The release of the first parliamentary review of Australia’s Modern Slavery Act (2018), published towards the end of 2021, marked an important, though perhaps somewhat sobering, milestone in the country’s effort to combat forced labour and exploitation in supply chains. For those of us tracking the Act’s implementation, the review’s findings were hardly surprising, yet they underscored how far many sectors—particularly apparel and agriculture—still have to go. The review painted a picture of patchy compliance, overreliance on boilerplate statements, and, crucially, persistent transparency gaps in supplier disclosures. The ambition of the Act was always high; the reality, at least so far, has proven uneven.
One of the most striking themes emerging from the review is the gap between policy commitment and operational reality. Many firms, it seems, were able to produce modern slavery statements that ticked the minimum legal boxes without truly disclosing the structure or risk profile of their supply chains. This isn’t entirely unexpected. After all, mapping complex, multi-tiered supplier networks—many of which stretch across jurisdictions where data is scarce or unreliable—is no small feat. But the review made clear that regulators, civil society, and indeed the broader public will not remain patient forever. The era of generic statements is drawing to a close.
For Australian apparel and agricultural companies, this presents both a challenge and an opportunity. The challenge is obvious: existing systems, where they exist at all, often aren’t set up to provide the kind of granular visibility that meaningful modern slavery reporting requires. The opportunity lies in the growing availability of open, NGO-sourced risk data, which can help firms build a far clearer picture of where their supply chain vulnerabilities may lie. One of the most valuable resources here is the Walk Free Foundation’s Global Slavery Index and associated risk maps. These tools, while by no means perfect, offer an evidence base that companies can use to prioritise supplier reviews and engage more constructively with upstream partners. The Index, for example, provides country-level and, in some cases, sector-level risk assessments that can act as an initial filter when deciding where to focus deeper due diligence efforts.
Yet, adopting such data sources is only the first step. The most credible firms are moving beyond static reports or one-off risk assessments and beginning to integrate dynamic, API-based monitoring tools into their compliance processes. This can sound intimidating, but the principle is simple enough. Rather than waiting for annual audits or supplier declarations, companies can use APIs to pull real-time or near-real-time data from inspection bodies, certification agencies, and credible NGOs. In practice, this might mean establishing a link between a company’s supplier management system and databases of factory inspections or labour rights violations maintained by independent bodies. Doing so allows procurement teams and compliance officers to spot potential red flags much earlier than would otherwise be possible.
The parliamentary review highlighted the problem of what might be called “orphan suppliers”—those entities that sit in the murky middle of the supply chain, beyond the immediate view of the importing company but integral to the production process. This is where API-based monitoring can help close data gaps. By connecting internal systems to external data feeds, firms can start to build a more continuous, nuanced picture of supplier performance, even in tiers of the supply chain that have traditionally remained opaque. It is not a panacea; data quality and coverage are still real constraints, particularly in high-risk geographies. But it is an important evolution from the static, backward-looking reports that have dominated modern slavery compliance to date.
Developing an action plan for closing these transparency gaps requires both technical and organisational shifts. First, companies need to inventory their current data sources and systems. What supplier information do they collect? Where are the gaps most acute? Is supplier data centralised or scattered across different teams and platforms? Often, this initial mapping reveals as much about internal process weaknesses as it does about external supply chain risks.
The next step is to identify priority suppliers or geographies for enhanced monitoring. This is where tools like the Walk Free risk maps can provide valuable input. A firm might, for example, decide to focus first on cotton farms in a particular region, or on smallholder agricultural producers supplying raw inputs for food processing. Having identified these priorities, the task becomes one of integrating external data—whether through APIs or batch uploads—into supplier records in a systematic way.
Importantly, this is not just a technology project. Success depends on building internal capacity and accountability. Someone in the organisation needs to “own” the data integration process and be responsible for responding to what the data reveals. Without that, even the most sophisticated monitoring tools risk becoming little more than window dressing.
It is also worth acknowledging that the parliamentary review hinted at potential regulatory tightening. There is growing political appetite to strengthen the enforcement mechanisms of the Modern Slavery Act, including possible penalties for firms that fail to provide adequate disclosures. This adds another layer of urgency to efforts to close data gaps and adopt more robust monitoring approaches. For many firms, particularly those in exposed sectors, the choice may soon be between proactive transparency and enforced compliance.
As companies chart their path forward, the tension between ambition and practicality will no doubt continue. Building a truly transparent supply chain is a complex, multi-year endeavour. But the tools now available—from open NGO data to API-based inspection feeds—mean that firms can make meaningful progress, even in the face of that complexity. The firms that succeed will likely be those that stop viewing modern slavery reporting as a compliance exercise and start seeing it as integral to how they understand and manage their business relationships.