What are my company’s reporting requirements under Australia’s Modern Slavery Act?

Your company’s annual modern slavery statement must include the following information:

1. Identify reporting entity;
2. Explain structure, operations, and supply chains of reporting entity;
3. Describe risks of modern slavery practices in operations and supply chains of reporting entity (and any entities that reporting entity owns or controls);
4. Describe actions taken by reporting entity (and any entity that reporting entity owns or controls) to assess and address those risks;
5. Explain how reporting entity assesses effectiveness of such actions;
6. Describe process of consultation with any entities the reporting entity owns or controls or is issuing a joint modern slavery statement with; and
7. Describe any other information reporting entity considers relevant.

This statement must be approved by the company’s board of directors or other governing body and signed by a director of the company. This statement must be submitted online to the publicly accessible registry maintained by the Australian Border Force within 6 months of the close of your financial year. See https://modernslaveryregister.gov.au/.

There is no template form for this purpose. As noted above, your company’s modern slavery statement must include all of the required information. This means your modern slavery compliance program must be built to ensure your company can comply with these reporting requirements. In other words, “build back” from these reporting requirements.

Some tips for drafting your company’s annual modern slavery statement are below:

• Reality-based: Avoid aspirational statements that are not supported by action.
• Honesty is the Best Policy: Be honest about your company’s situation and risks and what your company has done in the reporting year to improve your program.
• Remember that Your Statement is Not a Certification: Your company is not required to certify that its operations and supply chains are slave free.