Chartered Accountants ANZ lodged a submission on 17 May 2019 to the Modern Slavery Business Engagement Unit within the Department of Home Affairs ('The Department') on the Modern Slavery Act 2018 – Draft Guidance for Reporting Entities.
From January 2019, Australian businesses (corporate and non-corporate Commonwealth entities) with an annual consolidated revenue of at least $100 million are required to publish an annual modern slavery statement. The Draft Guidance for Reporting Entities was published by the Department to assist in identification and assessment of supply chains and prepare a modern slavery statement.
The main points of our submission to the Department were as follows:
- We draw attention to the commencement date of 1 January 2019 of the Commonwealth Modern Slavery Act 2018 (the Act) and highlight that organisations with reporting periods ending 31 March are already in their first reporting period, prior to the availability of guidance.
- We suggest that clear and concise guidance is provided to assist entities to identify if they are required to comply with the Act. In particular, clearly articulated explanations of how the entity will assess its revenue threshold as well as guidance for borderline entities that may be required to estimate their revenue threshold. It is critical that entities can clearly identify if they are or are not a reporting entity.
- We recommend that the Guidance is separated into three key components: Compliance with the Modern Slavery Act 2018, Understanding Modern Slavery and Modern Slavery Statement preparation and lodgement. This would provide greater clarity for users looking at compliance for the first time as well as users with pre-existing awareness of the Act.
- We recommend that the guidance provide clarity around the scope of the statement, in particular whether business relationships other than suppliers are included, such as customers.
The Department will be consolidating the feedback received and will continue to collaborate and engage with relevant stakeholders.