A race to the middle of the pack: an analysis of slavery and human trafficking statements submitted by Australian banks under the UKModern Slavery Act

Abstract

In 2018, the Australian Parliament passed the Australian Modern Slavery Act (AMSA), which requires the approximately 3,000 businesses in Australia earning over AUD$100m p.a. to report on the risks of modern slavery in their operations and global supply chains, and on their actions to reduce those risks. The Australian Government hopes that AMSA’s disclosure-based reporting model will spur businesses to race to the top; by conducting human rights due diligence. We will not know how useful reporting under AMSA is until businesses begin to report. Because AMSA is modelled on the UK’s 2015 Modern Slavery Act (UKMSA), reporting under UKMSA gives an indication of the likely trajectory of reporting under AMSA. How the Australian finance sector (which contributes AUD$140b p.a. to Australia’s GDP—more than the mining sector) responds to AMSA will significantly determine its effectiveness. This paper assesses reporting submitted by ANZ, CBA, NAB, Westpac, Macquarie, AMP Capital, IFM and QBE under UKMSA, to predict the quality of their eventual reporting under AMSA, including how that reporting may change over time. Our analysis suggests that a race to the middle of the pack has occurred over the three UKMSA reporting cycles.

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