Australia’s 2024 review of the Modern Slavery Act 2018, in force since January 2019, represents a significant evolution in the nation’s approach to combating forced labor within supply chains. The review tightened reporting thresholds by lowering the minimum consolidated revenue for mandatory reporting from AU$100 million to AU$50 million, substantially increasing the number of businesses required to submit annual modern slavery statements. In addition to this expanded coverage, the review introduced more detailed disclosure requirements, obligating entities to provide clearer, more specific accounts of their supply-chain risks, remediation efforts, and supplier engagement processes. For retailers, particularly in sectors such as apparel and textiles, this shift demands a new level of supply-chain visibility and data-driven accountability. This article explores practical steps for leveraging the Australian Border Force (ABF) import data portal to survey upstream garment and raw material suppliers and provides a checklist to guide the preparation of a robust 2025 anti-slavery statement.
Retailers operating in Australia’s apparel sector often face complex, multi-tiered supply chains that span numerous countries and involve high-risk activities, such as cotton farming, textile dyeing, and garment assembly. The revised Modern Slavery Act compels these businesses to move beyond high-level descriptions of policies and instead produce granular evidence of actions taken to assess and address modern slavery risks. To meet these expectations, retailers should first map their direct and indirect supplier networks, identifying not just Tier 1 manufacturers but also key raw material producers and processing facilities. The ABF import data portal offers a valuable resource for this mapping exercise. By accessing customs and trade data, retailers can cross-reference declared supplier entities, countries of origin, and commodity codes with their internal procurement records, thereby enhancing visibility into upstream supplier relationships that might otherwise be opaque.
Once supplier mapping is complete, retailers should implement a structured supplier survey process that collects detailed information on labor practices, sourcing policies, and remediation protocols. Surveys should be designed to elicit specific data points that align with the revised Act’s disclosure requirements, such as evidence of worker contracts, grievance mechanisms, and third-party audit reports. To maximize response rates and data quality, surveys can be distributed through digital supplier portals that enable secure, trackable data submissions. Retailers should prioritize outreach to suppliers operating in sectors or geographies identified by global benchmarks, such as the ILO or Walk Free Foundation, as high-risk for modern slavery practices. Where possible, suppliers should be encouraged to provide documentation, such as certifications under ethical sourcing standards or audit summaries from credible verification bodies.
The 2025 anti-slavery statement must present these findings in a clear, structured format that demonstrates both transparency and continuous improvement. A strong statement will begin with a description of the retailer’s supply-chain structure, including the geographic distribution of suppliers and the nature of goods sourced. It will then detail the specific risks identified during supplier mapping and surveys, highlighting the factors that contribute to elevated risk, such as reliance on low-skilled migrant labor or sourcing from jurisdictions with weak labor protections. The statement should describe the actions taken to address these risks, including supplier training, contract clauses that mandate compliance with labor standards, and any corrective actions implemented following risk assessments or audit findings.
Retailers should also include in their anti-slavery statement a discussion of their governance processes for managing modern slavery risks. This includes the role of board committees or senior management in overseeing compliance efforts, the integration of modern slavery criteria into supplier onboarding and procurement decisions, and the monitoring mechanisms in place to evaluate supplier performance over time. Disclosure of key performance indicators, such as the percentage of suppliers audited or the number of remediation plans implemented, provides stakeholders with tangible evidence of progress and accountability.
The following checklist can assist retailers in preparing a comprehensive 2025 anti-slavery statement. First, confirm whether your entity meets the revised AU$50 million reporting threshold and identify all reporting entities within your corporate group. Second, map Tier 1 and upstream suppliers using internal records and ABF import data. Third, design and distribute supplier surveys aligned with the Modern Slavery Act’s disclosure requirements, prioritizing high-risk categories. Fourth, analyze survey responses and import data to identify modern slavery risks across your supply chain. Fifth, document the actions taken to address these risks, including training, audits, and remediation measures. Sixth, compile governance and oversight information, including board involvement, procurement policies, and grievance mechanisms. Finally, draft the anti-slavery statement in accordance with ABF guidance, ensuring that it is approved by the relevant governing body and published in a timely manner.
Australia’s revised Modern Slavery Act signals a move toward more substantive, data-backed reporting that will challenge retailers to engage deeply with their supply chains and demonstrate genuine progress in eradicating forced labor. By leveraging tools such as the ABF import data portal and adopting structured supplier engagement processes, retailers can not only comply with the new requirements but also contribute meaningfully to global efforts to eliminate modern slavery. Early investment in robust data systems and supplier partnerships will position businesses to respond effectively to evolving regulatory expectations and stakeholder scrutiny in the years ahead.