Modern Slavery statement preparation checklist (AU)
A Modern Slavery statement is more than a compliance document — the post-review reforms (Anti-Slavery Commissioner, potential civil penalties) raise the expectation. This checklist covers the seven mandatory criteria and the broader preparation steps.
This is a 12-step checklist for preparing an Australian Modern Slavery statement under the Modern Slavery Act 2018 (Cth). It covers the seven mandatory criteria, supply chain mapping, risk assessment, effectiveness measurement, and board approval before submission to the Modern Slavery Statements Register. Use it each reporting cycle.
The checklist
Confirm reporting obligation
Confirm the entity is a reporting entity — $100m consolidated revenue Australian entity, or a foreign entity carrying on business in Australia.
Identify the reporting entity — mandatory criterion 1
Identify the reporting entity (or entities, if a joint statement) with ABN/ACN and the reporting period.
Describe structure, operations and supply chains — criterion 2
Describe the structure, operations, and supply chains of the reporting entity and any owned or controlled entities.
Describe risks — criterion 3
Describe the modern slavery risks in the operations and supply chains. Be specific — generic risk descriptions are called out.
Describe actions — criterion 4
Describe the actions taken to assess and address those risks — due diligence, remediation, grievance mechanisms.
Effectiveness — criterion 5
Describe how effectiveness is assessed — KPIs, audits, feedback channels, year-on-year progress.
Consultation — criterion 6
Describe consultation with any owned or controlled entities. Joint statements require consultation across covered entities.
Other relevant information — criterion 7
Any other relevant information — COVID-19 impact, geopolitical disruptions, major supplier changes.
Supply chain mapping
Map Tier 1 (direct) and Tier 2 suppliers for high-risk categories — geography, industry, workforce profile.
Grievance and remediation mechanism
Confirm a grievance mechanism is available, accessible to workers in the supply chain, and monitored.
Principal governing body approval
Obtain approval from the principal governing body (usually the board) and signature by a responsible member.
Register submission
Submit via the online register within 6 months of the end of the reporting period.
When this checklist applies
Use this checklist in the first two months after the reporting period ends. Begin supply chain data collection earlier in the cycle to meet the 6-month submission deadline.
Common pitfalls
- Generic statements rolled over year-on-year without updated risk analysis
- Joint statement missing evidence of consultation across covered entities
- No effectiveness measurement — criterion 5 unaddressed
- Board approval documented in the wrong entity (parent vs reporting entity)
- Late submission — appears on the register as overdue
Run this checklist on a real matter
Quillio drafts Modern Slavery statements from supply chain data, benchmarks against leading statements, and generates the board approval pack. See /practice-areas/commercial-lawyers or start a free trial.
The Modern Slavery Act is being reformed — watch for civil penalties and due diligence mandate changes. Use this checklist with current government guidance.
Use this checklist on your matter.
Quillio can run this checklist on a specific NSW conveyancing matter — confirm each item, calculate adjustments, and generate the supporting documents. The free trial requires no credit card.
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