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Commissioner calls for smarter due diligence to reduce modern slavery paperwork for small businesses

Small and medium sized-enterprises (SMEs) could face fewer repetitive questionnaires and more targeted modern slavery checks under proposals released today by the Australian Anti-Slavery Commissioner, Chris Evans.

The paper, Getting the Balance Right: Modern Slavery Due Diligence and SMEs, developed through iterative consultation with SMEs, industry groups and large businesses, sets out three proposals:

  • embedding greater proportionality, so information requests to suppliers match the level of risk;  
  • common due diligence infrastructure, so supplier information can be provided once and shared across customers, with mutual recognition of social compliance audits; and
  • sector-level collaboration and capacity building, with SMEs at the table.

SMEs are increasingly asked to complete questionnaires, agree to contractual obligations and provide assurance, often for multiple customers, at different times and in different formats, despite usually falling outside reporting obligations under the Modern Slavery Act.

"SMEs are essential to Australia's response to modern slavery," said Commissioner Evans. "This is not a call for less due diligence, it is a call for smarter due diligence."

"Modern slavery risks can arise in businesses of any size, including SMEs. The challenge is ensuring that due diligence efforts are focused on genuine risks, rather than repetitive administrative processes."

The paper comes as the Australian Government considers reforms to the modern slavery framework, including its proposal to introduce a new criminal offence for failure to prevent modern slavery. SMEs are included in the framework for reform proposed by the Commissioner in Impact through action: A framework for modern slavery reform, released on 15 October, and this paper builds on that work.

"I have written to the responsible Ministers to highlight the issues raised in this paper and the opportunities for reform," Commissioner Evans said. "I look forward to working constructively with the Government on practical solutions that work for SMEs and for tackling modern slavery."

Read paper, Getting the Balance Right: Modern Slavery Due Diligence and SMEs

View the paper, Impact through action: A framework for modern slavery reform