Modern Slavery: reporting requirements have commenced

Further to our recent update, the modern slavery reporting requirements under the new Modern Slavery Act 2018 (Cth) have now commenced. The legislation, which commenced on 1 January 2019, requires entities based, or operating, in Australia, which have an annual consolidated revenue of more than $100 million, to report annually on the risks of modern slavery in their operations and supply chains, and actions taken to address those risks.

The first reporting period under the legislation will be the organisation’s first financial year starting on or after 1 January 2019. For most companies with a standard Australian financial year, the first reporting period will be FY2019-2020 with the first report due between 1 July 2020 and 31 December 2020.

We expect in early February the Federal Government will issue further guidance and support to assist companies in meeting their reporting requirements. Until that occurs, see our October article for a comprehensive overview of the legislation and the steps that organisations should be taking to prepare to meet their obligations.

In the meantime, organisations should, if they have not already, begin to map their supply chains and identify potential modern slavery risks in their operations. Organisations should also review the policies and procedures they have in place in relation to modern slavery, including supplier codes of conduct and human rights policies.

Gadens can assist organisations to meet these new reporting requirements, together with reviewing existing policies, supplier terms and implementing risk management / due diligence frameworks to identify and appropriately respond to modern slavery risks.

Authored by:
Brett Feltham, Partner
Emma Corcoran, Lawyer