Wednesday, 21 July 2021 23:58

Australian big business barely meeting modern slavery disclosures Featured


While the world scrambled to be GDPR-compliant it appears companies are barely striving to do the minimum when it comes to modern slavery laws and disclosure. The legislation might be considered the GDPR of the supply chain but is becoming little more than a box-ticking exercise by big Australian corporates.

Sadly, slavery has never been eradicated from the earth and continues in various guises to this day. The term modern slavery covers a range of practices that use coercion, threats, violence, or the abuse of power to exploit and deprive people of their freedom. This includes human trafficking, labour and debt bondage and other ways. The International Labour Organisation estimates over 40 million people globally are living and working in slave-like conditions.

In fact, many of those people may well be producing goods as part of your own organisation's supply chain - smartphones and other gadgets, along with the raw minerals used to construct them, for example.

The Australian Government says it is taking a global leadership role in combating modern slavery, mandating compliance and reporting. Earlier this year, 31st March 2021, was the deadline for reporting entities to file modern slavery statements and Australian businesses were called to action.

This wasn't new news; the Australian Council of Superannuation Investors (ACSI) advised its members in 2019, “eradicating slavery is a mainstream corporate responsibility that is now enshrined in law. Under the new Modern Slavery Act, Australian businesses must report on their exposure to modern slavery risk” (which, of course, included superannuation funds.)

In fact, the legislation is from 2018 and became active on the first of January, 2019, requiring Australian businesses with over $100 million consolidated annual revenue to provide an annual public modern slavery statement and to report on the effectiveness of the measures they are taking.

However, ACSI said today Australia's top 200 public companies are falling short on their modern slavery disclosures. In fact, they say these companies are providing the bare minimum in terms of disclosing their exposure to modern slavery risk.

Only 5% of companies clearly articulated how they may be involved in modern slavery risk. Many organisations reflected on their own concern of slavery in their supply chain rather than within their operations, and in fact, 65% stated they saw no modern slavery risk factors relating to their own operations.

Tattarang provides a comprehensive 33-page statement detailing the organisation's staffing numbers, the amount of its spend by country, drills into its supply chain and its suppliers and investor’s supply chain, includes a case study of the risk assessment performed on one of its entities, and provides a detailed risk register along with actions being taken.

However, by contrast, iTWire quickly found a brief online statement by an ASX-listed company that said that business has "instituted a Supplier Code of Conduct that embodies our key principles, including its expectations that suppliers will abide by human rights laws.”

Another easily-found disclosure from an ASX-listed company was a six-page document including cover page and company background, with a two-line statement on page six, “Potential risk areas include where a local supplier is engaged to source a product from an overseas source. Further supplier on-boarding refinement over the next financial year will be focused on these identified potential risk areas.”

The Tattarang statement is thorough; the other two are not so and are representative of the bulk. 

ACSI concludes it is likely many companies simply do not understand how businesses fit into human rights frameworks and are poorly prepared, and consequently, are taking no or few steps to put grievance mechanisms in place for affected workers.

It is imperative companies participate in rooting out modern slavery from its supply chain, from the supply chain of its suppliers, and from its own operations, in every way it occurs.

Large Australian businesses clearly continue to struggle with the legislation, but these obligations - indeed, the human rights obligations implicit in dealing with human beings around the planet - can only be met by weaving them into end-to-end processes, policies, and operational technology.

The European General Data Protection Regulation, or GDPR, was visible and widely enacted. It’s the reason you are prompted to accept cookies on any website you visit. Yet, the fanfare and noise around the 2018 modern slavery legislation were virtually non-existent.

Happily, companies need not go on this journey alone. Coupa Software, for example, is a global cloud-based business spend management (BSM) software services company. The business is committed to promoting a workplace and supply chain free from modern slavery and human trafficking. Coupa offers a comprehensive platform on procurement, invoicing, expense management, and payment modules to aid companies in providing visibility and control into how companies spend money, assessing and managing risks.

This is an important topic and companies must recognise the gravity of their responsibility in combatting the evil of modern slavery. The legislation compels modern slavery disclosures but is a pointless, toothless exercise if businesses treat it as a tick box activity to spruik their organisation’s services while neglecting to explicitly detail their internal investigations, actions, and risks. Fortunately, no business needs to go it alone with the aid of a partner like Coupa.

I need to also take this moment to remind readers again of the Global Emancipation Network (GEN). I have written about GEN in the past, but cannot ever forget the seriousness of their mission to find every victim and stop every trafficker. I was introduced to GEN while in Washington DC in 2017 through big-data acquisition and analytics software firm Splunk. Splunk provided services and software to GEN as part of their charitable Splunk for Good pledge, with GEN using data analytics to disrupt human trafficking operations and embark on effective rescue operations. Sherie Caltagirone has devoted her life to combatting this evil in the world.

Where do we go from here? If you're a business, look into Coupa and your modern slavery risk profile - not simply because it is legislated, but because it’s the right thing to do. If you’re a person, look into GEN and how you can contribute to the work they do.

Image credit: "NOT for sale: human trafficking" by Maria Charitou is licensed under CC BY-ND 2.0

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David M Williams

David has been computing since 1984 where he instantly gravitated to the family Commodore 64. He completed a Bachelor of Computer Science degree from 1990 to 1992, commencing full-time employment as a systems analyst at the end of that year. David subsequently worked as a UNIX Systems Manager, Asia-Pacific technical specialist for an international software company, Business Analyst, IT Manager, and other roles. David has been the Chief Information Officer for national public companies since 2007, delivering IT knowledge and business acumen, seeking to transform the industries within which he works. David is also involved in the user group community, the Australian Computer Society technical advisory boards, and education.

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