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  • The deadline for submission of modern slavery statements is fast approaching, with due dates depending on the financial year in which reporting entities operate.
  • Our six-step compliance program offers practical guidance to help organisations meet the requirements under the Act and establish a robust modern slavery program.
  • Organisations which are not captured by the regime should still consider the steps outlined, as they will increasingly be requested to answer questions about their supply chain by reporting entities. Strong responses can have positive reputational implications and strengthen upstream supplier relationships.

The United Nations and The Walk Free Foundation estimate there are currently 40.3 million victims of modern slavery worldwide (Australian Government, Commonwealth Modern Slavery Act 2018 Guidance for Reporting Entities (‘Commonwealth Guidelines’)). Whilst the term slavery is traditionally associated with historical atrocities where individuals were bought, sold and worked as chattels, slavery is more common now than in previous centuries and continues to generate billions in unconscionable profits each year. In response to a growing call to action to end these practices, the Australian government introduced new legislation, the Modern Slavery Act 2018 (Cth) (the ‘Act’), which came into operation on 1 January 2019. Mandatory annual reporting obligations regarding modern slavery risks in operations and supply chains now apply to Australian entities, or foreign entities operating in Australia, with at least $100 million in consolidated annual turnover. With the Act now operative, Australian organisations are grappling with how to comply.

When is your company’s statement due?

An organisation’s first modern slavery statement is due within six months following the end of its first full financial year after 1 January 2019. The Commonwealth Guidelines provide the following snapshot, although individual advice should be sought:

Entity’s annual reporting period
First reporting period under the Act
Due date for statement
1 July – 30 June (Australian Financial Year)
1 July 2019 – 30 June 2020
No later than 31 December 2020
1 January – 31 December (Calendar Year)
1 January 2020 – 31 December 2020
No later than 30 June 2021
1 April – 31 March (Foreign Financial Year – including United Kingdom and Japan)
1 April 2019 –31 March 2020
No later than September 2020

Six-step compliance program

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