What is to be reported? The current proposal is for entities to report against the following four criteria: 1. The entity’s structure, its operations and its supply chains 2. The modern slavery risks present in the entity’s operations and supply chains 3. The entity’s policies and process to address modern slavery in its operations and supply chains and their effectiveness (such as codes of conduct, supplier contract terms and training for staff), and 4. The entity’s due diligence processes relating to modern slavery in its operations and supply chains and their effectiveness Further guidance will be required to understand what level of detail is required to achieve compliance. Disclosures should be made in a “Modern Slavery Statement” and it is proposed that it should be published within five months after the end of the Australian fiscal year. A requirement to include a link to the statement in a “prominent place” on the entities’ websites is likely, in line with expectations in the UK Act. How will compliance be monitored? Compliance provisions are not included in the initial proposal. However, there is a suggestion for the government to maintain a central repository of statements, which will aid benchmarking, identification and publishing the names of non-compliant entities. In principle support has been given for establishing an Independent Anti-slavery Commissioner, who would have the ability to consult, advise, report on, and make recommendations with respect to modern slavery supply chain reporting. This position and role, however, is yet to be determined. How does it compare to other jurisdictions? The UK Modern Slavery Act (2015) is a broader Act, which contains provisions confirming the offence of modern slavery. Reporting disclosures is one section (54), whereby guidelines for reporting criteria are provided, however, not mandated. The threshold for companies to report is GBP£36m. At this stage, the public sector is not subject to reporting provisions. The California Transparency of Supply Chain Act (2012), requires retailers and manufacturing companies with worldwide annual revenues of USD$100m or more that sell/operate in California to report on their specific actions to eradicate slavery and human trafficking from its direct supply chain. More recently in the US, amendments to the Tariff Act of 1930 now forbid goods made with forced labour from entering the country. The Corporate Duty of Vigilance Law was adopted by the French Parliament in February 2017. It requires approximately 150 of the largest French companies to assess, address, and report on the adverse impacts of their companies on people and the planet, including impacts linked to their companies and those of suppliers and sub-contractors. Concerned parties can bring allegations of noncompliance before the court, who can issue fines of up to EU€10m for failing to publish a plan or EU€30m where a failure has resulting in damages that would have otherwise been preventable. Formal enforcement provisions are unlikely — however, a proposed central repository of statements would facilitate non-compliant companies to be “named and shamed”. What AusLSA are doing? The Australian Government’s expected Modern Slavery legislation and regulations will require most AusLSA members to develop new systems to research, understand manage their supply chain for modern slavery risks. AusLSA will work with members to share resources and information and look at the opportunities to develop tools to better manage this process. O BE A SERIOUS PROBLEM IN THE THEM, OR NOT. WHAT WAS HISTORICALLY TION FROM REGULATORS GLOBALLY.