CU LAB: The Modern Slavery Act: Are my supply chains slave chains?


the Australian modern slavery Act that
will hopefully be enacted by the end of 2018 is going to implement the
groundbreaking requirement that large Australian companies or companies
operating in Australia report on the steps that they’re taking to combat
slavery in their business operations and their supply chains the companies and
organizations that are going to be affected by the modern slavery
legislation are going to be those companies with a operating annual
turnover of exceeding 50 million dollars and operating or having any part of
their business or headquarters in Australia so that will include
multinational companies operating in Australia and also relevantly government
bodies and agencies and our role model citizen the Australian Government well
there are a number of steps that businesses will need to start taking now
to prepare for the content of their modern slavery statements which will
most likely be due by November 2020 and one of the first things you should do is
educate your senior leadership team and your board to ensure that they are aware
of this important initiative and they start taking steps to dedicate time and
resources to it once you’ve educated your board and your board is is ready to
implement modern slavery policies and procedures throughout the organization
you should then appoint somebody in your senior leadership team to monitor
compliance with those policies and procedures and then to report back to
the board on a periodic basis as to how that is going the next thing you should
do is to look at your supply chain and map them and work out who are the
high-risk suppliers in terms of there being no risk of modern slavery and you
can look at an industry or you can look at a sector where it’s likely modern
slavery risks are prevalent and that could be for example the fishing
industry the construction the mining the property industry a number of high-risk
goods those that come from the high-risk countries like cement or steel or cobalt
for example that is mined in the DRC once you’ve mapped your supply chain
you’ll need to investigate those suppliers and one of
tools that you can use to do that is to issue your supply with a self-assessment
questionnaire and try to capture as much information as about about the supplier
as possible that might be by conducting reputational assessments and looking at
other company company data and the next thing you should do is to implement
training for all of your staff so that your staff and your suppliers are aware
of these modern slavery policies and procedures and that they start to adhere
to it and that could be by updating your a module so your learning modules are
rolling out more detailed training for senior management of the company you’ll
need to update your training regularly and you’ll need to give it to new
starters so that they’re aware of your company policies and you’ll need to do
the same thing with supplies including updating supplier contracts to ensure
that the supplier is adhering to your modern slavery policies and procedures
and the other thing you can do is start to collaborate with other businesses the
point of this disclosure law is to get businesses to work together to combat
what is a global issue and so that could be by sharing resources perhaps it’s
sharing an audit report by adopting that the same procedures with respect to a
common supplier and sharing information that you capture in relation to that
supplier and finally the last thing you can do now fairly easily is to implement
a whistleblowing policy that’s to ensure that your employees feel comfortable
pointing out any risks that they might see of modern slavery taking place in
the business or perhaps in the supply chain

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