When Australia’s Modern Slavery Act came into force in 2018, it was heralded as a major step toward eradicating forced labor and exploitation from corporate supply chains. Yet, as with many such regulatory frameworks, the real test came later—when companies began filing statements and regulators assessed whether those statements amounted to more than just well-meaning words. The first Auditor General’s report on the Act, published in March 2022, offers a sobering, though not entirely discouraging, view of how businesses have responded so far. Particularly in sectors like apparel and agriculture, where supply chains can be extraordinarily complex and risks of exploitation higher, the report’s findings raise as many questions as they answer.
The Auditor General’s office set out to evaluate not just the existence of modern slavery statements, but their substance. It seems fair to say that while most companies met the basic reporting requirement—that is, submitting a statement on time—the quality and depth of those statements varied considerably. This isn’t unexpected. Regulatory compliance, after all, tends to follow a learning curve. Still, the report highlighted some recurring weaknesses: generic risk descriptions, vague mitigation plans, and limited evidence of actual supplier engagement. Some firms provided polished documents with all the right language, yet when probed, it was clear these were, at times, exercises in box-ticking rather than meaningful transparency.
One of the report’s more practical recommendations was for firms to make greater use of open industry benchmarking data. The suggestion seems, on its face, almost obvious—why wouldn’t companies want to understand how their practices stack up against peers? And yet, surprisingly few of the submitted statements made reference to widely available resources like the Walk Free Foundation’s data sets. For apparel and agriculture businesses, where modern slavery risks often lurk deep in upstream operations (think cotton farms in remote regions or seasonal farm labor), these benchmarks could provide critical context. By failing to leverage such data, companies risked not only regulatory criticism but also undermined the credibility of their commitments in the eyes of investors and the public.
For firms looking to strengthen their next round of modern slavery statements, taking the Auditor’s advice seriously would mean starting with a reassessment of their risk mapping processes. This might involve comparing their supply chains to Walk Free’s prevalence estimates for specific countries or regions, or reviewing sectoral risk indicators published by civil society groups. It won’t provide a perfect map—no data set can—but it offers a starting point far better than intuition or outdated internal reports. There’s something to be said for the discipline that external benchmarks can impose. They force uncomfortable questions. They make it harder to gloss over gaps with vague assertions of due diligence.
Another point that emerged, sometimes implicitly, in the Auditor General’s review was the need for clearer, more actionable disclosures. Many statements described policies and aspirations in broad terms. Far fewer spelled out, in plain language, what steps had actually been taken in the reporting period. A checklist approach might feel mechanistic, but it could serve as a useful scaffold. For instance, statements could explicitly confirm whether supplier contracts had been amended to include modern slavery clauses, whether audits (desk-based or field) had been conducted, whether remediation plans were put in place where risks were found, and whether grievance mechanisms had been tested for accessibility. It sounds basic, perhaps, but clarity in reporting is often what separates serious effort from performative compliance.
There is, of course, a balance to strike. Overly rigid templates risk stifling the kind of thoughtful, tailored responses that the Act is meant to encourage. But without some structure, statements can veer into marketing copy territory. And that, frankly, is where several of the reviewed submissions seemed to land—full of promise, light on specifics. The Auditor’s report stopped short of naming and shaming, but its tone suggested mounting impatience with this pattern.
For apparel and agriculture firms, one complicating factor is the sheer diversity of their supplier bases. A small clothing brand might source fabric from dozens of mills, each in a different country. A produce distributor could be working with hundreds of farms, large and small, across multiple regions. The effort required to gather meaningful data at that scale is significant. That said, what the report implicitly urged was not perfection, but progress. Even partial supplier mapping, if transparently reported, signals intent and direction. And from a policymaker’s perspective, that’s arguably what the Act was designed to achieve—to nudge firms onto a path of continuous improvement, rather than to expect flawless compliance overnight.
The first Auditor General’s report leaves as much work for regulators as it does for companies. There’s a subtle but real tension between encouraging better practice and enforcing minimum standards. Too much of the former without the latter risks letting laggards off the hook. But an overly punitive approach could chill genuine efforts at transparency. Finding that middle ground will, no doubt, occupy policymakers’ attention in the years ahead.