Modern Slavery Policy

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Last updated November 18, 2025

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Suitable for Australia

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Frequently asked questions

Key Components of a Modern Slavery Policy

When developing a modern slavery policy, it is recommended using a template or seeking legal advice to ensure the policy is legally compliant and consistent with the Modern Slavery Act 2018 (Cth)

Below are a few key components that should be included in a modern slavery policy:

Purpose

The purpose of the modern slavery policy should be defined here. It is likely the purpose will be to pledge the business’s support in avoiding slavery and to not engage in modern slavery practices.

Indicators of Modern Slavery

A business’s modern slavery policy is also likely to state any indicators of modern slavery. These indicators should be general and broad depending on the business type, communication methods (online or face to face), and business size. Indicators of modern slavery include not being in possession of ID, limited social interaction with others and acting with hostility.  

Responsibilities of Both Parties

A modern slavery policy will also state the responsibilities of both the employer and employee in eradicating modern slavery. This is likely to include the business’s pledging to identify and address modern slavery risks in the business and supply chain, and to take steps in raising awareness of modern slavery risks. 

How to Report Modern Slavery

A modern slavery policy will outline the procedures to take if you have a reasonably held suspicion of modern slavery practices. This may include contacting a manager if you suspect modern slavery occuring in the workplace or calling the police in circumstances where you suspect someone is subject to modern slavery.

It is recommended to use a template or seek legal advice when constructing a modern slavery document to avoid inconsistency and ensure legal compliance. 

Mistakes to Avoid

It is integral to ensure that your modern slavery policy avoids common errors made when drafting a modern slavery policy. These mistakes include:

Specificity

Providing vague or general statements when drafting your modern slavery policy is ineffective and counterproductive to tackling modern slavery. It is important your modern slavery policy is specific in every aspect.

Tokenism

Like greenwashing, tokenism occurs when a business acts symbolically or performative when it comes to social justice. Tokenising modern slavery in a modern slavery policy could include the act of not practicing or genuinely caring when it comes to modern slavery being reported or pointed out. 

It is recommended seeking legal advice or using a template when constructing a modern slavery policy to avoid making such errors. 

Further Information:

View Sample Modern Slavery Policy

The Legal Risk Score of a Modern Slavery Policy Template is Low

Our legal team have marked this document as low risk considering:

  • The document assigns significant responsibilities to individuals at all levels to monitor and report modern slavery, which could place pressure on employees to interpret and act on complex situations without clear guidelines.
  • There is a reliance on the vigilance and proactive behavior of those within the company to recognise and report indicators of modern slavery, potentially leading to inconsistencies in enforcement and recognition of such practices.
  • The policy requires compliance with modern slavery laws and practices but does not specify detailed procedural steps for addressing identified issues, which might lead to varied interpretations and implementations of the policy.

Users familiar with compliance documents might find this document useful but should be aware of the need for possibly further detailed procedural development to ensure consistent application and effectiveness.

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