Modern Slavery Statement Guide for Australian Businesses
Everything you need to know about Modern Slavery Act reporting requirements, the 7 mandatory criteria, deadlines, and how to write an effective statement.
What is Modern Slavery?
Modern slavery describes situations where offenders use coercion, threats, or deception to exploit victims and undermine their freedom. It includes eight types of serious exploitation.
The Scale of the Problem
The International Labour Organization estimates 50 million people are trapped in modern slavery globally. In Australia, an estimated 41,000 people are living in conditions of modern slavery. Every business has modern slavery risks in their supply chain - the question is whether you've identified and addressed them.
Who Must Submit a Modern Slavery Statement?
Mandatory Reporting Entities
Australian entities with $100M+ consolidated revenue
Companies registered or incorporated in Australia
Foreign entities carrying on business in Australia with $100M+ revenue
Must have Australian operations, not just sales
Corporate Commonwealth entities with $100M+ revenue
Government-owned corporations and entities
Proposed Changes Coming
The Government's December 2024 response to the statutory review indicates:
- Threshold reduction to $50M is under consideration
- Civil penalties agreed in principle for non-compliance
- Due diligence requirements to be mandated
- Anti-Slavery Commissioner with expanded powers
The 7 Mandatory Criteria
Your Modern Slavery Statement must address each of these criteria under Section 16 of the Act.
Structure, Operations & Supply Chains
Describe your entity's structure, operations, and supply chains
Include corporate structure, business activities, locations, workforce profile, and key supply chain tiers
Modern Slavery Risks
Identify the risks of modern slavery in your operations and supply chains
Assess geographic, sector, product, and entity-level risk factors across your value chain
Actions Taken
Describe actions taken to assess and address those risks
Include policies, due diligence processes, supplier engagement, training, and grievance mechanisms
Effectiveness Assessment
Explain how you assess the effectiveness of your actions
Include KPIs, audit results, supplier assessments, and continuous improvement processes
Consultation Process
Describe consultation with owned or controlled entities (for joint statements)
Explain how subsidiaries and controlled entities were consulted in preparing the statement
Approval & Signature
Must be approved by principal governing body and signed by a responsible member
Board approval and director signature required before submission
Any Other Relevant Information
Include any additional information relevant to your modern slavery response
Industry collaborations, remediation cases, future commitments, emerging risks
High-Risk Sectors & Geographies
Understanding where modern slavery risks are highest helps focus your due diligence efforts.
Agriculture & Fishing
Seasonal labour, remote locations, labour hire
Construction
Subcontracting layers, migrant workers, informal labour
Manufacturing
Complex supply chains, offshore production, piece-rate work
Hospitality & Cleaning
Cash payments, visa workers, franchise models
Logistics & Warehousing
Gig economy, labour hire, time pressure
Retail & Fashion
Offshore manufacturing, raw material sourcing
Southeast Asia
Thailand, Vietnam, Malaysia, Indonesia, Philippines
South Asia
India, Bangladesh, Pakistan, Sri Lanka
East Asia
China (Xinjiang region particularly high risk)
Middle East
UAE, Qatar, Saudi Arabia (migrant worker exploitation)
Africa
Various countries - mining and agriculture sectors
Preparation Timeline
Start 6 months before your financial year end to ensure a quality statement.
Risk assessment refresh
Update supply chain mapping and risk assessment
Stakeholder consultation
Engage subsidiaries, suppliers, and internal teams
Draft statement
Prepare statement addressing all mandatory criteria
Board approval & submit
Obtain board approval, signature, and submit to register
Common Mistakes to Avoid
Mistake
Generic, copy-paste statements
Solution
Tailor your statement to your specific operations, risks, and actions
Mistake
Focusing only on Tier 1 suppliers
Solution
Assess risks across all supply chain tiers, especially raw materials
Mistake
No meaningful effectiveness measures
Solution
Include specific KPIs and evidence of outcomes, not just activities
Mistake
Treating it as a compliance tick-box
Solution
Embed modern slavery risk management into procurement and operations
Mistake
Late or missed submissions
Solution
Start preparation 3-6 months before your financial year end
Frequently Asked Questions
What is a Modern Slavery Statement?
A Modern Slavery Statement is a public document that describes the steps an organisation is taking to address modern slavery risks in its operations and supply chains. Under the Modern Slavery Act 2018 (Cth), entities with consolidated revenue of $100 million or more must submit an annual statement to the Modern Slavery Statements Register.
Who must submit a Modern Slavery Statement in Australia?
Australian entities and entities carrying on business in Australia with annual consolidated revenue of $100 million or more must submit a statement. This includes businesses, corporate Commonwealth entities, and government-owned corporations. The threshold may be lowered to $50 million under proposed reforms.
When is my Modern Slavery Statement due?
Statements must be submitted within 6 months of the end of your financial year. For example, if your financial year ends on 30 June 2025, your statement is due by 31 December 2025. If your year ends 31 December 2024, it's due by 30 June 2025.
What are the penalties for not submitting a Modern Slavery Statement?
Currently, there are no direct financial penalties, but non-compliance results in public naming on the Modern Slavery Statements Register. The Government has agreed in principle to introduce civil penalties, expected to be legislated in 2025-2026. Reputational risk and customer/investor pressure are immediate consequences.
Can I submit a voluntary Modern Slavery Statement?
Yes. Entities below the $100 million threshold can submit voluntary statements. This is increasingly common as larger customers and supply chain partners require transparency from their suppliers. Voluntary statements must meet the same mandatory criteria as required statements.
What's the difference between the Australian and UK Modern Slavery Acts?
The Australian Modern Slavery Act 2018 has a higher threshold ($100M vs £36M), requires more detailed mandatory criteria, and maintains a central public register. The UK Act requires a statement on the company website. Australia's Act is being strengthened with proposed penalties and due diligence requirements.
About the Author
Lee Stewart
Founder & Principal Consultant, ESG Strategy
Lee Stewart is an Amazon #1 bestselling author with 20+ years' experience leading sustainability strategy for major multinationals including Fonterra and Fujitsu. He is the author of How to Build Sustainability into Your Business Strategy and advises organisations across Australia and New Zealand on ESG governance, compliance, and value-led transition planning.
Speaking: COP28 delegate, Climate Reality Mentor, regular contributor to CFO and governance publications.