MODERN SLAVERY AUDITS
The global economy relies on corporate sourcing and procurement practices along complex transnational supply chains. Some goods and services that find their way to the consumer public are sourced in contexts tainted by modern slavery, including forced labour and human trafficking.
Mandatory reporting and disclosure schemes have long been used to manage risk and impact across various aspects of corporate and market activity. It is only more recently that some governments have begun to use such mechanisms in the context of human rights, including specifically to address modern slavery risks in supply chains.
Evolving mandatory disclosure mechanisms in this context carry some promise in terms of addressing the most serious socially negative ‘externalities’ of global manufacturing supply chains, as well as narrowing the perennial national-level implementation gap in international human rights law.
Such mechanisms have important implications for business and for the legal, accounting and assurance professions, which may be familiar with reporting requirements, but not in a human rights context.
Yet more empirical research is needed, both on the assumptions underlying mandatory human rights reporting schemes and their intended purpose, as well as the drivers and patterns of corporate responses to such mechanisms.
REMOTE DESKTOP AUDIT
Organisations will invariably determine their own strategy by developing action plans for their business divisions and implementing sanctions as required. Businesses should obtain their own legal and compliance advice on their reporting obligations. Businesses can maintain responsibility and transparency in their supply chains through actions such as the following:
- Within your business, build awareness of human rights and modern slavery risks with team members in all areas
- Include clauses and terms that address modern slavery risks in contracts with suppliers and contracts
- Conduct a review of all business operations and those of your suppliers and other business partners to identify areas where there may be a risk of forced labour and modern slavery practices
- Develop action plans to address risks or potential risks identified and then a process to assess effectiveness
- Increase awareness of privacy risks and input relevant controls to mitigate these risks
FULL ORGANISATIONAL AUDIT
The Modern Slavery Act is mainly focused on modern slavery risks and mitigation strategies within supply chains. The Reporting Requirement supports the Australian business community to identify and address their modern slavery risks and maintain responsible and transparent supply chains.
Entities required to comply with the Reporting Requirement must prepare detailed annual Modern Slavery Statements setting out their actions to assess and address modern slavery risks in their operations and supply chains.
This includes a range of matters including actions taken by the entity to assess and address risks of Modern Slavery in its operations and supply chains (including due diligence and remediation processes) and how the entity assesses the effectiveness of such actions to address the risks.
While the problem of modern slavery is a persistent and hidden crime, those working to end it are crippled by three significant challenges: prevailing gaps in collecting and sharing data, limited resources to address slavery, and a challenging policy environment.
Through collective action, these allies are working to confront the individuals and institutions that perpetuate slavery, liberate victims, support survivors, and educate the public. The very persistence and even growth of modern-day slavery indicates both the problem’s complexity and its resistance to many of the initiatives currently in place. It will likely take the entire freedom ecosystem—businesses, governments, NGOs, academia, multilateral organizations, private investors, civil-society groups, and consumers—working together to abolish practices that challenge the best intentions to promote a freer world.
Desktop Audits determine what the entity already does in this space, particularly what existing policies and procedures can be leveraged. A gap analysis will inform next steps and the resources required to eradicate modern slavery from operations and supply chains.