In building a comprehensive Modern Slavery policy in Australia, you should cover several key aspects:
Definition and Scope
Clearly define what constitutes modern slavery, including forced labour, human trafficking, child labour, debt bondage, and other related offences. Specify the industries, sectors, and contexts that the policy will address relevant to your supply chain.
Engage suppliers operating within Australia above a certain size threshold, and encourage them to report on their efforts to identify and mitigate modern slavery risks in their supply chains and operations.
Establish guidelines and frequency of reporting to ensure visibility or performance, escalation of risk, remediation of incidences and wider business awareness.
Conduct a formalised and documented risk assessment to identify the potential for modern slavery in your supply chains and operations. This should involve evaluating your own operations, suppliers, subcontractors, and business partners. Provide guidance, training, or recognised codes of practice, and industry standards to help suppliers and ensure your approaches are aligned.
Make it a requirement for suppliers to publish or report on annual modern slavery statements detailing the steps taken to combat modern slavery, the identified risks, and the actions taken to mitigate them.
Training and Awareness
Encourage and suport your suppliers to train employees and relevant stakeholders about modern slavery risks, identification, and prevention methods.
Include provisions for support and assistance to victims of modern slavery, ensuring access to medical care, legal aid, counselling, and rehabilitation.
Establish an independent team to monitor compliance, review modern slavery statements, and enforce penalties for non-compliance across the supply base.
Promote and be involved in collaborations between government, businesses, civil society organisations, and international partners to collectively address modern slavery issues.
Encourage your suppliers to regularly review and update their policies and practices to stay current with evolving modern slavery risks and prevention strategies. Benchmarking against industry-leading or competitors is important to highlight areas of focus within the MS policy or mitigation strategies where risks or potential exposure has been identified.
Supply Chain Transparency
Emphasise supply chain transparency, requiring businesses to map their supply chains and disclose information about suppliers, subcontractors, and sourcing practices.
Acknowledge the global nature of modern slavery and collaborate with organisations with international operations and experience to address this issue on a broader scale for businesses of sufficient scale and impact.
Modern Slavery Statement (MSS)
For companies with a revenue of more than $100m AUS, an MSS is a mandatory requirement with certain criteria and must be posted online. The facility can also be used for companies that do not meet this threshold and post voluntarily. This is a way to show the effectiveness of your and your suppliers’ MS policies.
An effective modern slavery policy in Australia should be robust, transparent, and responsive, aiming to eradicate modern slavery and uphold human rights both domestically and globally.
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