Australia Modern Slavery Act
Preparation: The Key To Effective Reporting
Australia’s Modern Slavery Act came into effect on 1 January 2019. While the first reporting period is not until 2020, there are several actions companies should begin now to help effectively meet reporting requirements.
Australia now has Modern Slavery Reporting requirements at the Commonwealth level and in New South Wales via state legislation. Reporting guidelines were released for public comment closing on 19 May and gives further detail on the expectations for compliant reporting. Understanding and documenting key risks within companies and their supply chains and conducting a thorough risk assessment now will help assess the complexity of the task ahead. It will also set a road map for protecting and enhancing business reputation among diverse stakeholders.
Reporting requirements and coverage of the Commonwealth & NSW Acts are similar, but not identical, meaning several discrepancies will need to be worked through. This includes:
- The size of company – more than 3,000 companies are likely to be required to report under the Commonwealth Act with a number of others captured by the lower revenue threshold for the NSW Act.
- Application of penalties for non-compliance differs between the two Acts creating an unclear situation on compliance risk for those companies captured by both Acts.