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Modern Slavery Reporting Requirements: Mandatory Criteria 4 - Actions taken to assess and address the risks of modern slavery practices occurring in a business’s operations and supply chains

February 06, 2020

Businesses with an annual consolidated revenue of over $100 million must submit a Modern Slavery Statement (MSS) outlining the risks of modern slavery in their supply chain within 6 months of the end of their reporting period (whether that be a financial or calendar year).  Read an overview of Modern Slavery Reporting Requirements.

There are seven mandatory criteria for an MSS. This fact sheet provides information on Criteria 4 which requires a business to describe what actions the business is taking to assess and address the risks of modern slavery practices occurring in its operations and supply chains.

You must also report on the actions taken by any other businesses that you own or control, and should only cover the actions taken during the twelve month reporting period.

The description of the actions taken must include information about due diligence and remediation processes that your business undertakes.

What does due diligence mean?

Due diligence is the ongoing management processes to identify, prevent, mitigate and account for how your business addresses actual and potential modern slavery risks.

There are four parts to due diligence:

  1. Identifying and assessing potential modern slavery practices, for example:
    1. when engaging a new contractor or supplier, part of your contractor management process may involve asking questions to determine if the contractor displays any indicators of modern slavery risks ,
    2. Engage with contractors and suppliers to determine how they are addressing modern slavery risks; and
    3. Asking contractors and suppliers to provide an undertaking as part of the contractual arrangements   or agree to a code of conduct in regard to  the risk of modern slavery; 
  2. Integrating your findings across your business and take appropriate action to address impacts, for example:
    1. Undertake training with your procurement team so they understand modern slavery, and what needs to be done if it is suspected in the supply chain; and
    2. Introducing new grievance/whistleblowing policies for your employees and contractors to report any potential risks or concerns about colleagues or supply chain issues;
  3. Tracking your business’s performance to check whether impacts are being addressed, for example:
    1. Regularly carrying out an internal audit of supplier/contractor screening processes;
    2. Regularly reviewing internal policies, and carrying out appropriate training and refresher training;
    3. Increase engagement with suppliers; 
  4. Publically communicating what is being done, for example:
    1. Publishing your MSS on your website; and
    2. Publically reporting on any actions the business takes to combat modern slavery.

What does remediation mean?

Businesses that identify that they have caused or contributed to modern slavery must provide for, or cooperate in, the remediation of its impact. This means you should try to ‘make good’ the adverse impact by restoring the victim to the situation they would have be in if the adverse impact had not occurred.

Remediation can take place in many forms and don’t necessarily need to just focus on modern slavery, for example:

  • Taking steps to ensure the harm cannot reoccur;
  • Public apology;
  • Compensation;
  • Dispute resolution process; or
  • Stopping certain activities.

If your business did not directly cause or contribute to the harm, but are linked to a business who caused adverse impacts, whilst not responsible for remediation, it is recommended you work with the business that caused the harm to minimise the impact, and prevent reoccurrence. If this is unsuccessful you may wish to cease any further business interaction with such a business.

Effective remediation processes can help you identify issues before they escalate, better manage risks, reinforce your culture, improve morale and wellbeing and strengthen your entity’s reputation.

For further information HIA members can contact a Workplace Adviser on 1300 650 620 or view the ‘Guidance for Reporting entities’ published by the Department of Home Affairs.

This fact sheet is part of a series on modern slavery reporting requirements aimed at assisting members understand the requirements. More information is set out in:

Previous page | Overview | Fact sheet 1Fact sheet 2 | Fact sheet 3 | Fact sheet 4 | Fact sheet 5 | Next

Each fact sheet is available to download as a pdf below:

#1 Modern Slavery Reporting Requirements - Overview 

#2 Modern Slavery Reporting Requirements – Do I need to report?

#3 Modern Slavery Reporting Requirements – Mandatory Criteria 1 & 2

#4 Modern Slavery Reporting Requirements – Mandatory Criteria 3

#5 Modern Slavery Reporting Requirements – Mandatory Criteria 4

#6 Modern Slavery Reporting Requirements – Mandatory Criteria 5