In December 2018, the Parliament of Australia passed the Modern Slavery Act. This landmark legislation’s goal is to stop situations where one is forced to work, is controlled by others, treated as a commodity, or have their freedom of movement taken away.  The Act calls on Australian companies to ensure there is no modern slavery occurring in their global supply chains.  

It's estimated that 3,000 Australian and global companies will come under the Act. Those with extensive supply chains in the developing world will find it harder to ensure compliance. In this article, we take a closer look at the situation and how anonymous reporting can be a key part of complying with the Act.

 

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What Is Modern Slavery?

The definition of modern slavery is when people are exploited and not allowed to refuse or leave work due to abuse of power, threats, violence, deception, or coercion. Examples of modern slavery include child labour, human trafficking, forced labour, deceptive recruiting, debt servitude, and of course, slavery.  

The Modern Slavery Act’s goal is to ensure businesses in Australia take the steps necessary to stamp out modern slavery in their supply chain. By publicly reporting how they are combating modern slavery, it shines a brighter light on the subject and encourages better behaviour through their supply chain partners. 

Who Is Impacted By The Modern Slavery Act?

Under the Act, businesses (Australian and foreign) with over $100 million in consolidated revenue need to report what they're doing to combat modern slavery in their supply chains. For entities in New South Wales, the threshold is even lower, at $50 million. 

Industries with specific risk include those that source a majority of their products from the developing world, especially in the Asia Pacific region.  Example include large consumer-focused companies like retailers and large grocery stores, mining & minerals, electronics, and manufacturing companies.  

What Are The Challenges In Complying?

Companies face significant challenges in complying with the Modern Slavery Act, including:

The size of their supply chain. Most organisations have hundreds if not thousands of supply chain partners of varying sizes. This presents a challenge in the sheer number of partners one needs to inspect, audit, and ensure they are in compliance.

The length of their supply chain. Supply chains now reach around the world and globalisation has increased the length of one's supply chain. This means suppliers are now often based in developing countries around the world, making compliance even more difficult due to culture and distance.

Manpower. Adhering to the Act is not an easy task and it takes internal resources, external consultants, as well as a lot of time. A company needs a dedicated team to run their compliance program. Also, there will be a need for consultants, investigators, and everything else it takes to have a successful compliance program. It’s an intensive process and needs a significant investment in money and resources.

Countries you source from. Today’s supply chains often reach into the developing world where there's less of a focus on stamping out modern slavery. You will need to convince partners in these countries to spend their time and resources ensuring they are in compliance. In some cases you will have leverage, in other cases, you will need to convince them to make it a priority.

Visibility. As mentioned, supply chains are now quite large, complex, and often opaque. It’s challenging for a company to get full visibility across their supply chain due to this complexity. With the Act, it’s imperative they now have this visibility into their partners and their activities. 

How Can Anonymous Reporting Help You Comply With The Modern Slavery Act?

As discussed above, supply chains can be complex and have many links. This dynamic makes compliance more challenging. Physical inspections are part of the solution with experts examining your supply chain partners.  Unfortunately, inspections can only go so far and are just part of the solution.

Combining an anonymous reporting platform together with inspections increases the scale of your compliance efforts. Web and mobile-based anonymous reporting platforms increase your eyes and ears on the ground. By having your supply chain partners communicating your platform in their facilities, workers can easily make reports. It's as simple as using a QR code or filling in a simple mobile form to flag up misconduct.

A great analogy to illustrate these benefits is a flashlight. Performing inspections is like shining a flashlight at your partners to see them better. Anonymous reporting gives flashlights to everyone and lets them shine the light; you get to see where it's shining and take action.

What Are The Benefits Of Anonymous Reporting?

There are many benefits of combining anonymous reporting with your existing compliance efforts.

Scale. Inspection of your supply partners is a critical and an important part of any compliance program. However, inspectors can only scale so much before you run into resource and cost constraints.  Anonymous reporting provides the scale to receive reports from anywhere and helps compliment existing inspections. 

It’s 24/7 & global. The internet never sleeps and anonymous reporting lets workers report misconduct at any time. With your supply chain crisscrossing the world, you can receive reports from anywhere.

Focus on where issues are. Anonymous reports shine the light on where misconduct is taking place. Use these reports to focus your investigative efforts and inspections on partners receiving reports.

Ease of reporting. Anyone with a mobile phone can make a report. Whether using a QR code or filling in a simple mobile form in their local language, it’s easy for them to flag up misconduct. 

Management visibility. By using a web and mobile-based platform, management has full visibility into what is being reported and where, as well as the results of the investigations.

Easier compliance with the Modern Slavery Act. While anonymous reporting is not the only answer, it’s definitely one of the answers to help comply with the Act. Setting up a platform shows you are taking the efforts to comply and hear from anyone in your supply chain that wants to report misconduct and violations of the Act.  

What Does An Anonymous Reporting Platform Look Like?

An anonymous reporting platform can help you comply with the Act, but what does a platform look like? When starting your evaluation of an anonymous reporting platform, the following are key features to keep in mind. 

Mobile-enabled. Most supply chains reach into the developing world where mobile phones are more prevalent than personal computers. A platform needs to be mobile-enabled as most reports will come from submissions on a phone. Tools like QR codes and mobile responsive sites help make the process of submitting a report via mobile easier.

Ease of use. Reports will only happen if they are easy to make. The process for a worker to submit a report needs to be fast, simple, and easy for them to follow through with.

Anonymous communication. The platform should provide for 2-way, secure, anonymous communication. Anyone submitting a report will have a natural fear of reprisal, so it’s critical to ensure they know their report is anonymous and their identity is protected.

Multi-lingual. Most supply chains reach into parts of the world that do not speak English. Your anonymous reporting platform needs to be multi-lingual to help make it easier for workers to submit reports. A local language platform will increase the number of reports received and thus increase your chance to spot risk in your supply chain. 

Centralised case management. Anonymous reports can come from any supplier you ask to use your platform. Ensure the reports flow into a centralised platform that lets you investigate each report, identify its source, track its progress, and report on it.

Functionality to automate reports and workflows. Reports can come from anywhere and cover anything. A key feature to triage reports is the ability to automate actions. Apply your business processes to the platform and ensure reports go to the right place. Being able to automatically assign workflows also helps increase efficiencies in investigating reports.

Conclusion

In 2019, companies will need to comply with the Modern Slavery Act. Compliance presents many challenges for companies, especially with the results being publicly available. The benefits of anonymous reporting mean it should be one of the tools you use in your compliance strategy. Having eyes and ears on the ground in your supply chain can help you identify risk you might not uncover through other methods.

 

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