Businesses operating in Australia with a turnover of $100 million or more are required under the Modern Slavery Act to tackle modern slavery in their operations and supply chain, submitting an annual statement to outline their progress.

Recently the Federal Government called for submissions as part of a review of the Modern Slavery Act and the National Retail Association took the opportunity to share some key insights and feedback, gained through their work with retailers. The National Retail Association convenes an Ethical Sourcing Committee with a Modern Slavery focus, to share best practices and tackle some of the challenges faced by retailers, such as traceability beyond the first tier of the supply chain, tackling grievance mechanisms, successful remediation, and audit programmes.

Our work with retailers has shown that since the introduction of the Act, retailers have made considerable progress toward tackling modern slavery. Obligations under the Act, however, are resource intensive. While the federal government estimated that the cost to businesses was approximately $22,000, our engagement has shown that on average, total annual costs are more accurately between $50,000 – $100,000, including costs of management platforms, grievance mechanisms, third-party auditing, additional internal resourcing for supply chain managers and preparing annual modern slavery reporting.

The National Retail Association has put forward a number of learnings and areas of potential improvement, to be considered in the review, which we believe will help advance human rights outcomes. These include:

  • Supporting businesses to collaborate on grievance mechanisms, audits, and remediation, to avoid working in parallel and maximize human rights outcomes.
  • Continuing to promote an approach of continuous improvement. Introducing financial penalties will detract from this approach and move to a focus on meeting a minimum standard.
  • Providing greater industry-specific support, particularly for businesses in their first and second reporting cycles, which could be met through the introduction of an Anti-Slavery Commissioner to educate, inform and guide businesses.
  • Integrating annual reporting with other government agencies and regulatory bodies. Publicly accessible annual statements are an important tool for benchmarking and promoting best practices. The integration will increase the profile and public awareness of modern slavery work and raise accountability for businesses.

The National Retail Association argues that ultimately, managing modern slavery risk should eventually become a cost of doing business in Australia.  We support lowering the participation requirements as Australia’s modern slavery endeavours mature and evolve, however, in a careful way that does not compromise the quality of reporting.

A full copy of the National Retail Association’s Modern Slavery Act review submission is available.