Joint Submission on Australian Modern Slavery Act 2018’s Draft Guidance for Reporting Entities

In May 2019, ICAR, FLEX, and CORE made a submission to Australia’s Modern Slavery Business Engagement Unit, commenting on the Australian Modern Slavery Act 2018’s Draft Guidance for Reporting Entities.

Providing detailed guidance and advice to reporting entities will be essential to ensure the effective implementation of Australia’s Modern Slavery Act, as argued in ICAR and FLEX’s recent report, Full Disclosure: Towards Better Modern Slavery Reporting.

ICAR, FLEX, and CORE therefore urge the Australian Government to strengthen its Draft Guidance for Reporting Entities, recommending that the Guidance should:

1.     Encourage integration of a gender sensitive approach when reporting entities seek to describe and explain measures taken to address modern slavery risks.

2.     Encourage disclosure of factory names and addresses to adequately describe a reporting entity’s structure, operations and supply chains.

3.     Urge consideration of modern slavery as part of a continuum of other labor rights violations and to include information related to risks, instances and measures to address broader labor abuse which may lead to modern slavery.

4.     Encourage consideration of how reporting entities’ own business models and practices may be conducive to risks of modern slavery and implement and report on measures to address such risks in their statements.

5.     Urge consideration of workforce characteristics and specific risks related to the nature and background of their workforce when assessing modern slavery risks.

6.     Encourage consultation with relevant stakeholders in an ongoing process, including during the phases of risk identification, development of prevention and mitigation measures, reporting, and assessing the effectiveness of measures.

7.     Include and describe key criteria to ensure the effectiveness of grievance mechanisms.

8.     Recommend that reporting entities describe the measures they plan to take in the future to continue addressing identified risks.

The full submission can be downloaded here.

For more information, please contact Marion Cadier at marion@icar.ngo.

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