INTHEBLACK July/August 2023 - Magazine - Page 27
improve compliance are needed, such as
by implementing stiffer civil penalties for
businesses that fail to comply.
The proposed amendments reflect the
recommendations in a new report, Broken
Promises: Two years of corporate reporting under
Australia’s Modern Slavery Act.
The report has examined the second year
of corporate statements submitted to the
Australian Government’s Modern Slavery
Register. It considered statements from 92
companies sourcing from four sectors with
known risks of modern slavery – garments,
rubber gloves, seafood and fresh produce.
The results show that 66 per cent of
the companies reviewed are still failing
to comply with the basic reporting
requirements mandated by the legislation,
with some companies not submitting
reports at all.
A further 43 per cent of companies
have failed to identify obvious modern
slavery risks in their supply chains.
Report co-author Amy Sinclair, senior
researcher and regional representative for
Australia, New Zealand and the Pacific
at the Business & Human Rights Resource
Centre, says reporting alone is unlikely
to result in the transformative changes
to corporate practices that are needed
to eliminate modern slavery.
“Companies should be required to take
action in the form of effective human rights
due diligence. They should be proactively
looking for risks of modern slavery in their
operations and supply chains and figuring
out how they will address those.
“Ideally, there would be an investigative
element attached to the commissioner
role, rather than it just being simply an
awareness-raising role.
“We’d like to see penalties introduced,
so that, at a very minimum, companies
are actually reporting in accordance with
the Act and producing the disclosures that
are required,” Sinclair says.
THE RIPPLE EFFECT
Patrick Viljoen CPA, senior manager ESG
at CPA Australia, says that a recent joint
submission to the Australian Government from
CPA Australia and Chartered Accountants
Australia and New Zealand emphasises the
need to move away from a pure compliance
focus. Instead, a more comprehensive
understanding is needed about how to engage,
on an ongoing basis, with suppliers in the
process of eliminating modern slavery and
uplifting the supply chains as a result.
“Companies should be required to take action in the
form of effective human rights due diligence. They
should be proactively looking for risks of modern
slavery in their operations and supply chains and
figuring out how they will address those.”
AMY SINCLAIR, BUSINESS & HUMAN RIGHTS RESOURCE CENTRE
“We see the anti-slavery commissioner
working in two ways. Firstly, to provide
appropriate guidance that will be needed
for the level of upskilling and support for
preparation and reporting. Secondly, to take
action,” Viljoen says.
“We need to help people understand, in
practical terms, what modern slavery in their
supply chains might look like and what they
need to do to address it.”
Looking specifically at the financial
services industry, Louise Davidson, CEO of
the Australian Council of Superannuation
Investors (ACSI), points to risk areas in
supply chains. This includes IT procurement,
logistics, and property and building services
– such as facilities management, utilities,
cleaning, waste management and security,
and print and promotional goods.
“It can be challenging to have visibility
over the IT and other procurement supply
chains, so financial services companies need
to consider how they can engage with their
direct suppliers about their approach and
performance in relation to human rights and
supply chain management,” Davidson says.
Accountants play a leading role in this
space, because it involves due diligence and
reporting, Christ adds.
“If you look hard enough, you will find
modern slavery in your supply chains, and if
you are unsure of what steps to take, there are
a number of organisations that have developed
tools that can help businesses engage with
their supply chain,” Christ explains.
“I’m working with a brilliant company in
New Zealand called AskYourTeam. They
have developed an app-based tool that
migrant workers, among others, can use to
report the conditions they are working under.
“Their concerns don’t go directly to the
person they are working for. They might go
to a supermarket chain, for example, who
can see where there might be an issue with
a particular labour contractor. Once problems
have been identified, organisations can act,”
says Christ.
LISTEN
to an audio
recording of
this article
READ
CPA Australia’s
modern slavery
statement
READ
CPA Australia’s
Modern Slavery
Compass
LISTEN
to a With Interest
episode on modern
slavery in global
supply chains
intheblack.cpaaustralia.com.au 27
