3. RisksDescribe the risks of modern slavery practices in the operations and supply chains of the reporting entity and any entities it owns or controls


AMSA utilises the Department of Home Affairs ‘Cause, Contribute and Linked Model’ (CCL Model) to limit the risk of modern slavery in our supply chains. Using this model assists AMSA understanding and focus on those items we directly control or contribute to as opposed to those items where we have less control.

AnchorRisks of Modern Slavery Practices in AMSA Overview

AMSA Risk Assessment

AMSA’s operations and supply chains cross many industries and sectors from call centre labour hire to search and rescue operations, stationary to construction of AtoNs. These industries and sectors have complex multi-tiered downstream supply chains that span various industries and countries.

AMSA has conducted a risk assessment on major contracts and supply chains. This assessment is based on the following risk matrix:

AMSA Risk Assessment
AMSA Risk Assessment
Very Low
  • AMSA’s direct operations (i.e. employees)
  • Travel Services
  • Aerial Search and Rescue
  • Emergency Towage Capability
  • Dedicated AtoN maintenance
  • General AtoN maintenance (various contracts)
  • Corporate clothing
  • Office furniture
  • International sector of the maritime industry

AMSA has effectively eliminated the risks associated with these contracts /supplies through various means including:

  • AMSA’s Enterprise Agreement
  • Whole of Government arrangements (including panels)
  • Generic contractual terms and conditions (including modern slavery clauses)
  • Strict procurement activity in accordance with the Commonwealth Procurement Rules
  • Working closely with suppliers to address any modern slavery risks
  • Risks associated with the international sector of the maritime industry are addressed through the Maritime Labour Convention 2006 (the Convention) which sets out standards and regulations for the working and living conditions of seafarers.

Note: AMSA is satisfied that through its operation under the maritime Labour Convention and the Fair Work Act that the risk potential to cause, contribute to or be directly linked to modern slavery is very low.

  • Materials supplied for AtoN maintenance
  • Search and rescue and emergency towage supplies

A low risk exists regarding elements of vessels that AMSA utilises and goods procured overseas (equipment, vessel parts, unique building materials/minerals etc) that may include elements of indentured labour.



  • Provision of ICT equipment and supplies

The industry which is used to manufacture computer components has a history or indentured labour and servitude which AMSA is aware of.

AMSA has little control over the risk presented by mining supply chains but will look to how it can influence  suppliers to reduce the risk over time.


It is unlikely that AMSA’s current known and immediate supply chain has risks which meet the threshold for serious exploitation as defined by the Act.

Appendix 1 describes a list of modern slavery indicators which can be used to identify the risks of our major suppliers. They included considering the indicators in the following manners:

  • Sector and industry risks
  • Product and service
  • Geographic risk
  • Entity risks

The result of assessing the indicators and applying the CCL model is an internal risk and control table which  AMSA will update as it  improves its awareness and understanding of the risk of modern slavery.

AMSA acknowledges that:

  • visibility of the risks of modern slavery practices in the full downstream supply chains is limited
  • modern slavery risks to AMSA will change over time as operational requirements change and our understanding of our supply chains improves
  • identified contracts/supply chains include a risk that there may be links to modern slavery further down the supply chain that are outside of AMSA’s control and that are not visible to AMSA.