A modern slavery disclosure framework for small businesses

“Our findings suggest that companies are much more comfortable reporting on their policies, committees and complaint channels than explaining what happens after a concern is raised,” Pham said.

This research follows the federal government’s consultation on strengthening the nation’s modern slavery laws.

“The purpose of putting out this type of framework is to actually allow smaller organisations to learn from what is already there in the market, the experience of larger organisations, and develop a framework that we can base on best practice in the market so that smaller organisations can move faster in their learning curve,” Pham told the brand.

“The companies can look at the framework and use it as a practical review tool and look at different areas and say first, ‘do we have grievance mechanisms, and are there multiple channels, or is it just email, are there hotlines?’” 

The research found that only 10 per cent of respondents, when designing grievance mechanisms, disclosed evidence of consulting affected stakeholders or their representatives.

“A lot of the time, you know, people submit grievances, and then they don’t hear from the company at all,” she noted.

She said that because of this, it is crucial for employees to be informed about the range of remedies available.

“Constantly testing and reviewing whether the mechanisms actually work [is crucial]. Just don’t assume that if you don’t hear anything, no new is good news.”

“The more channels and the more accessible the mechanisms are, the more effective they are.”

“Share the information about the grievance mechanisms that the organisation has with the suppliers and then ask them to promote it to the workers of the suppliers if you think it is one area of high risk.”

Pham said that to ensure transparency, businesses should look at the specific types of issues that are being reported.

“When an organisation reviews the mechanisms, they should look at if there are issues being reported. So they should look into what type of issues – do a bit of a chain analysis, root cause analysis, to understand how they should prevent this from happening again.”

“That part of the review of the framework is also very, very important. And it directly relates to the spirit of our Modern Slavery Act, which is about continuous improvement.”

“That review is a part of that feedback loop, [which shows that] we have something that is working, allowing us to see some certain issues that are happening.”

Pham told the brand that applying the framework begins with identification.

“Firstly, you must understand who the potentially affected stakeholders are. Are they your direct workers, your workers in the supply chains?”

“Target the most vulnerable group of stakeholders, instead of being broad, because this requires resources. Have a targeted approach scaled to the organisation, its size, and risk profile.”