Firms to act for clients in modern slavery reporting requirements

By Naomi Neilson|25 August 2019
Abigail McGregor


In light of recent modern slavery amendments, firms should be updating any reporting requirements to ensure both the firm and clients are operating without risk.

At a recent UTS seminar on “A Practical Guide to Modern Slavery”, experts in the field suggested ways in which entities should be protecting themselves and ensuring supply chains are operating in a way that complies with Commonwealth standards.

Partner at Norton Rose Fulbright (NRF) Abigail McGregor said the firm recently had a process of reviewing each of the firms’ suppliers to ensure processes were ethical.

“From there we had a really strong idea of who our suppliers were and what they were supplying us with and from where. We also took the view that our clients would likely struggle to replicate this process without the aid of technology because it was manual and hugely time consuming,” Ms McGregor said.


On 1 January 2019, the Modern Slavery Act 2018 (Cth) introduced new requirements for reporting on modern slavery. The requirements related to large companies working in Australia, and related to the steps that must be taken to respond to slavery risks.

In its broadest terms, modern slavery relates to situations of exploitation and where a person is unable to leave work due to threats, violence, coercion or abuse. In Australia, this constitutes human trafficking, slavery and slavery-like conditions.

It encompasses slavery, servitude, worst forms of child labour, forced labour, human trafficking, debt bondage, forced marriage and deceptive recruiting for labour.

The most recent data found in excess of 40 million people globally are estimated to be in some form of modern slavery. More than 30 million are in the Asia-Pacific alone and Australia has about 4,300 “enslaved” people under these conditions.

To ensure there is a credible and coherent strategy in place to cut out modern slavery risks, NRF had a team of graduates and staff conduct the process of reviewing any of the firms’ suppliers. Part of it involved creating a questionnaire driven by data analytics that provided an overall assessment of the supply chain with a score for each supplier.


“We created an online questionnaire driven by analytics because we were hearing that some of our clients were issuing 10,000 questionnaires to their suppliers and then got back and had to read 10,000 answers and tried to keep consistency.

“Which is an extraordinary process for one person to do,” Ms McGregor said.

McGregor suggested entities should roll out training programs on top of this to ensure staff are aware of modern slavery risks. At NRF, staff undertake mandatory and annual training on human rights issues, “which is a simple thing to introduce”.

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Firms to act for clients in modern slavery reporting requirements
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