INTHEBLACK July 2020 - Page 49



F E AT U R E
// M O D E R N S L AV E RY
at a traditional finance team in any business in
Australia, they would typically control aspects such as
procurement, legal risk and compliance.
“Accountants make such a big difference to people’s
lives once they realise what they’re capable of doing,
especially through the supply chain,” Somaiya says.
“RIGHT NOW, WE ARE ENCOURAGING ENTITIES TO CONSIDER HOW THE IMPACT OF
COVID-19 MIGHT INCREASE THE VULNERABILITY OF WORKERS IN THEIR
OPERATIONS AND SUPPLY CHAINS TO MODERN SLAVERY.”
DAVID BRIGHTLING, AUSTRALIAN BORDER FORCE
Above: A member
of Italy’s Unione
Sindacale Di Base
(USB) at a May 2020
demonstration
around workers’
rights during the
time of COVID-19.
Top: A woman
wearing a face
mask walks past
graffiti, translated as
“don’t be a slave of
the dollar”, in
Caracas, Venezuela.
Top right: A worker
in a production
line at a seafood
processing operation
in Bangkok, Thailand,
in April 2020.
54 ITB July 2020
The latest Global Slavery Index, published in 2018
by Walk Free Foundation, an initiative of philanthropic
organisation Mindaroo, estimates that 40.3 million
people were in some form of slavery in 2016.
It also states that G20 countries are estimated to
import A$547 billion of at-risk goods – goods that
are considered to be at risk of being produced by
forced labour each year.
Reports of children in Thailand being forced to
peel prawns bound for Australian tables have gained
global attention and widespread condemnation.
The 2013 collapse of the Rana Plaza building in
Dhaka, Bangladesh, which killed at least 1132 people
working in its five garment factories, also highlighted
the hazardous working conditions inside the supply
chains of many global fashion brands.
Developed nations such as Australia are not immune
to modern slavery – an estimated 15,000 people are
living in conditions of modern slavery in the country
right now.
In 2015, five karaoke bars in Melbourne and Perth
were raided by a joint taskforce, including the Fair
Work Ombudsman and Border Force, following
allegations of wage fraud, sham contracting and
sexual slavery of female hosts.
In October 2016, the Migrant Workers’ Taskforce,
chaired by Professor Allan Fels, was set up with a
focus on domestic slavery, sex slaves and wage fraud.
Fels’s taskforce delivered its first report in March
2019, revealing that more than half of all temporary
migrant workers were underpaid and subject to poor
working conditions.
REPORTING THE RISKS
Australia has several measures in place to help
organisations identify the risks of modern slavery
in their supply chains. Under Australia’s Modern
Slavery Act 2018, modelled on the UK’s Modern
Slavery Act 2015, from 1 January 2019, about 3000
organisations based or operating in Australia with
a consolidated revenue of more than A$100 million
must report annually on the risks of modern slavery
practices in their operations.
In addition, under the Act, organisations are required
to report on the action they are taking to assess and
address modern slavery risks and the effectiveness of
their response. The reports must be submitted to the
Australian Government.
Against the backdrop of COVID-19, now more
than ever, attention must be paid to the supply chains
struggling to survive in a globally depressed economy,
says Vanessa Zimmerman, CEO of business and
human rights consultancy Pillar Two.
“It might be stating the obvious, but I think one of
the key messages that has come out is that people who
were already at risk for modern slavery may become
even more vulnerable, because the desperation to have
any work at all might mean they’ll be much more
willing to accept situations they wouldn’t previously
have accepted,” Zimmerman says.
David Brightling is assistant secretary at the
Australian Border Force’s modern slavery and
trafficking branch, which is responsible for
implementing the Modern Slavery Act. He says the
most at-risk areas for modern slavery in Australia
include cleaning, agricultural work, construction
and hospitality.
“We know that modern slavery happens here
in Australia, as well as overseas. Right now we are
encouraging entities to consider how the impact
of COVID-19 might increase the vulnerability of
workers in their operations and their supply chains
to modern slavery.
“Factory shutdowns, order cancellations, workforce
reductions and sudden changes to supply chain
structures can disproportionately affect some workers
and increase their exposure to either modern slavery
or other forms of exploitation,” Brightling says.
HOW FINANCE PROFESSIONALS CAN HELP
Dr Katherine Christ CPA, a lecturer in accounting at
the University of South Australia, is the co-author of
Modern Slavery Compass, a tool developed with
CPA Australia to help businesses meet their reporting
obligations under the Modern Slavery Act.
“Organisations are not starting from a zero base –
there are many resources freely available that we have
included in the Modern Slavery Compass,” Christ
says, adding that finance professionals play a key role
in the reporting process and that organisations should
not fear reputational risk by calling out modern
slavery practices.
“Accounting is implicated throughout the whole
reporting and management process under the Act.
An accountant should really play a leading role in this
space, because it involves due diligence and reporting –
if you look hard enough, you will find modern slavery
in your supply chains,” Christ says.
“It is important that you are completely transparent
with your stakeholders and celebrate the fact that you’ve
found it and you are working with suppliers and
contractors to make a positive difference for the victims.”
Deepen Somaiya, infrastructure procurement
manager at Transurban, says the company’s finance
team was critical in establishing a successful program
to meet modern slavery reporting requirements.
“I can’t overstate it – the finance community
has such an important role to play. If you look
DIGGING INTO THE SUPPLY CHAIN
While only businesses with a turnover of more than
A$100 million are required to report under the Act,
small and medium-sized enterprises (SMEs) are also
vital to stamping out modern slavery in supply chains.
Shaeron Yapp, human rights principal at global
mining and metals company South32, says working
with SMEs in your supply chain is essential to be able
to report under the Act.
“One of our focus areas is to support and develop
SMEs in our emerging markets, and bring them into
our supply chain where we can.
“We recognise that sometimes they’re not quite
ready in terms of their management policies,
capabilities and systems, so we also work to address
any issues to prevent any potential risk for our supply
chains. For example, we are giving our local SMEs
in South Africa human rights training and educating
them about modern slavery,” Yapp says.
What should businesses do when they identify
potentially risky practices?
Zimmerman says it depends on the situation.
“I think, if they find a clear case of modern slavery,
often calling the authorities will be one of the first
steps to free the survivor and ensure action is taken
against the perpetrator. However, it has to be done in
a very careful way to avoid endangering the survivor
of modern slavery, as well as the person who might
be reporting it, and to prepare for any flow-on
consequences,” Zimmerman says.
Brightling says if organisations identify modern
slavery in their supply chains in Australia, they should
respond in a way that best protects the victims. If the
instances of slavery are in supply chains outside of
Australia, they should be working with those suppliers
to change practices.
“For instances of modern slavery in Australia, we
encourage organisations to contact the police. That
will ensure that there’s a proper investigation, and any
victims are identified and protected, and that
the perpetrators are held to account,” Brightling says.
PUTTING PEOPLE FIRST
Dr Leeora Black, principal in the Sustainability
Services team at Deloitte, says a victim-centred
approach is crucial, and that boycotting suppliers
will not address the problem.
Above: Construction is
one of the industires
that has been identified
as at high risk of modern
slavery practices.
Top: South 32’s Worsley
Alumina refinery near
Collie, Western Australia.
MODERN
SLAVERY
COMPASS
T H E M O D E R N S L AV E RY
C O M PAS S I S A T O O L
TO MANAGE THE RISK
A N D I M P L I C AT I O N S
O F M O D E R N S L AV E RY.
The Modern Slavery
Compass is designed
to help large and small
organisations navigate
the reporting
requirements of
Australia’s Modern
Slavery Act. It is
based on a process
of continuous
improvement and
addresses five core
questions in relation
to modern slavery
management, as well
as identifying actions
organisations need to
take to implement and
improve their modern
slavery management.
It also lists freely
available resources
to help businesses
understand more about
the problem and how to
be part of the solution.
• Preconditions (Where
have we been?)
• Current position
(Where are we now?)
• Expectations (Where
are we going and what
do we do now?)
• Results (What is the
outcome from the
actions taken?)
• Effectiveness (How
did we do?)
intheblack.com July 2020 55

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