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Modern slavery reporting – Mandatory Criteria 5

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

Seven mandatory criteria for an MSS

There are seven mandatory criteria for a Modern Slavery Statement (MSS). The information below relates to Criteria 5, which requires a business to describe how the reporting entity assesses the effectiveness of actions being taken to assess and address modern slavery risks.

Under this criterion you are only required to explain how you assess the effectiveness of a business’s actions. You are not required to determine whether the actions are effective.

This means you need to explain in your MSS what the business is doing to check whether their actions to assess and address their risks of modern slavery are working.
You must also report on any other businesses that you own or control.

How do you assess the effectiveness of a business’s actions?

There are a range of ways in which you can assess the effectiveness of your business’s actions. These include the following:

  • Establishing a process to regularly review actions taken. This can be in the form of annual meetings, or workshops to discuss and review your entity’s response to modern slavery
  • Regularly checking risk assessment processes. This will ensure you are conducting risk assessments to account for change in circumstances – for example, if your business operations move to a regional area or another country
  • Setting up a process to provide for regular engagement and feedback between key areas of your business. This enables information sharing and the determination of any potential gaps and areas for improvement
  • Conducting internal audits to ensure your internal processes are being followed – for example, when engaging a contract all appropriate information is captured and acted upon
  • Working and engaging with suppliers to check any actions they have put in place to address modern slavery risks 
  • Get independent reviews undertaken through an industry group, external auditor or a Non-Government Organisation (NGO)
  • Establishing and monitoring KPIs. Monitoring how the entity is tracking against KPIs for modern slavery policies or processes, and response.

For further information, view the ‘Guidance for Reporting entities’ published by the Department of Home Affairs.

This information is part of a series on modern slavery reporting requirements aimed at assisting members understand the requirements. See the related documents contained in the ‘What to read next’ section for more information. 

To find out more, contact HIA's Workplace Services team

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