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Modern Slavery

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Written by Support
Updated over 3 weeks ago

Why Do You Need to Do This?

The Modern Slavery Act 2018 requires large businesses (those with annual consolidated revenue over $100 million) to report annually on the risks of modern slavery in their operations and supply chains, and the steps they are taking to address them.

Even if your business is small and not directly required to report, companies that do report must assess their entire supply chain. This includes checking with small suppliers and subcontractors like you to ensure modern slavery risks are identified and managed throughout the network.

What Is Modern Slavery?

Modern slavery includes serious forms of exploitation such as:

  • Forced labour

  • Child labour

  • Debt bondage

  • Human trafficking

  • Unfair or exploitative working conditions

These risks can exist both within Australia and overseas, particularly in industries or supply chains involving low-cost goods, raw materials, or offshore labour.

How Should You Respond?

As a small business or sole trader, you're not expected to carry out audits or have complex reporting systems. However, you are expected to show that you:

  • Understand what modern slavery is

  • Are aware of risks in your supply chain

  • Take reasonable steps to avoid supporting it

You can address the following three areas in your response:

1. Describe the measures undertaken to reduce the prevalence of Modern Slavery in your supply chain

Build your response:

Part 1: Who do you buy from?

  • Name actual suppliers (Bunnings, Office works, your wholesaler)

  • Don't just say "reputable suppliers"

Part 2: What would make you stop using someone?

  • Think of a real red flag (workers seem scared, no invoices, cash only)

  • Say what you'd actually do (stop using them, report it)

Write 2-3 sentences: Start with who you work with, then explain what you check for, and finish with what action you'd take if concerned.

2. Can you provide stakeholders with reliable insights into the Modern Slavery footprint of your goods and services?

Build your response:

Part 1: How simple is your supply chain?

  • Do you import anything? (Yes/No)

  • Can you name your main suppliers? (List 2-3)

Part 2: Would you share this info?

  • Say yes if someone asks

  • Mention what you could tell them (supplier names, what you buy)

Write 1-2 sentences: State how simple your supply chain is and confirm you're willing to share details if asked.

3. Describe how you maintain awareness of Modern Slavery in your supply chain

Build your response:

Part 1: How do you stay aware? (be honest)

  • Use common sense about prices being too cheap

  • Stick with known local suppliers

  • Check businesses have ABNs

Part 2: What makes you suspicious?

  • Unusually low prices

  • No proper documentation

  • Workers who won't talk or seem scared

Write 1-2 sentences: Explain your practical approach to staying aware and what warning signs you watch for.

Tips for Tailoring Your Answer

Depending on your business, you might also include:

  • If you have employees: Confirm they are legally employed, fairly paid, and working in safe conditions.

  • If you use subcontractors: Mention whether you check their legal work rights or ask about their business practices.

  • If you import goods: Briefly explain how you assess supplier risk (e.g. country of origin, supplier reputation, ethical sourcing policies).

  • If you only work locally: Highlight your use of trusted, low-risk suppliers and your awareness of modern slavery issues.

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