As I detailed in Sourceable articles in late 2020, Australia’s Modern Slavery Act 2018 has prompted a flurry of activity from organisations of all sizes – not just in Australia but worldwide
Many of the largest have made, or are developing, their Modern Slavery Statements in line with the reporting requirements and seven essential criteria. Many medium-sized organisations have been completing assessments from their clients about their knowledge, processes and actions around human rights. And many smaller firms have been answering questions, looking to develop policies and procedures, and starting to raise awareness across their staff, suppliers and sub-contractors.
The sceptical amongst us might admire this burst of reporting energy but ask whether this really changes anything. Despite all these statements, commitments and policies, is anything different? Are these changes merely theoretical, or are things altering in practice?
I’d like to point you towards five signs that, yes, things are really changing for the better – and that those changes are set to continue:
1) Investors are already looking for organisations that are taking action, not just making promises
Investors Against Slavery and Trafficking Asia-Pacific (IAST APAC) is an investor-led initiative convened to promote effective action among investee companies in the Asia-Pacific region to find, fix and prevent modern slavery, labour exploitation and human trafficking in their value chains. They have made it clear that, with more people enslaved today than at any other time in history, things must change.
IAST APAC represents AU$5.9 trillion in funds under management and remains open to investors to join. In November 2020, the coalition of investors wrote to the 100 largest companies on the ASX telling them to take the risks of modern slavery and human trafficking more seriously.
“We see modern slavery, human trafficking and labour exploitation as something that goes beyond ethics,” the IAST APAC letter says. “Business models and value chains that rely on underpaid workers, weak regulation or illegal activities such as forced labour and other forms of modern slavery drive unsustainable earnings.”
The leadership offered by this group of institutional investors aims not only to reduce modern slavery risks in the region, but also to be a source of learning and insight for investors worldwide. Find out more about how investors are already looking for action, not just promises, at http://iast.fastinitiative.org/
2) Australia’s Online Modern Slavery Register is increasing visibility and transparency
In March and April 2021, hundreds more modern slavery statements submitted to the Australian Border Force’s Online Register under the Modern Slavery Act 2018 were published at https://modernslaveryregister.gov.au/. With over 860 mandatory statements now publicly available online covering over 1,980 reporting entities, as well as more than 130 voluntary statements, this represents another big step towards proper visibility around what organisations are doing to assess and address modern slavery risks, as well as increased transparency around supply chain risks. Yes, an organisation could say very little, do very little, and still submit a technically ‘compliant’ statement but, at a time when investors, clients and consumers are increasingly comparing policies, practices and progress, that’s becoming a mighty risky thing to do.
3) More people are searching for organisations’ statements than ever before
As if those 1,000+ modern slavery statements weren’t notable enough, Australia’s Online Register indicates that over 250,000 searches have already been performed through that website by mid-April. That indicates that there is growing interest in what organisations are reporting, and that number is climbing every day; quarter of a million searches in the five months since the first statements were published means more people than ever want to see what’s going on in organisations’ operations and supply chains.
The UK Government launched its own central registry of modern slavery statements during March 2021, following a commitment to strengthen the reporting requirements under section 54 of the UK Modern Slavery Act 2015 and their Transparency in Supply Chains Consultation, and national and international comparisons can only increase. The UK Modern Slavery Statement Registry Service is now at https://modern-slavery-statement-registry.service.gov.uk/
Both the Australian and UK registers are intended to enhance transparency and accessibility by bringing modern slavery statements together in one place, allowing consumers, business counterparties, investors and civil society to search for statements and scrutinise the steps organisations are taking to identify and address modern slavery risks in their operations and supply chains.
Formerly, the international Modern Slavery Registry operated by the Business and Human Rights Resource Centre, had filled the gap. The Registry provided an invaluable resource that helped promote transparency and increase accountability by enabling users worldwide the access to scrutinise over 16,000 modern slavery statements side by side.
4) Partnership continues to be the new leadership
The Property Council of Australia’s Modern Slavery Supplier Platform has seen a 113% increase in partners since its launch in October 2019, going from 15 founding partners to 32 platform partners in April 2021, with over 4,000 suppliers engaged and a more ‘streamlined’ approach for the new assessment questions emerging in 2021. Partners collaborating to achieve continuous improvement have also helped suppliers to gain access to a range of educational resources and measure progress in their actions and responses year on year.
The Modern Slavery Supplier Platform, supported by the Property Council of Australia with technical smarts from Informed 365 and project management from Better Sydney, now allows leading property and construction organisations to assess and report on their supply chain networks more easily through a single online approach which collects, compares and shares data on suppliers. This ensures consistency across the industry, streamlines the reporting process for businesses involved, reduces the reporting burden and makes it easier for suppliers to share information with leading property organisations.
The streamlined Supplier Platform and question set can be seen at https://propertycouncil.informed365.com/login
5) Awareness-raising, learning and training are coming to the fore
Looking around, there are now more quality, free resources available on the topics of human rights and modern slavery than ever before, with organisations including Anti-Slavery Australia and the Supply Chain Sustainability School providing free online learning modules, posters, references and other materials.
There are also more interactive and challenging elements ranging from the physical, such as the pop-up ‘store’ Human Mart which has been located in different spots around Sydney for weeks at a time (details at https://humanmart.com.au/), to the focused, such as the guide for financial services recently released by KPMG Banarra and the Australian Human Rights Commission (details at https://assets.kpmg/content/dam/kpmg/au/pdf/2021/financial-services-modern-slavery-practical-guide.pdf), and the practical, such as the UN Global Compact Network Australia’s new ‘Implementing Effective Modern Slavery Grievance Mechanisms’ guidance note at https://unglobalcompact.org.au/wp-content/uploads/2021/03/4261-UNGC-Grievance-Mechanisms-GUIDANCE-DOC_28pp-9-FA.pdf
All these available resources mean that the early focus on continuous improvement through an organisation’s operations and supply chains is not just achievable but expected. The Australian ‘Guidelines for Reporting Entities’ confirm that reporting entities are supposed to adopt a ‘continuous improvement’ approach to compliance as their understanding of modern slavery improves, and that means raising awareness across staff, clients and suppliers. When preparing their Modern Slavery Statement, a reporting entity should consider how it will continue to improve its response to modern slavery in future; and not just their own response, but awareness and actions across their local, national and global supply chains.
Change is happening; be part of it. Collaborate, question, raise awareness and ask for help.