Moving Beyond Compliance in Modern Slavery Risk Management

For many Australian businesses, meeting the requirements of the Modern Slavery Act 2018 is still a relatively new exercise. Since its introduction in 2019, companies with annual consolidated revenue above $100 million have been required to report annually on how they assess and address the risk of modern slavery in their operations and supply chains.

While initial years focused on establishing governance, policies, and reporting processes, there is now a growing expectation from investors, government, and the public that companies demonstrate continuous improvement — showing progress year on year, not just repeating last year’s statement.

Continuous improvement means embedding modern slavery risk management into your core business strategy and raising the bar every reporting period. It means moving from “we have policies in place” to “our actions are demonstrably reducing risk, improving worker outcomes, and strengthening our social impact.”

1. From Compliance to Leadership

The Monash University Modern Slavery Disclosure Quality Ratings for ASX100 companies show a clear trend: leading companies are the ones that treat the Act not as a tick-box exercise but as a framework for building better business. In FY2023, companies like AGL, Fortescue Metals Group, and Endeavour Group demonstrated improved visibility of their supply chains, deeper engagement with suppliers beyond Tier 1, and clearer metrics to measure effectiveness.

This progression is what continuous improvement looks like in practice:

• AGL mapped supply chain spend by country, linked it to risk levels, and integrated findings into sourcing decisions.

• Fortescue provided detailed mapping of its iron ore value chain, including key risk countries and mitigation steps at multiple tiers.

• Endeavour Group illustrated multi-tier supply chains for different business units, signalling a deeper understanding of where exploitation risk might occur.

Each of these examples shows that improvement is not about adding more pages to your statement; it’s about sharpening focus, increasing transparency, and closing gaps in knowledge and action.

2. Setting Annual Improvement Goals

The Modern Slavery Act requires companies to report on the effectiveness of their actions, but the Government’s 2023 review found that most statements lack measurable outcomes. Without clear targets, improvement becomes difficult to prove.

A best-practice approach is to set specific, measurable, achievable, relevant, and time-bound (SMART) goals each year, such as:

• Increase supply chain visibility from Tier 1 to Tier 3 for the top five at-risk product categories.

• Conduct modern slavery risk assessments for 100% of new suppliers in high-risk countries.

• Provide modern slavery training to 90% of procurement staff and key suppliers.

• Establish and promote an independent grievance mechanism in at least three high-risk sourcing countries.

Setting these goals allows you to measure progress in your next statement, demonstrating tangible year-on-year improvement.

3. Leveraging Independent and Survivor-Led Guidance

One of the most significant steps a business can take to accelerate improvement is to involve survivors of modern slavery in the design, delivery, and evaluation of its risk management strategies.

The Freedom Hub (TFH) is a pioneer in this space, offering survivor-informed guidance through its Survivor Advisory Board. This approach is unique because it brings lived experience directly into corporate policy-making and supply chain decision-making.

Why survivor input matters:

• Survivors can identify exploitation patterns and risk indicators that traditional audits often miss.

• They help ensure grievance mechanisms are safe, accessible, and culturally appropriate.

• They provide insight into remediation that is genuinely empowering for victims, rather than tokenistic.

For example, a TFH-supported company working in the hospitality sector reviewed its supplier onboarding process after survivor feedback highlighted that contract terms could indirectly encourage excessive working hours in supplier factories. By adjusting payment timelines and setting realistic production schedules, the company reduced pressure on suppliers and minimised the risk of forced overtime.

 

4. Embedding Continuous Learning in Your Organisation

Improvement is not just about supplier audits; it’s also about your own team’s awareness and capability. Continuous learning should include:

• Annual training updates for procurement, HR, and compliance teams, integrating the latest intelligence from the Global Slavery Index and survivor-informed case studies.

• Cross-functional collaboration so that modern slavery risk is considered in product design, marketing, logistics, and investment decisions.

• Benchmarking against industry peers and leaders, using tools like the Monash University MSD framework or sector-specific initiatives (e.g., the Cleaning Accountability Framework, Seafood Stewardship Index).

By keeping staff informed and engaged, companies create an organisational culture where modern slavery risk management is part of everyday business thinking.

5. Measuring and Reporting Effectiveness

Stakeholders increasingly want evidence that actions are working. Stronger measurement could include:

• Tracking the number and type of grievances raised and resolved.

• Monitoring changes in supplier risk ratings over time.

• Assessing worker satisfaction and safety through anonymous surveys in partnership with NGOs.

• Publicly reporting on remediation outcomes, including survivor reintegration support.

Companies like Origin Energy have begun using interactive maps and dashboards in their statements to visualise progress, making it easier for stakeholders to see where risk is being reduced.

6. Collaborating for Greater Impact

Continuous improvement is easier when companies collaborate. Pooling resources, sharing intelligence, and co-funding remediation can have far greater impact than working alone.

Examples in Australia include:

• Industry working groups facilitated by the Business Council of Australia and the Australian Human Rights Commission.

• Multi-stakeholder initiatives linking businesses with civil society groups for worker engagement in high-risk sourcing regions.

• Partnerships with organisations like TFH that can broker relationships with survivor networks and NGOs on the ground.

7. The Business Case for Continuous Improvement

Investor Confidence and ESG Alignment
Research from Monash Business School shows that in FY2022, 40% of ASX100 companies received an “A” rating for modern slavery reporting, up from just 3% two years earlier. Therefore, highlighting strengthened investor trust and strategic resource commitment to risk management. (Irwin Mitchell; acsi.org.au; KPMG Assets; The Australian; Monash University; investordaily.com.au;)
Additionally, the Australian Council of Superannuation Investors (ACSI) notes that companies linking executive compensation to ESG goals, including modern slavery performance, demonstrate stronger reporting and risk mitigation. KPMG.

Brand Trust and Consumer Perceptions
According to industry analysis, proactive modern slavery due diligence enhances customer loyalty and strengthens brand reputation, differentiating ethical leaders in a competitive market. deloitte.com; Intertek SAI Global Australia; businessthink.unsw.edu.au.
Further, UNSW research confirms modern consumers now prioritise authenticity, transparency, and ethical engagement over traditional marketing, meaning companies must show consistent improvement to maintain trust. businessthink.unsw.edu.au.

Peer Pressure and ‘Race to the Top’
Deloitte highlights the Australian Government’s intention for modern slavery reporting to trigger a “race to the top” effect—where businesses are driven to continuously improve and elevate workplace practices across supply chains. KPMG Assets , deloitte.com, acsi.org.au.
Complementing this, Allens, the law firm, emphasised that continuous improvement in modern slavery policies (risk assessments, grievance mechanisms, contractual controls is an expectation from stakeholders and prepares businesses for forthcoming regulatory changes. Allens.

Why These Matter Together

• Investors reward clear progress with continued or increased capital.

• Consumers maintain loyalty to companies that demonstrate genuine ethical improvement.

• Peers and regulators foster an environment where raising the bar becomes the norm, not the exception.

This triple-aligned incentive, investor trust, consumer loyalty, and regulatory momentum, builds a compelling business case for continuous improvement. If you’d like, I can extract these into a more concise table or integrate them seamlessly into your article’s flow.

 

 

 

 

 

Final Word: Turning Compliance into Legacy

Continuous improvement in modern slavery risk management is not about doing more for the sake of it — it’s about doing better, informed by evidence, guided by those with lived experience, and aligned to the highest global standards.

By setting measurable goals, involving survivors through initiatives like The Freedom Hub’s Survivor Advisory Board, investing in staff capability, and collaborating with peers, Australian businesses can move from baseline compliance to genuine leadership.

In doing so, they not only meet their legal obligations but also contribute to the global effort to end modern slavery, and that is a legacy worth building, year after year.

Find out how TFH Ethical Business Team can help your business improve HERE.