The Modern Slavery Act 2018 (Cth) (MSA) was widely hailed as a critical first step by Australia towards tackling the global problem of modern slavery, with the government proclaiming that it would transform the way businesses respond to modern slavery by prompting a business-led ‘race to the top’.

This report analyses 102 company statements published in the first reporting cycle of the MSA, to evaluate how many companies are starting to implement effective measures to address modern slavery and how many are lagging. Rather than focusing on the largest ASX-listed companies, we examined statements published by companies sourcing from four sectors with known risks of modern slavery:

– garments (sourced in China)
– healthcare – rubber gloves (PPE) (sourced in Malaysia) – horticulture (sourced in Australia)
– seafood (sourced from Thailand)

We first examined whether the statements complied with the mandatory reporting criteria under the MSA and provided meaningful information against all these criteria. We then compared the information about modern slavery risks in each statement with publicly available information about the risks and working conditions in these sectors in order to understand whether companies are appropriately identifying the most salient risks present in their operations and supply chains. Finally, we analysed whether companies appear from their statements to be taking effective and meaningful actions to address these risks.