Due to COVID-19, modern slavery reporting deadlines have been extended and new guidance has been released.

Extension for statements

On 28 April 2020, the Government announced that the deadlines for entities due to lodge statements under the Modern Slavery Act 2018 (Cth) (Act) will be extended by three months.

The extension applies to all reporting entities under the Act operating on reporting periods that end on or before 30 June 2020.

The table below summarises the new reporting deadlines:

Reporting period Original deadline for submission of modern slavery statement New, extended deadline for submission of modern slavery statement
1 April 2019 - 31 March 2020 (Foreign Financial Year) 30 September 2020 31 December 2020

1 July 2019 - 30 June 2020 (Australian Financial Year) 31 December 2020 31 March 2021

Reporting periods ending after 30 June 2020 The six month deadline for reporting periods ending after 30 June 2020 remains unchanged

The Government said that the decision to temporarily extend reporting deadlines recognises the significant and unprecedented impact of COVID-19 on Australian businesses and global supply chains. The extension will provide businesses additional time to ensure they are able to comply with their legislative obligations. Click here to read the announcement.

New guidance

The Australian Border Force has also released guidance on how entities can reduce the risk of vulnerable workers in their operations and supply chains becoming exposed to modern slavery as a result of the COVID-19 pandemic (Guidance), including:

  • maintaining supplier relationships and fostering open communication with suppliers about COVID-19 risks
  • collaborating with suppliers, workers, business peers, investors, civil society and peak bodies
  • reviewing key international resources and implementing, where applicable, guidance to support decent work in supply chains.

The Guidance also explains how reporting entities under the Act can address the impact of COVID-19 in their statements, and encourages reporting entities affected by COVID-19 to clearly explain in their modern slavery statements how COVID-19 has impacted their capacity to assess and address modern slavery risks during their reporting periods.

A link to the Guidance can be found here.

This publication does not deal with every important topic or change in law and is not intended to be relied upon as a substitute for legal or other advice that may be relevant to the reader's specific circumstances. If you have found this publication of interest and would like to know more or wish to obtain legal advice relevant to your circumstances please contact one of the named individuals listed.