Australia’s Modern Slavery Act, enacted in 2018, established a mandatory reporting framework requiring large entities to disclose the steps they have taken to address modern slavery risks within their operations and supply chains. The publication of the first updates to the Modern Slavery Transparency Register in December 2023 marks a significant milestone in the evolution of the Act’s implementation. These updates not only provide a clearer view of how companies are managing modern slavery risks but also set a benchmark for best practices in supplier audits, risk assessment, and public reporting. The Australian Border Force, as the regulator, has used this opportunity to highlight areas where reporting entities are excelling and where improvement is needed to drive more meaningful transparency.
One of the key takeaways from the 2023 Transparency Register updates is the growing maturity of supplier audit programs among leading Australian retailers and manufacturers. Companies that have earned positive recognition in the register have demonstrated a systematic approach to supplier due diligence, characterized by rigorous audit schedules, third-party verification, and the use of standardized audit templates that align with international frameworks such as the UN Guiding Principles on Business and Human Rights. These companies are also increasingly leveraging open data sources, such as industry-wide supplier lists and public compliance databases, to validate supplier self-assessments and identify red flags in complex, multi-tier supply chains. By making greater use of these external data points, Australian businesses are enhancing the reliability of their supply chain maps and identifying previously hidden risks related to forced labor, debt bondage, and exploitative recruitment practices.
For Australian retailers and manufacturers seeking to align their published modern slavery statements with the latest Transparency Register data, several practical steps can help ensure consistency, accuracy, and relevance. First, companies should perform a gap analysis comparing their current statements with the register’s published best practices, paying particular attention to the depth of supply chain mapping, the clarity of risk descriptions, and the specificity of actions taken. This analysis can highlight areas where additional detail or disclosure may be warranted, such as outlining the frequency of supplier audits, describing remediation measures for identified cases of modern slavery, or disclosing partnerships with worker rights organizations. Retailers are also encouraged to ensure that the data and commitments described in their modern slavery statements are reflected in the information they submit to the Transparency Register, creating a cohesive narrative that reinforces accountability.
The Australian Border Force’s introduction of a new risk-rating tool offers companies a practical resource for refining their modern slavery due diligence efforts. This tool, designed to assist reporting entities in evaluating modern slavery risks across supply chains, combines sectoral risk data, geographic risk indices, and historical enforcement records to generate supplier-level risk profiles. To adopt this tool effectively, companies should integrate it into their supplier onboarding and review processes, using the risk scores to prioritize audits, allocate resources for supplier engagement, and inform decisions on supplier retention or termination. The risk-rating tool also supports dynamic risk monitoring, enabling companies to adjust their focus as supplier circumstances or external conditions change over time. For example, a supplier’s risk profile might shift due to political instability in a sourcing country or following media reports of labor abuses in a specific sector.
To operationalize the risk-rating tool, companies can begin by mapping their existing supplier lists against the tool’s risk parameters, creating a baseline risk profile for their supply chains. This data can then be embedded in procurement and compliance management systems, ensuring that risk considerations are integrated into day-to-day supplier interactions. Companies should also consider providing training for procurement teams, compliance officers, and executive leadership on how to interpret and act upon risk scores. By institutionalizing this knowledge, organizations can promote a culture of proactive risk management and ensure that modern slavery concerns remain front of mind in supplier decisions.
Looking ahead, the enhanced visibility provided by the Transparency Register updates and the risk-rating tool creates new opportunities for Australian companies to demonstrate leadership on modern slavery issues. By aligning their public statements with register data, adopting robust risk management tools, and committing to continuous improvement, retailers and manufacturers can set themselves apart as champions of ethical supply chains. These efforts not only contribute to compliance with the Modern Slavery Act but also support broader goals of responsible business conduct, stakeholder trust, and brand reputation. Furthermore, as global supply chain transparency expectations continue to rise, companies that invest in these practices today will be better positioned to navigate emerging regulatory frameworks and market demands for ethical sourcing.
The first updates to Australia’s Modern Slavery Transparency Register mark a turning point in the nation’s fight against modern slavery in supply chains. By learning from leading practices, leveraging open data, and integrating the Australian Border Force’s risk-rating tool, Australian retailers and manufacturers can strengthen their modern slavery responses and enhance their contributions to a fairer, more transparent global economy. The road ahead requires vigilance, collaboration, and innovation, but the tools and frameworks now available provide a strong foundation for meaningful progress.