Supplier Due Diligence & Responsible Sourcing
Preventing modern slavery: governance and accountability
Practical governance and evidence steps for businesses monitoring Australia's proposed failure-to-prevent offence.
The proposed offence has been announced, but is not yet law.
On 16 July 2026, the Australian Government announced that it would introduce a corporate offence for failing to prevent modern slavery. The announcement describes a proposed application to companies with annual consolidated revenue above A$100 million and a defence based on reasonable prevention steps. Legislation and final details remain to be seen.
Current reporting obligations continue to apply.
The Modern Slavery Act 2018 currently requires covered reporting entities to prepare annual modern slavery statements. A future prevention offence would be a separate development, not a substitute for current reporting, due diligence or remediation work.
Treat prevention as an operating system, not a policy statement.
- Give a senior owner clear authority, resources and reporting lines.
- Identify salient risks to people across operations and supply chains.
- Apply enhanced due diligence where geography, labour model, sector or evidence creates higher risk.
- Train people who make sourcing, buying, contracting and remediation decisions.
- Provide safe complaints and escalation channels and protect against retaliation.
- Investigate indicators, act on findings and retain evidence of outcomes.
Give boards evidence they can test.
Board reporting should identify priority risks, unresolved evidence gaps, overdue corrective actions, serious allegations, remediation decisions and measures of effectiveness. It should not treat the number of supplier questionnaires or audits as proof that harm has been prevented.
Questions to ask
Focus on the decision and the evidence.
- 01
Who owns prevention and escalation decisions?
- 02
How are risks to people identified and prioritised?
- 03
What evidence shows actions are implemented and effective?
Primary sources
Check the controlling material.
Recommended training
Watchdog PRO Certificate: Responsible Sourcing Professional
Translate governance expectations into ownership, supplier evidence, corrective action and accountable reporting.
- Map and prioritise responsible-sourcing risk
- Assess supplier evidence and audit limitations
- Apply worker-centred corrective action and remedy
Practical support
Apply the guidance to your facts.
Identify the exact product, claim, customer journey, supplier, legal entity or process involved. Preserve the information that supports the current position, record unresolved facts, assign an owner and confirm the point at which specialist review is required.
Tell us how this issue affects your organisation and receive a tailored recommendation for the most useful next step.
Important information
Check the current position.
This resource is general information, not legal advice. Laws, official guidance and proposals can change. Do not rely on a title or summary alone to decide whether a requirement applies to a particular entity, product or activity.