

Currently, in Australia, The Modern Slavery Act requires businesses that turn over more than $100 million a year to upload a modern slavery statement to the Commonwealth Government’s Modern Slavery Register by 31 March 2021.

And it’s not only big businesses. Any organisation can submit a voluntary modern slavery statement if it wants to demonstrate its commitment to transparency about slavery in its supply chain.

Mellon thinks the trend will catch on.

“I think we’ll have smaller organisations – turning over $1m to $5m – making statements as time goes on,” says Mellon. “It’s important to have the CEO put their signature to these documents – it sends a clear message about transparency and responsibility.”

But how can one business make a difference?

First, it’s important to recognise that the first step is transparency. Change comes second and continuous improvement will follow that.

The aim of all this activity is to build a groundswell of businesses that demand more rigorous employment standards from their suppliers. As the numbers grow, the pressure will increase and unscrupulous employers – here and overseas – will be forced to change their ways.

Simply asking, “Do we know where our stuff comes from?” and following up with, “So where does it come from, then?” is powerful, Mellon says.

The easiest trap to fall into is simply buying on price with no consideration for the people behind the price. In short, “If it’s too good to be true, then it’s probably not true,” Mellon says.

What is in a modern slavery statement?

Your modern slavery statement includes seven mandatory reporting criteria which can be paraphrased as:

  1. Your organisation’s name
  2. Your organisation’s structure and operations
  3. The risks of modern-day slavery that you have identified in your supply chain
  4. What action you are taking to reduce those risks
  5. How you assess the effectiveness of that action – which may include internal audits, working groups and third-party assessments
  6. What consultation you have had across your organisation and businesses, such as subsidiaries and associated entities
  7. Anything else you want to add – for example, you may be part of the Australian Property Council’s Modern-Slavery Initiative

Where to find more information

Free resources are available. The Minderoo Foundation’s Walk Free initiative has published a Business and Investor Toolkit and the Supply Chain Sustainability School’s Modern Slavery resource is a good starting point.