The 15 members of the Property Council’s Modern Slavery Working Group engaged five experts to scrutinise their modern slavery statements in November. The result is 11 recommendations that can help every company tackling modern slavery.
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Three key takeaways:
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There are 40.3 million people living in conditions of modern slavery, according to the Global Slavery Index, of whom 62 per cent are estimated to be across the Asia Pacific region.
The Commonwealth Modern Slavery Act, which came into force on 1 January 2019, requires companies with annual revenues of more than $100 million to report annually on the risks of modern slavery in their operations and supply chains, and to demonstrate the actions they are taking to address those risks.
The Act identifies eight types of serious exploitation: trafficking in persons, slavery, servitude, forced marriage, forced labour, debt bondage, deceptive recruiting for labour or services, and the worst forms of child labour.
Modern slavery statements, lodged each year with the Australian Government, are published through the Online Register for Modern Slavery Statements. This has already been searched nearly half a million times by investors, customers and peers since its November 2020 debut.
In November, the Property Council and the 15 founding partners of the supplier platform asked five experts with varied and complementary skills to examine their modern slavery statements and provide insight into patterns, sectoral issues and emerging risks within the property industry.
The experts were Professor Justine Nolan from the Australian Human Rights Institute at UNSW; Professor Jennifer Burn and her colleague Carolyn Liaw from Anti-Slavery Australia at UTS; and Professor Dayna Simpson and Associate Professor Marie Segrave from the Monash Business School. The project was led by Robin Mellon, project manager for the Property Council’s Working Group and Supplier Platform and CEO of Better Sydney.
“Modern slavery is complex and requires ambitious commitment to achieving change,” says Professor Simpson. “It also requires committing to innovation to understand your operations, and to transform practices for the better.”
First among the recommendations was the need for statements that are “actions-based, clear and relevant,” Mellon says. The experts recommended that organisations link the content of their statements directly to the seven reporting criteria of the Modern Slavery Act 2018. “If they’re doing something amazing but it’s buried in 28 pages of spin, it’s hard for anyone to identify or understand it.”
Another recommendation was to provide “relevant and exact” information about suppliers. While many statements provide generic detail, the experts want to see more specifics, Mellon notes. As organisations enter their second or, in some cases, third year of reporting, “it’s time to start being more precise”.
A third recommendation was to acknowledge the “spectrum of exploitation”, rather than see modern slavery as a “binary condition,” Mellon adds.
“There is a scale from safe, decent work through dangerous or sub-standard working conditions to human rights abuses and modern slavery.” The experts recommend property and construction companies check for issues, such as compliance with minimum wage levels and entitlements, employment documentation and conditions, as these can be warning signs or ‘red flags’ for modern slavery in its different forms.
“Many companies do not describe their modern slavery risks in detail, including how they have assessed risks or their measures for assessing effectiveness,” reports Professor Nolan. “Companies need to do a better job of analysing sector and regional risk and specifying how they as a company cause, contribute to, or are directly linked to modern slavery risks.”
One of the group’s biggest takeaways from the activity was to provide case studies of how changes in process have impacted people.
“Some of the best statements outlined what they’d found as they assessed and addressed human rights risks, the impacts on the real people through their operations and supply chains, the changes made and the effects on people’s lives,” Mellon concludes.
The Property Council’s 11 Recommendations for Modern Slavery Statements includes a range of valuable resources and tips for helping your organisation improve how you address modern slavery.