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
The form will ask you a series of direct questions. Here's how to answer each:
1. Are you required to provide a Modern Slavery Statement as per the Modern Slavery Act 2018 OR have you voluntarily developed a statement? (Mandatory for companies with an annual consolidated revenue > $100M)
Most small businesses will answer No — a statement is only mandatory once your annual consolidated revenue exceeds $100M, or if you've chosen to publish one voluntarily.
2. Has your organisation had any breaches in relation to bribery, corruption or labour/human rights breaches?
Answer honestly, briefly describing what happened and what corrective action was taken.
3. Do employees receive training on modern slavery or human rights?
This doesn't need to be a formal course — an induction that covers fair work practices counts. If you don't currently provide any, answer honestly and note whether you plan to introduce something.
4. Do you source products/services from overseas?
If yes, list the countries you import from or contract with.
5. Have you assessed modern slavery risks in your operations or suppliers?
The expected answer is Yes. A formal audit isn't expected — knowing who your suppliers are, considering whether their industry or location carries higher risk, and staying alert to warning signs all count as assessing risk. If you haven't done this yet, note what steps you plan to take.
6. Does your organisation employ labour hire providers?
Answer based on your current workforce arrangements.
7. Do your workers pay any recruitment or placement fees?
Recruitment or placement fees charged to workers are a common indicator of exploitative labour practices, so the expected answer is No. If workers do pay such fees, explain the circumstances.
8. Do all workers have clear written contracts before starting?
Workers without clear written contracts are more vulnerable to exploitative arrangements, so the expected answer is Yes. If not, explain what you use instead.
9. Do workers have a safe way to raise concerns or complaints?
A safe way to raise concerns helps surface labour rights issues early, so the expected answer is Yes. If not, explain how workers can raise them.
10. Do you pay workers in cash?
Cash payment alone isn't a breach, but you should be able to explain the circumstances (e.g. casual or one-off work).
11. Any comments or improvement plans for the next 12 months?
Use this to note any planned improvements, e.g. "reviewing supplier contracts in Q1."
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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