With many of our clients in their second or third year of modern slavery reporting, we’ve been looking for opportunities to help accelerate their modern slavery risk management and due diligence programs to demonstrate how they are practically addressing the issue and striving for continuous improvement. 

What data trends did we see in modern slavery risk analysis among our clients in 2022? In 2022 we assessed close to $9 billion of procurement spend from Australian (or Australian-based) companies against modern slavery risk indicators (including geography, commodity, industry sector and workforce profile). Pouring over this amount of data and working closely with procurement teams provided some useful insights into trends and issues to consider when assessing and addressing supply chain risk.

In 2022 we assessed close to 200 of our clients’ suppliers for modern slavery risk in their operations and supply chains using our shallow and deep dive SAQ Self Assessment Questionnaire process. Suppliers provided a diverse range of goods and services, including explosives, construction materials, plant and equipment, medical technology, packaging, ICT components, security, shipping and logistics services, industrial robots and agricultural products to name a few.

Supporting our clients to prepare Modern Slavery Statements has highlighted the importance of engaging Executive Leadership Teams and Boards early and often. Ensuring the Board understands the type and scale of modern slavery risks, and how their organisation may cause, contribute to, or be directly linked to modern slavery is critical.

On 23 August 2021 the Australian Senate passed the Customs Amendment (Banning Goods Produced by Forced Labour) Bill 2021 containing provisions that would prohibit the importation of goods produced or manufactured using forced labour. To have any tangible impact, it is important to consider just how far along the supply chain the new Bill will require importers to look. What level of certainty (i.e burden of proof) will be required? And what implications will it have on bilateral trade?

With one month to go to the end of the second Modern Slavery reporting period for many entities, we’ve been busy analysing nearly $20 billion of spend from over 60 Australian businesses (across thirteen industry sectors) for modern slavery risk. We use our proprietary Category Risk Taxonomy (CRT) to assess potential risk within an entity’s supply chain based on spend, supplier and supply category.

Over the last five years we have worked with a wide cross-section of Australian businesses and assessed tens of billions of dollars of spend to refine our Modern Slavery Supply Chain Risk Assessment process. Our proprietary Category Risk Taxonomy enables us to assess and rank over 600 spend categories for potential risk, based on four key modern slavery risk indicators.

Incorporating assessment of corruption not only into a single index, but into a multi-faceted understanding of where an entity’s risks lie, provides a more robust approach to assessing and addressing modern slavery risks in complex, multi-tiered global supply chains.

Beneath the promise of a catch-all indicator that accurately outlines the prevalence or risk of modern slavery, lies complexities wrought with failures of enforcement, informal labour markets that make measurement near impossible, and a lack of social support systems that render workers at risk of coercion. While rankings can make complex information easy to process, they cannot provide give a complete story about countries’ potential risk for the purpose of supplier prioritisation.

The representation of modern slavery ‘success’ through simple, easy to understand rankings and indices serves to suggest that modern slavery or other complex social issues are straightforward to understand. Condensing complex national environments and risk contexts renders historical processes of colonisation and resource exploitation by powerful countries invisible, and strips available data of its geopolitical context.

While easily understood, a ranking or index alone gives little insight into the characteristics of risk within a particular country. The complexity of modern slavery risk for businesses looking to map their supply chains necessitates a deeper understanding of how risks manifest across different contexts and industries around the globe.

With the much-anticipated return of the German Bundesliga this Saturday (16 May 2020), and English Premier League fans hoping for a June return of the season, it seems timely to take a look at ‘The World Game” and its world wide-supply chain through a modern slavery lens.

Seven years ago today, the Rana Plaza garment factory in Bangladesh collapsed, killing 1134 people and injuring many more. The disaster sparked an outcry for greater transparency and accountability in fashion – but how far have we really come?

While civil society increasingly holds corporations accountable for modern slavery or broader human rights impacts, transparency in reporting requirements (such as those in Australia’s Modern Slavery Act) appear to focus less on ‘accountability’ and more on ‘countability’. But what does this mean practically? Does it matter? And can countability lead to accountability?

Mapping your supply chain is one of the widely recognised ‘first steps’ to managing modern slavery risk. However, before you start mapping it’s important to identify where the risk lies. Prioritising potential supplier risk using the right spend data and risk factors lets you focus time and resources on where the actual risk is.

Presenting with a panel of experts at a recent Modern Slavery Forum hosted by the Catholic Archdiocese in Sydney, I was asked how prepared Australian businesses are to manage modern slavery risks. We also dived a little deeper into understanding some of the gaps Australian businesses face in meeting their modern slavery reporting requirements.