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IJM Australia’s response to proposed Modern Slavery Reporting Requirement

17 May 2018

IJM Australia is hopeful about the Government’s proposed Modern Slavery Reporting Requirement but is concerned that the lack of penalties for non-compliance could make it difficult to mainstream compliance and create a cultural shift across industry. We believe this shift will be necessary in the fight to tackle slavery not only in Australia’s supply chains, but in the fight to tackle slavery and violence around the world.

The Australian Government’s proposed Modern Slavery Reporting Requirement is based on section 54 of the Modern Slavery Act 2015 (UK) and requires businesses to produce an annual statement about the risk of modern slavery in their supply chains and the actions they are taking to address it. We are encouraged that the proposal addresses some of the weaknesses of the UK model and are consistent with the recommendations made to the Government by IJM Australia and other civil society organisations, but note that the effectiveness of the provision will depend on rigorous and sustained collaboration between business, civil society and the Government’s new Anti-Slavery Business Engagement Unit.

IJM Australia believes that the proposed Reporting Requirement does not go far enough to ensure increased transparency in Australian supply chains. Without a penalty mechanism, it is difficult to see how we can ensure that businesses are completing their annual statements in a way that is truly transparent and useful, and therefore have any impact on modern slavery in supply chains.

We believe that the objectives and funding arrangements of the Anti-Slavery Business Engagement Unit need to be clear and consistent. We would encourage continuous engagement and dialogue with businesses about their Modern Slavery Statements and the follow-up actions that should follow from them, and note that the $3.6 million spread over four years which ‘will be partially absorbed by the Department of Home Affairs’ may be insufficient to cover the significant and vital task of actively monitoring the compliance of more than 3000 companies caught under the Reporting Requirement.

Whilst we are encouraged that the Australian Government is taking steps to introduce a Modern Slavery Reporting Requirement, IJM Australia is concerned that the focus on reducing the risk of modern slavery in the supply chains of Australian businesses will fail to address inherent problems in the public justice systems of developing countries where Australian companies source their goods. IJM works with local authorities in developing countries to investigate and prosecute cases of modern slavery and we believe that strengthened legal systems in those countries will deter primary producers from offering goods tainted by slave labour to Australian companies and their suppliers in the first place.

We hope that supply chain transparency is only the first of many steps taken by Australian Government, business and civil society in partnership to ensure we confront the scourge of slavery at both ends of the supply chain.

International Justice Mission is a global organisation that partners with local authorities to rescue victims of violence, bring criminals to justice, restore survivors, and strengthen public justice systems.

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