Modern Slavery Business & Investor
Toolkit

A collection of resources to guide your organisation’s approach in how to address modern slavery.

It contains links to case studies, research, legal frameworks and tools produced by Walk Free and other civil society organisations from around the world.

Featured Tool

Modern Slavery Benchmarking Tool

Not sure where to start? Measure your organisation’s current performance and receive a list of actions to implement by using Walk Free’s Modern Slavery Benchmarking Tool.

The results include a score, a list of steps you can take to improve, suggested disclosures and personalised information on risks relating to forced labour.

Reporting on modern slavery

Frequently asked questions on the reporting of modern slavery.

Is my business required to report on modern slavery?

In Australia, businesses with an annual turnover of $100m or higher must submit an annual Modern Slavery Statement. If your business does not meet this threshold, you may still receive requests for information from larger organisations to assist them in meeting their own reporting obligations.

What are some examples of modern slavery in business?

A cleaning service provider illegally employed migrant workers through deceptive job advertisements. Upon arrival in Australia, the workers’ passports are retained, and the hours are much longer than agreed. Their employer threatens that if they quit, they will be arrested and deported.

A factory worker borrowed money from a recruitment agent to secure work for himself. Each pay cycle, his wages are used to re-pay the loan, which accrues interest at extortionate rates. This factory supplies electronic goods to companies across to Australia.

What should companies do to address modern slavery?

Companies must find, fix and prevent labour practices that are exploitative. They should assess operations and supply chains for associated risks and remediate harm. Contract clauses and policies that protect workers should be implemented.

Understanding the problem

Forced labour and debt bondage are widespread forms of modern slavery that exist within the complex supply chains that span our world. Though companies may unwittingly become involved in perpetuating this human exploitation they are increasingly being held responsible.

Business guides to addressing modern slavery

Guidance on Modern Slavery Risks for Thai BusinessesStock Exchange of Thailand, Walk Free & Finance Against Slavery and Trafficking
Managing Risks Associated with Modern Slavery: A Good Practice Note for the Private SectorEthical Trading Initiative & Ergon Associates
Modern Slavery Benchmarking ToolStock Exchange of Thailand, Walk Free & Finance Against Slavery and Trafficking
Modern Slavery Map – An Interactive Map for Business of Anti-Human Trafficking Organisations
Modern Slavery Risks, Rights and Responsibilities: A Guide for Companies and InvestorsAustralian Council of Superannuation Investors & KPMG
Property, Construction and Modern Slavery: Practical Responses for Managing Risk to PeopleAustralian Human Rights Commission and KPMG
Respecting Human Rights in our Supply ChainsEnergy Procurement Supply Association & Action Sustainability

Open source learning modules

E-course: Introduction to the Management of Fair and Ethical Recruitment and Employment of Migrant WorkersInternational Organization for Migration (IOM)
Modern Slavery ModulesSupply Chain Sustainability School (requires sign-up)
Modern Slavery Resources and Educational MaterialAustralian Government
United Nations Global Compact Human Rights and Business Learning Tool

Awareness-raising videos

‘Can You Spot the Signs?’Supply Chain Sustainability School
Businesses and the Modern Slavery ActBe Slavery Free (Stop the Traffik Australia)
Example from the Malaysian Palm Oil IndustryInternational Organization for Migration (IOM)
Trapped in Forced Labour – Lured by a JobInternational Labour Organization
What is Modern Slavery?Be Slavery Free (Stop the Traffik Australia)

Benchmarking tools and indices

These indices benchmark companies to empower consumers and other stakeholders with information on their operations, encouraging business engagement and improvements in rankings from year to year.

Brand DirectoryGood on You
Corporate Human Rights BenchmarkWorld Benchmarking Alliance
Ethical Fashion GuideBaptist World Aid
Fashion Transparency IndexFashion Revolution
KnowTheChain
KPMG Modern Slavery BenchmarkKPMG
Modern Slavery Benchmarking ToolWalk Free

Global data on slavery and related risks

Commodity AtlasVerité
Corruption Perceptions IndexTransparency International
Global Report on Trafficking in PersonsUNODC
Global Slavery IndexWalk Free
List of Goods Produced by Child Labor or Forced LaborUS Department of Labor
Measurement. Action. Freedom. An Independent Assessment of Government Progress Towards Achieving UN Sustainable Development Goal 8.7Walk Free
Products Made with Uyghur Forced LabourSheffield Hallam University
Responsible Sourcing Tool
Trafficking in Persons ReportUS Department of State

Supply chain due diligence, codes of conduct, corrective action & remedy

Organisations have the responsibility to respect human rights within their business activities and relationships. Creating clear policies and implementing effective systems is key to ensuring the ethical recruitment and treatment of workers.

Codes of conduct and company policies

Company Action PlatformBusiness and Human Rights Resource Centre
Example: Human Rights Due Diligence StandardAnglo Gold Ashanti
Example: Human Rights PolicyUnilever
Example: Supplier Code of ConductMicrosoft
Modern Slavery Model Contract ClausesAustralian Government
Sample Code of ConductResponsible Sourcing Tool
Verité Fair Hiring Toolkit: Improving Company Codes of Conduct and Company PoliciesVerité

Ethical recruitment tools

A Guide to Fair Recruitment of Migrant LabourInternational Labour Organization
Fees and IDs: Tackling Recruitment Fees and Confiscation of Workers’ PassportsInstitute for Human Rights and Business
General Principles and Operational Guidelines for Fair Recruitment and Definition of Recruitment Fees and Related CostsInternational Labour Organization
Labour Migration Process Mapping Guide: Understanding and Assessing Human and Labour Rights Risks to Migrant Workers During Recruitment, Employment and ReturnInternational Organization for Migration (IOM)
Migrant Worker Guidelines for EmployersInternational Organization for Migration (IOM)
Migration with Dignity: A Guide to Implementing the Dhaka PrinciplesInstitute for Human Rights and Business
Six Steps to Responsible RecruitmentThe Leadership Group for Responsible Recruitment
Worker Voice-Driven Ethical Recruitment ToolkitIssara Institute

Supply chain transparency

A Small Business Guide to Supply Chain MappingBusiness Advice
Example: Supplier Self-Assessment QuestionnaireHuman Rights Resources and Energy Collaborative
Know Your Supply Chains: Desk-Based Research Strategies to Identify Uyghur Region ExposureSheffield Hallam University
Social Audits Guidance and FAQs (for Suppliers)Human Rights Resources and Energy Collaborative
Tackling Modern Slavery in Supply ChainsWalk Free
The Path to Supply Chain TransparencyDeloitte University Press
Verité Fair Hiring Toolkit: Reporting and TransparencyVerité

Grievance mechanisms, corrective action and remediation

Modern Slavery Response & Remedy FrameworkWalk Free and Human Rights Resources and Energy Collaborative
Work Right HubAustralian Red Cross
Modern Slavery & Remediation – An Investor’s GuideWalk Free and the First Sentier MUFG Sustainable Investment Institute
Modern Slavery & Remediation – Investor CheatsheetWalk Free and the First Sentier MUFG Sustainable Investment Institute
Access to Remedy – Practical Guidance for CompaniesEthical Trading Initiative
Effective Modern Slavery Grievance Mechanisms: A Case Study Publication for BusinessUN Global Compact Network Australia
Example: Responsible Sourcing Standards: Supplier Guidance on Developing Grievance MechanismsWoolworths Group
Implementing Effective Modern Slavery Grievance Mechanisms: A Guidance Note for BusinessUN Global Compact Network Australia
Operational Guidelines for Businesses on Remediation of Migrant Worker GrievancesInternational Organization for Migration (IOM)
Operational-Level Grievance MechanismsFederal Institute for Sustainable Development (Belgium)
Remediation and Grievance MechanismsBusiness Respect Human Rights
The WEST PrinciplesWorker Engagement Supported by Technology (WEST)
Workplace Monitoring ReportsFair Labor Association

Legal obligations and frameworks

Organisations must consider both reputational risk and corporate liability arising from international standards and national laws. Business and investors can play a major role in contributing towards social progress and are being placed under increasing levels of scrutiny to ensure they minimise the adverse impacts of their operations, supply chains and other business relationships.

National and regional supply chain transparency and due diligence laws

Australia: Modern Slavery Act (2018)
California: Transparency in Supply Chains Act (2010)
Canada: Fighting Against Forced Labour and Child Labour in Supply Chains
European Union: Regulation of Due Diligence (2017)
France: Duty of Vigilance Legislation (2017)
Germany: Supply Chain Due Diligence Act
Key Legislation Driving Responsible BusinessSedex
Norway: Transparency Act
The Netherlands: Child Labour Laws (2017)
United Kingdom: Modern Slavery Act (2015)
United States of America : Section 307 of the Tariff Act 1930
United States of America : Uyghur Forced Labour Prevention Act
USA: Dodd-Frank Act (2010)
USA: Tariff Act (1930)

International standards and frameworks

ILO Declaration on Fundamental Principles and Rights at WorkInternational Labour Organization
ILO Standards on Forced Labour; the New Protocol and Recommendation at a GlanceInternational Labour Organization
ILO Tri-Partite Declaration of Principles Concerning Multinational Enterprises and Social PolicyInternational Labour Organization
OECD Due Diligence Guidelines for Responsible Business ConductOrganisation for Economic Cooperation and Development (OECD)
OECD Guidelines for Multinational Enterprises on Responsible Business ConductOrganisation for Economic Cooperation and Development (OECD)
Overview of Key ILO ConventionsBali Process Government and Business Forum
The UN Guiding Principles on Business and Human Rights: An Introduction
UN Guiding Principles on Business and Human RightsUnited Nations

Modern slavery reporting

In recent years, reporting and disclosure requirements have come into place that require entities to publish statements identifying the risk of modern slavery in their operations and supply chain as well as actions taken to address those risks. The UK and Australia have both introduced Modern Slavery Acts requiring large organisations to report on an annual basis. These obligations complement other international standards, such as the United Nations Guiding Principles on Business and Human Rights.

Guidance

Modern Slavery Guidance Material and ResourcesAustralian Government
Modern Slavery Statements: A Framework for EvaluationEthical Trading Alliance
Transparency in Supply Chains: A Practical GuideUK Home Office
UN Guiding Principles Reporting FrameworkUnited Nations

Analysis and case studies

Beyond Compliance in the Finance SectorWalk Free
Beyond Compliance in the Garment IndustryWalk Free
Beyond Compliance in the Hotel Sector: A Review of UK Modern Slavery Act StatementsWalk Free & WikiRate
Beyond Compliance in the Renewable Energy Sector: Assessing UK and Australian Modern Slavery Act StatementsWalk Free and WikiRate
Beyond Compliance: The Modern Slavery Act Research ProjectWalk Free & Wiki Rate
Example: Modern Slavery Statement (Australia)Woolworths Group
Modern Slavery Statement Disclosure Quality: ASX100 CompaniesMonash Centre for Financial Studies
Moving From Paper to Practice: ASX200 Reporting Under Australia’s Modern Slavery ActACSI

Financial sector tools

The financial sector is critical to the eradication of modern slavery due to its far-reaching and influential business relationships across all industry sectors. Business models reliant on modern slavery in their operations or supply chains not only come at high social cost, but are also unlikely to yield sustainable earnings growth over time. The resources below include financial sector guidance, investor engagement tools, and widely recognised principles-based frameworks to equip the sector to address modern slavery.

Financial sector general guidance

Beyond Compliance in the Finance Sector: A Review of Statements Produced by Asset Managers Under the UK Modern Slavery ActWalk Free, WikiRate and the Business & Human Rights Resource Centre
Fighting Modern Slavery and Human Trafficking Online CourseAssociation of Certified Anti-Money Laundering Specialists
Financial Services and Modern SlaveryAustralian Human Rights Commission & KPMG
Human Rights for the Financial Sector Guidance ToolUNEP Finance Initiative
Implementation ToolkitFinance Against Slavery & Trafficking
Roadmap for Financing the 2030 Agenda for Sustainable Development 2019-2021United Nations

Investors (asset owners and asset managers)

Bridging ESG Silos: The Intersection of Climate Change and Modern SlaveryWalk Free and AllianceBernstein
Engagement Expectations: Find it, Fix it, Prevent itCCLA
From Poor Working Conditions to Forced Labour – What’s Hidden in Your Portfolio?Principles for Responsible Investment
Human Rights Reporting: Are Companies Telling Investors What They Need to Know?Shift
Human Rights Risks in Xinjiang Uyghur Autonomous Region – Practical Guidance for InvestorsInvestor Alliance for Human Rights
Investor Primer of Grievance MechanismsEngage the Chain
Investor Toolkit on Human RightsInvestor Alliance for Human Rights
Modern Slavery Reporting – Guide for InvestorsResponsible Investment Association Australasia, Australian Council of Superannuation Investors
Modern Slavery Risks, Rights and Responsibilities: A Guide for Companies and InvestorsAustralian Council of Superannuation Investors & KPMG
Responsible Business Conduct for Institutional InvestorsOECD
RI Review ToolPrinciples for Responsible Investment

Commercial banks and insurers

Conferences and TrainingsAssociation of Certified Anti-Money Laundering Specialists
Modern slavery due diligence for Australian banksKPMG
Principles for Responsible BankingUNEP Finance Initiative
Principles for Sustainable InsuranceUNEP Finance Initiative
The Equator Principles IV, July 2020The Equator Principles Association
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