At the outset of implementing a modern slavery risk management framework you need a high level project plan that will guide how you will manage the risk of modern slavery in your supply chain and operations as well as prepare for reporting under the Modern Slavery Act 2018 (Cth) (Act).
Who will be responsible for the project? You should establish a project team and hold an initial briefing session about the Act and obligations and workshop potential areas of risk.
In this initial stage, it is important to understand your external legal and regulatory obligations as those obligations will inform the structure and content of your modern slavery risk management framework.
As a foundation for your program, your business should make a commitment to manage the risk of modern slavery within its operations and supply chain. This commitment is significant as it demonstrates to your stakeholders and competitors, that your business is committed to minimising the risk of modern slavery and adverse human rights impacts.
Once this commitment is made, the work to embed the commitment into the operations of your business needs to start. You need to look at relevant policies and procedures and consider whether they uphold the commitment. For example, what commitments do you require of your suppliers and is modern slavery risk a factor in supplier selection?
Stay tuned for resolution 2 – undertaking a risk assessment.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.