As per the Commonwealth Modern Slavery Act 2018 Guidance for Reporting Entities

Type of RiskIndicators

Sector and industry risks

Certain sectors and industries may have high modern slavery risks because of their characteristics, products and processes.

  • Use of unskilled, temporary or seasonal labour.
  • Use of short-term contracts and outsourcing.
  • Use of foreign workers or temporary or unskilled labour to carry out functions which are not immediately visible because the work is undertaken at nighttime or in remote locations, such as security or cleaning.
  • Use of child labour in hazardous conditions, such as underground, with dangerous machinery or tools, in unhealthy environments (including where they are exposed to physical or sexual abuse), or for long hours.
  • Recruitment strategies by suppliers, their agents or labour hire agencies target specific individuals and groups from marginalised or disadvantaged communities.
  • The sector involves direct engagement with children, including through orphanage tourism and other forms of ‘voluntourism’ (including through companies’ social investment and corporate social responsibility programs).

Product and services risks

Certain products and services may have high modern slavery risks because of the way they are produced, provided or used.

  • Cost requirements or delivery timeframes might require suppliers to engage in excessive working hours, make cost savings on labour hire or rapidly increase workforce size.
  • The development of the product or delivery of the services has been reported as involving labour exploitation by international organisations or NGOs.
  • Children are often used in the development of the product or delivery of the service, such as carpet weaving.
  • The product or components of the product are made in countries where there is a high risk of labour exploitation reported by international organisations or NGOs.
  • The services are provided in countries where there is a high risk of labour exploitation reported by international organisations or NGOs.
  • The product is made from materials or using services reported to involve a high risk of labour exploitation by international organisations or NGOs.

Geographic risks

Some countries may have higher risks of modern slavery, including due to poor governance, weak rule of law, conflict, migration flows and socioeconomic factors like poverty. Several organisations issue public reports evaluating governance, corruption and rule of law in countries around the world. You can use these reports to identify higher risk countries for modern slavery.

  • The country has not ratified international conventions relevant to modern slavery, such as: the International Convention to Suppress the Slave Trade and Slavery (1926); ILO Convention (No. 29) concerning Forced or Compulsory Labour (1930); the Supplementary Convention on the Abolition of Slavery, the Slave Trade and Practices similar to Slavery (1956); the Protocol to Supress, Prevent and Punish Trafficking in Persons, Especially Women and Children (2000); ILO Convention (No. 182) concerning the Prohibition and Immediate Action for the Elimination of the Worst Forms of Child Labour (1999).
  • The country is reported to have a high prevalence of modern slavery or labour rights violations, other human rights violations and/or child labour by international organisations or NGOs.
  • The country has inadequate protections for workers, including no or weak capacity to effectively monitor workplace standards and enforce compliance with national standards.
  • Law enforcement agencies are reported to be hostile to workers in at risk industries.
  • The country forces parts of the population to work for development purposes, for example to assist in construction or agriculture.
  • The country is reported to have weak rule of law by international organisations or NGOs, including due to corruption, conflict and/or political instability.
  • The country has a high prevalence of people who are vulnerable to exploitation because they are impoverished, displaced or subject to severe discrimination

Entity risks

Some entities may have particular modern slavery risks because they have poor governance structures, a record of treating workers poorly or a track record of human rights violations.

  • Entity has previously been reported as noncompliant with human rights or labour standards, including by media or NGO sources.
  • Entity’s procurement and sourcing processes appear poorly managed or inefficient.
  • Entity has complex or opaque supply chains.
  • Workers appear to have little information about workplace entitlements and protections and there is a general lack of information about workplace standards.
  • Audit results for the entity appear unreliable or conflict with other sources of information about the supplier, such as NGO reports.
  • Staff recruitment costs by labour hire companies or recruiters are not covered by the company, meaning that recruitment expenses such as travel may be improperly imposed on workers.
  • Entity provides residential care for children overseas.

Indicators of modern slavery

A combination of these signs may indicate a person is in a situation of modern slavery and that further investigation and assessment is required. You should also consider that some groups may be at higher risk of being impacted by modern slavery, such as women and migrant workers. For example, women can be disproportionately impacted by modern slavery due to structural disadvantages, including lack of access to education.

he suspected victim or victims are:

  • living at the workplace, or another place owned/controlled by their employer
  • underpaid or not paid at all
  • required to work excessive hours
  • confined or isolated in the workplace or only leave at odd times
  • guarded at work or in their accommodation
  • isolated in remote locations that are difficult to access and/or restricted from contacting or interacting with people outside the workplace (for example, their phones are confiscated or they are supervised when in public)
  • managed by an intermediary or third party who ‘holds’ or ‘invests’ their money for them
  • subject to different or less favourable working conditions than other workers because of their country of origin, gender or other factors • unable to terminate their employment at any time appear to be servicing a debt to an employer or a third party (such as a recruitment agent)
  • appear to be subjected to, or threatened with, violence, emotional, sexual, verbal or physical abuse and/or degrading treatment in connection with their employment
  • appear to be subjected to intimidation, such as threats to their family or close relations in connection with their employment • appear to have false travel or personal documents and/or are not allowed access to these documents because they are being held by an employer or third party
  • appear to have been deceived about the conditions of their employment
  • are not provided with contracts in a language and format that they can easily understand
  • are not informed of, or do not appear able to understand the terms and conditions of their employment
  • are not provided with any protective equipment, training or means to refuse to participate in dangerous work practices, or refuse to handle known toxic materials or hazards
  • do not have permission to work because they are from another country or appear to be working in breach of visa requirements.