The Australian Council of Superannuation Investors (ACSI) represents 26 Australian and international asset owners and institutional investors. Collectively, they manage over $1 trillion in assets.

ACSI commissioned and recently released a report on ASX200 companies reporting on modern slavery in response to the Modern Slavery Act (MSA) – see HERE.

The report assessed modern slavery statements from ASX200 companies against “46 quality indicators over six assessment areas”. The assessment areas include but are not limited to the following:

• describing structure, operations, and supply chains.
• describing modern slavery risks in operations and supply chains.
• describing actions to assess the effectiveness of the modern slavery response.

Within the report is an example for each assessment area in tabular format as a guide for companies seeking to improve their modern slavery reporting.

Statements indicated ASX200 companies are taking foundational actions to manage modern slavery risks, including through risk assessments of supply chains (96%), use of contract clauses (67%), internal training (90%) and collaboration (51%).

Beyond this only a small cohort of companies clearly disclosed and explained advanced actions to manage modern slavery risks. This includes:

• working with suppliers to build their capacity to manage modern slavery risks (6%)
• building the internal capacity of boards and senior leadership on modern slavery (3%)
• consulting with potentially affected groups or their representatives (such as workers or their representatives) as part of risk assessment processes (2%); and
• defining effectiveness or an effective response to modern slavery to assist with tracking performance (10%).

Only 10% of companies’ statements identified steps taken to ensure grievance mechanisms (if they exist) are trusted and accessible to hear and address modern slavery complaints, and only 8% of companies indicated they had identified a modern slavery incident or allegation.

ACSI includes a list of recommendations for investors seeking to improve modern slavery reporting standards:

• Encouragement of open disclosures surrounding modern slavery allegations or incidents
• Encouragement of disclosures on modern slavery response evolutions and case studies
• Integration of modern slavery responses into a wider engagement of ESG
• Using the Australian Government’s Modern Slavery Register to engage with companies that do not meet the reporting standards of peers. (Modern Slavery Register HERE)
• Increasing leverage against companies via collective engagement

Analysis was conducted by Pillar Two (a human rights advisory firm). You can read it HERE.

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