The passage of Australia’s Modern Slavery Act in 2018 prompted significant reflection across multiple sectors, but it wasn’t until the first reporting cycles in 2019 that the scale of the challenge became truly clear. Mining firms, manufacturers, retailers—each began grappling, in varying degrees of seriousness, with the Act’s reporting requirements. Yet, for all the initial activity, there remained, through much of 2019 and into early 2020, an uncomfortable sense that most disclosures were generic. Too few companies provided the granularity policymakers, advocacy groups, or frankly, the public, had hoped for. It was in this context that, by mid-2020, both NGOs and several industry coalitions started piloting supplier scorecards aimed at adding meaningful structure to the reporting process.
These scorecards, at their core, sought to move beyond narrative statements and into the realm of measurable, comparable supplier performance. There was no single template. Rather, these were experiments—trial frameworks that tested ways of ranking suppliers not only on the presence or absence of modern slavery risks but on the strength of their controls, the robustness of their worker protections, and their responsiveness to audit findings. The pilots varied in their sophistication. Some focused narrowly on a handful of high-risk commodities; others tried, perhaps over-ambitiously, to cover entire supply chains.
Australian mining companies found themselves at the forefront of these efforts. Given the global nature of their supply chains and the scrutiny they already faced from investors and civil society, it was almost inevitable. One practical step these companies were encouraged to take—one that some adopted with greater rigor than others—was the use of Australian Border Force (ABF) open import data. This data, while not without its gaps, offers visibility into import volumes, origins, and, importantly, importers of record. By cross-referencing this information with internal procurement records, companies could begin ranking smelters or refiners not only by their location or output but by documented compliance levels with the Act’s expectations.
The actual ranking process, though, was and remains complex. Import data tells only part of the story. Mining firms needed to combine these data points with audit results, certifications (where available), and other third-party assessments. Some also began incorporating feedback from workers themselves, albeit in limited pilots. There were challenges—inevitable ones. Data quality varied. Smelter disclosures were often incomplete or delayed. And in some instances, mining companies faced uncomfortable conversations with longstanding suppliers who suddenly found themselves at the lower end of these emerging scorecards.
For those companies now looking to formalize their approach, a step-by-step framework for designing a supplier performance index is worth considering. The first step is mapping the universe of suppliers—identifying, as comprehensively as possible, all Tier 1 and critical Tier 2 suppliers. This mapping should, where feasible, link to ABF import data to validate supply-chain nodes. The second step involves defining the criteria on which suppliers will be assessed. Here, firms need to strike a balance: too many criteria, and the index risks becoming unwieldy; too few, and it loses meaning. Most pilots prioritized indicators like audit outcomes, grievance mechanism effectiveness, remediation activity, and external certification status.
Third, companies must decide on weighting. Not all criteria are equal, and firms must make judgment calls on which indicators matter most given their specific risk profiles. It’s at this stage that internal debates often surface—between legal, procurement, and sustainability teams—as to what the index should ultimately aim to drive: compliance, risk reduction, or broader social impact. The fourth step is validation. Initial drafts of the index should be tested against a sample of suppliers to check for unintended biases or data inconsistencies. It’s remarkable how often well-intentioned indices end up disproportionately penalizing smaller suppliers or those in emerging markets where reporting infrastructure is weaker.
Finally, once confidence in the index is established, firms should consider how to communicate results. Publishing the supplier performance index on corporate websites can enhance transparency, but it also raises risks if not done carefully. The temptation might be to sanitize the data, to present only aggregated scores or positive findings. Yet, there’s growing evidence that stakeholders—whether regulators, investors, or the public—value honesty over perfection. Some firms have begun sharing supplier scores along with contextual explanations: where improvements are needed, what support is being offered, and what consequences, if any, are being applied for underperformance.
It is fair to say that the first supplier scorecard pilots were imperfect. But then, perfection was never really the goal. The point was to learn, to push companies beyond static compliance statements and towards dynamic, data-informed supply chain management. As mining companies, and indeed other sectors, refine their approaches, the hope—expressed quietly in some quarters—is that these tools will eventually embed modern slavery considerations deeply into procurement practices, not as an external reporting obligation but as a core operational priority.