Six years after the Modern Slavery Act 2018 came into force in Australia, organisations with the most impressive modern slavery responses are moving well beyond addressing the minimum reporting requirements.

A common thread of those impressive statements is that they treat modern slavery risk management as a core part of their corporate governance and supply chain frameworks. These organisations embed proactive, evidence based due diligence into procurement and supplier management workflows, rather than treating it as a retrospective risk assessment exercise.

This article outlines practical steps to help organisations strengthen their modern slavery statements, enhance transparency across their supply chains, and move from basic compliance to credible, data driven operational  risk management.

What is the state of modern slavery reporting in Australia in 2025?

While the Modern Slavery Act 2018 currently lacks penalties for non-compliance, many reporting entities have matured well beyond the initial approach taken where companies were challenged by how to identify modern slavery risks and what risks were appropriate to report. The focus has now shifted toward how to operationalise modern slavery due diligence, effectively engage suppliers, and demonstrate measurable impact against activities that the organisation previously reported on.

The seven mandatory reporting criteria under the Act remain unchanged. There has been no legislative amendments in relation to introducing penalties for non compliance, lowering reporting thresholds or enforcing mandatory due diligence. 

However, the broader global landscape is evolving. Due diligence legislation globally shows a trend towards stronger accountability. Global trading relationships increasingly depend on demonstrable human rights performance and supply chain transparency. For Australian companies seeking to diversify and remain globally competitive, the ability to demonstrate a credible human rights record and ethical supply chain practices supports market access, improves investor confidence, and unlocks international partnerships.

What makes a modern slavery statement credible in 2025?

The standards for a “reasonably proficient” statement have changed significantly between 2020 and now. Early reporting focused on awareness and internal policy commitments; today, those are table stakes. The emphasis has shifted to evidence, measurable outcomes, and global engagement.

A credible modern slavery statement is like a tax return. It should be complete, accurate, and consistent across reporting periods. In 2025, a strong statement should:

1. Be grounded in verifiable due diligence data.
2. Address both Tier 1 (direct) and deeper supply chain exposure.
3. Show progress against previous commitments.
4. Demonstrate supplier engagement and remediation outcomes.
5. Avoid unsubstantiated claims or marketing language.

What are the most common modern slavery reporting pitfalls?

Fair Supply’s analysis of hundreds of Modern Slavery Statements reveals several recurring issues that undermine credibility and regulatory integrity:

• Copy-and-paste content
  Reusing text from previous years without updating dynamic elements (such as supplier numbers, geographic exposure, or due diligence outcomes) creates the impression of a static and superficial approach.
  
  
• Aspirational promises without delivery
  Listing initiatives that never materialise introduces accountability gaps. It is preferable to scale back or remove commitments entirely rather than risk overstating progress.
  
  
• Overgeneralised language
  Phrases like “continuous improvement” or “eliminating all modern slavery” are overly broad and can signal a limited understanding of modern slavery risk or the practical steps needed to manage it effectively.
  
  
• Corporate  Social Responsibility/’Good Corporate Citizen’ statements
  Treating the statement as a corporate social responsibility or brand exercise rather than a regulatory disclosure weakens its evidentiary value. Strong statements prioritise accuracy, specificity, and substantiated action over promotional tone.

What are the consequences of weak or incomplete modern slavery statements?

Although the Act itself does not impose penalties, a modern slavery statement is a regulatory compliance document required to be approved by a reporting entity’s Board of Directors. Inaccurate or misleading disclosures can potentially expose organisations and directors to liability under existing misleading or deceptive conduct provisions and the Corporations Act.

Beyond legal risk, reputational and investor scrutiny is intensifying. NGOs, research institutions, and the media are benchmarking statements against peers. Investors are increasingly assessing modern slavery disclosures alongside financial and ESG performance. In this environment, organisations should submit accurate, consistent, and credible statements to uphold stakeholder trust, uphold compliance and preserve access to capital and investment.

How often should modern slavery risk assessments be conducted?

An annual supply chain assessment of modern slavery risks is recommended. However, businesses should understand that modern slavery risk is not static. In order to identify, respond to, and monitor emerging risks, the recommended best practice is for businesses to embed real time due diligence into procurement workflows.

By integrating risk screening into supplier onboarding, contract renewal and supplier onboarding, reporting entities can identify high risk suppliers early and apply targeted clauses or escalation procedures. Shifting from periodic reviews to continuous monitoring strengthens compliance, improves data accuracy, and enhances overall supply chain resilience.

How should transparency be approached?

Transparency does not mean claiming to be risk free. Every supply chain carries inherent human rights risk. The strongest statements openly acknowledge this reality and instead explain how the entity is identifying, managing and mitigating those risks. 

Companies should not hesitate to disclose high risk areas or potential hotspots within their supply chains. On the contrary, being specific and transparent about where risks exist is a hallmark of credible reporting. 

Transparency should be purposeful and supported by context. The most effective approach combines honest disclosure with clear evidence of due diligence, demonstrating to stakeholders, investors, and regulators that the organisation understands its risks and is actively managing them.

What practical due diligence actions strengthen both compliance and credibility?

In 2025, reporting entities should prioritise due diligence actions that produce measurable improvements. Some of these actions include:

• Conducting desktop audits using reliable external data sources to identify high risk countries and industries.
• Embedding due diligence within procurement systems and supplier onboarding processes.
• Integrating technology to track supplier risk ratings, responses, and remediation over time.
• Collaborating with industry bodies and NGOs to leverage shared intelligence.
• Reporting progress transparently, including challenges and lessons learned.
  
  

How should reporting entities measure effectiveness?

Regulators and stakeholders now expect more than narrative-based activity reporting. They expect evidence of effectiveness using both qualitative and quantitative measures. A credible statement demonstrates progress, not perfection.  It updates data annually, reports on prior commitments, and uses precise, evidence-based language to show whether actions are mitigating identified risks.

Effective statements link activities to outcomes through specific key performance indicators (KPIs). The following is a non-exhaustive list of example KPIs organisations may consider:

• The proportion of high risk suppliers that completed enhanced due diligence.
• The number of remediation cases identified and resolved.
• Percentage of suppliers completing modern slavery or human rights training.
• Number and resolution rate of reported incidents.
• Average response time to reported incidents.
• Supplier improvement rates following engagement or remediation.
• Expansion of supply chain visibility, such as mapping coverage beyond Tier 1 suppliers.
  
  

Presenting measurable outcomes demonstrates that due diligence is active and responsive, rather than merely procedural. Over time, these indicators show the organisation’s maturity in identifying, managing, and remediating modern slavery risk.

How can boards be more effectively engaged?

Board approval remains a mandatory element of modern slavery reporting, yet the depth of engagement varies considerably. Boards are most responsive when modern slavery is framed as a core governance and risk issue, directly linked to directors’ duties and organisational accountability.

Effective board education should emphasise:

• The legal significance of approving and signing the statement
• Emerging enforcement trends and growing investor expectations
• The importance of internal controls, assurance mechanisms, and clear escalation pathways

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Embedding modern slavery risk into the organisation’s corporate risk register ensures that oversight is ongoing, structured, and aligned with broader governance and compliance frameworks.

How can reporting entities support smaller suppliers?

Although smaller suppliers are not legally bound by the Act, many are drawn into compliance ecosystems through supplier questionnaires and audits. Reporting entities can mitigate this pressure and avoid shifting the compliance burden onto smaller, less resourced suppliers in several ways. Reporting entities should communicate context, provide access to educational resources, and tailor requests to each supplier’s capacity and risk level.

Smaller suppliers are often overwhelmed by repetitive or poorly designed questionnaires. Reporting entities can improve both response rates and data quality by:

• Simplifying and, where necessary, translating questionnaires for overseas suppliers
• Aligning questions with genuine risk factors
• Explaining why data is collected and how it will be used
• Offering access to free training and practical guidance

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Building supplier capability in this way enhances compliance outcomes across the supply chain and promotes collaborative, long-term relationships rather than transactional reporting.

Strengthening modern slavery reporting with technology

High quality data and ongoing due diligence are central to credible modern slavery reporting. Manual processes alone cannot keep pace with the scale and rapid change of global supply chains.

If your organisation is seeking to strengthen its next statement through structured supply chain risk management and operationalised supplier engagement and due diligence workflows, explore Fair Supply’s Modern Slavery Software Solution.

The platform enables reporting entities to:

• Identify and quantify modern slavery risk across their supply chains.
• Manage supplier assessments and responses efficiently through automated tracking and insights.
• Generate evidence based data and reports to support board approval and public disclosure.

Integrating technology transforms modern slavery reporting from an annual compliance task into a continuous due diligence process that improves transparency, builds credibility, and supports responsible business conduct.