Incremental progress, persistent gaps: ASX200 reporting under Australia’s Modern Slavery Act

Incremental progress, persistent gaps: ASX200 reporting under Australia’s Modern Slavery Act is ACSI's third assessment of company reporting and risk management under Australia’s Modern Slavery Act (‘MSA’).

This year’s research comes after six cycles of reporting under the MSA and finds that while progress continues, it remains uneven. Many companies have strengthened the foundations of their modern slavery risk management, but relatively few are demonstrating the more mature practices needed to identify, prevent and remediate modern slavery risks.

For the first time, the research also includes a deeper assessment of 51 companies operating in sectors likely to face higher modern slavery risks. This assessment incorporates more targeted indicators and examines whether the companies’ approaches are proportionate to their greater exposure.
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Key findings:

ASX200 companies scored an average of 28% on the core indicators. 86% was the highest score, with 20 companies scoring above 50% on the core indicators.
The 51 higher-risk sector companies scored an average of 13% on the targeted indicators. 56% was the highest score, with only two companies scoring above 50% on the targeted indicators. 80% of companies identified modern slavery risk areas or factors relating to their operations (56% in 2023) and 82% in their supply chains (96% in 2023, with the decrease attributable to a different sample).
Few ASX200 companies are demonstrating mature risk management actions, including providing training to suppliers (25%); and defining what an effective response to modern slavery looks like to assist with tracking performance (13%).
Only a small number of higher-risk sector companies are demonstrating advanced risk management practices, including engaging with suppliers at tier 2 or below (14%); conducting living wage (18%) or worker voice (8%) initiatives; and taking steps to ensure grievance mechanisms are trusted and accessible (31%).
Only 13% of statements identified an instance of modern slavery, with 8% of these providing detail about how these instances were remediated.

Six years into reporting under the Act, investors increasingly need to understand not simply whether policies and processes are in place, but whether they are working in practice and leading to meaningful outcomes.
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