Modern slavery is often discussed as a supply chain problem that happens somewhere far away. But the truth is modern slavery is happening at home too. In fact, Walk Free’s Global Slavery Index estimates that around 41,000 people are living in modern slavery in Australia.
While Walk Free notes that nearly two thirds of forced labour cases are linked to global supply chains, modern slavery can also occur in Australia through domestic labour arrangements, temporary migrant workforces, and contracted services.
In other words, modern slavery in Australia can affect the people who make, move, clean, package, pick, process, and provide the goods and services that flow through everyday business activity.
Australia’s Modern Slavery Act 2018 has helped bring these risks into view. It requires businesses and other entities operating in Australia with annual consolidated revenue of at least $100 million to prepare an annual Modern Slavery Statement that describes how they identify and address modern slavery risks in their operations and supply chains.
Monash Centre for Financial Studies’ Modern Slavery Disclosure Quality Ratings: ASX100 Companies Update 2025, published in December 2025, reviewed FY2024 Modern Slavery Statements from ASX100 companies. It found that a clear divide remains between companies showing leadership and those still taking a minimal compliance approach.
That divide matters. A Modern Slavery Statement is not just a reporting obligation. It is a public signal of how seriously an organisation understands risk, governance, accountability, and human rights.
The next test for Australian businesses is not whether they can produce a statement. It is whether the systems behind that statement are strong enough to find risk, act on it, and show credible progress over time.
Modern slavery in Australia is not only an offshore issue
At home, modern slavery risk can sit in local labour arrangements, contracted services, temporary migrant workforces, and industries where vulnerable workers may have limited power to speak up.
Walk Free identifies domestic forced labour risks in sectors including agriculture, construction, domestic work, meat processing, cleaning, hospitality, and food services, many of which rely on migrant workers entering Australia on temporary visas.
As such, modern slavery risk is not something that can be pushed to the far end of an overseas supply chain. It may sit closer to the organisation in domestic labour hire or supplier relationships that have not been examined closely enough.
That makes the Modern Slavery Statement more than a disclosure document. It becomes a test of whether the organisation has the visibility and governance to recognise risk before harm is hidden in plain sight.
Why compliance is only the starting point
An annual Modern Slavery Statement must describe the actions the organisation is taking to assess and address modern slavery risks in its operations and supply chains. The Australian Government publishes these statements on the Modern Slavery Statements Register.
A Modern Slavery Statement should give stakeholders a clear view of how an organisation is identifying and addressing risk across areas such as:
- Operations and supply chains
- Modern slavery risk identification and assessment
- Supplier due diligence and risk mitigation
- Governance and accountability
- Grievance mechanisms and remediation
- Consultation across owned or controlled entities
- How the organisation assesses whether its actions are effective
The legal requirement matters, but compliance is only the starting point.
Modern slavery reporting now sits in a broader accountability environment. Boards, executives, procurement teams, sustainability leaders, risk teams, and governance stakeholders are expected to understand not only what the law requires, but how modern slavery risk is being managed in practice.
This means a stronger statement cannot be built from better wording alone. It needs to reflect stronger systems.
Where Australian businesses still need to improve
The Monash Modern Slavery Disclosure Quality Ratings show that many companies have improved their reporting. It also shows that progress remains uneven.
The report identifies several recurring weaknesses in low-scoring statements. These include:
- Insufficient supply chain transparency
- Overly general discussion of modern slavery risks
- Weak governance structures and disclosures
- Poorly described grievance mechanisms and remediation processes
- Limited reporting on supplier due diligence
- Absence of measurable KPIs
- Unclear methods and responsibilities
- Limited awareness of available tools and industry initiatives.
Supply chain visibility remains one of the most persistent gaps. Monash found that only 52 per cent of reviewed statements described supply chains beyond Tier 1 suppliers – the direct suppliers an organisation buys from or contracts with – in FY2024.
That is a significant issue because modern slavery risks often sit deeper in the supply chain. If an organisation only understands its direct Tier 1 suppliers, it may miss risks linked to subcontracting, labour hire, raw materials, high-risk geographies, or outsourced production.
The lesson is not that every organisation must have perfect visibility immediately. The lesson is that stakeholders are increasingly looking for evidence of maturity. They want to see whether companies are mapping risk, engaging suppliers, strengthening governance, improving reporting systems, and measuring whether their actions are working.
The gap is no longer just between organisations that report and those that do not. It is between organisations that treat the statement as an annual compliance document and those that treat it as evidence of an evolving risk management system.
The modern slavery reform conversation
The reform conversation has been building since a statutory review of the Modern Slavery Act, which examined the first three years of the Act’s operation and was tabled in Parliament in May 2023.
Led by Professor John McMillan AO, the review made 30 recommendations to strengthen the regime, including introducing penalties for non-compliance, lowering the reporting threshold from $100 million to $50 million, requiring entities to report on modern slavery incidents or risks, and requiring entities to have a due diligence system in place. The Australian Government released its response in December 2024, agreeing in full, in part, or in principle to 25 of the 30 recommendations.
Those reforms are not yet all in force. But they show the direction of travel: stronger expectations, closer scrutiny, and a shift from disclosure alone toward due diligence and accountability.
The arrival of Australia’s first national Anti-Slavery Commissioner also changes the context. Chris Evans, who began his five-year term as the inaugural Australian Anti-Slavery Commissioner in December 2024, has said high-quality reporting is only the first step and must be coupled with action.
What better looks like and why the bar is rising
Better modern slavery reporting starts before the statement is written.
It begins with clearer governance, better supply chain mapping, stronger supplier engagement, and more disciplined risk assessment. It also requires practical systems that allow people to raise concerns and clear pathways for investigation and remediation when issues are found.
Monash identified a range of stronger practices. These include:
- Supplier self assessment questionnaires
- Detailed supply chain mapping
- Supply chain audits and risk evaluation
- Site visits where appropriate
- Supplier risk management plans
- Targeted training
- Worker welfare assessments
- Approved sub supplier lists
- Traceability audits
- Stronger human rights and modern slavery clauses in contracts
It also highlights the importance of multilingual and confidential grievance channels that workers and external stakeholders can access, clear grievance pathways, defined responsibilities, transparent reporting on issues raised, and remediation frameworks that explain how an organisation will respond when harm is identified.
The strongest statements also report indicators that show whether the organisation is making progress. These can include training completion rates, supply chain mapping progress, site audits, supplier audits, supplier code of conduct uptake, risk issues mitigated, grievance channel communication, grievances reported and resolved, remedies provided, third party effectiveness assessment, and participation in industry initiatives.
Table: Modern slavery reporting best practices
| Common gap | What better looks like |
| Limited visibility beyond Tier 1 suppliers | Deeper supply chain mapping across priority categories, geographies, and higher risk supplier tiers |
| Generic discussion of modern slavery risk | Risk assessment linked to specific goods, services, sectors, countries, labour arrangements, and supplier characteristics |
| Weak governance disclosure | Clear accountability across board, executive, procurement, sustainability, and risk functions |
| Limited supplier due diligence | Supplier questionnaires, risk screening, targeted audits or site visits where appropriate, and follow up action plans |
| Poorly described grievance mechanisms | Confidential, accessible, and multilingual channels available to workers and external stakeholders |
| Unclear remediation pathways | Defined escalation processes, responsibilities, remedies, and review mechanisms |
| Activity based effectiveness reporting | Outcome-focused indicators, such as risks mitigated, issues resolved, worker feedback, and improvements in supplier practice |
From statement writing to stronger systems
A credible Modern Slavery Statement does more than meet a reporting deadline. It shows that an organisation understands where risk may sit, how decisions are made, who is accountable, how suppliers are engaged, how concerns can be raised, and how the business will respond when harm is identified.
For many organisations, the opportunity now is to move from statement writing to stronger systems.
The Growth Activists works with organisations to build this more practical approach. The goal is not only to produce a stronger Modern Slavery Statement. It is to help businesses build the governance, visibility, and accountability that make the statement credible in practice.
Get in touch today to find out how we can support your modern slavery reporting.
