Modern Slavery Masterclass Series FAQs

Below are the questions asked at the modern slavery masterclass series.

Q: What are pros and cons between introducing a human rights vs modern slavery policy?

A: It depends on internal structures and overall business strategy. That said, we see really good approaches where companies have adopted broad framing of a human rights policy, with an embedded and dedicated modern slavery section. This can really help advocate for a holistic approach and integration with other sustainability practices. Also, some orgs have an appetite for fewer docs and so one “catch all” Human Rights policy which contextualises modern slavery issues, can ultimately help simplify and clarify implementation.

Q: Are there any examples of addressing modern slavery within a human rights policy?

A: Here is one example: Fortescue, Human Rights Policy

Q: Do I need a standalone modern slavery policy or can I include a modern slavery provision in existing Procurement Policy and Supplier Code of Conduct?

A: Not necessarily. It depends on internal structures and overall business strategy. It can be effective to embed your organisation’s approach to addressing modern slavery risks within your relevant functional areas and policy framework.

Q: What is good practice in assembling a human rights working group?

A: Cross-functional and based on your business structure; it may include procurement, risk, legal, sustainability, people or other teams depending on your sector and structure. Shared responsibility and designated ownership support a holistic approach.

Q: Is a modern slavery statement, i.e. as required by AU MS Act, sufficient to cover off the policy aspect?

A: No, a statement would be the output of your organisation’s efforts as a result of your policy and strategy. Preparing for the requirements of a modern slavery statement can certainly help inform your policy approach and galvanise your internal stakeholders.

Q: Outside of the social audits in place for key suppliers, what measures can be put in place to ensure that our Tier 1 suppliers (as a starting point) have adequate governance in place?

A: Beyond audits, there are several practical steps you can take to strengthen supplier governance. Start by ensuring suppliers understand and commit to your Supplier Code of Conduct. Providing onboarding and training that clearly communicates your expectations on labour rights, grievance mechanisms and remediation can help embed those standards from the outset.  You can also use tools like RFP questions or supplier self-assessments to assess the maturity of their governance and risk management practices.  Encouraging open dialogue is important so you have a trusted channel of communication to raise questions and concerns or flag risks early.

For ideas on sample questions, see the SBN Docket Starter QAs for Suppliers. Audit providers and associations (e.g., JAC, Responsible Business Alliance, Sedex, etc.) also have SAQ offerings. Finally, industry-specific collaborations (e.g. on worker voice tools) might be helpful to fill gaps between social audit-based insights and what suppliers report themselves.

Q: Are there recommended questions to ask in a Supplier Self-Assessment Questionnaire (SAQ)? And how do we assess the answers?

A: For ideas on sample questions, see the SBN Docket Sustainable Supply Chain Toolbox Starter QAs for Suppliers. Topic areas could be weighted depending on your own ESG / sustainability priorities.

Q: How can businesses contextualize human rights frameworks, particularly the UN Guiding Principles on Business and Human Rights (UNGPs) and OECD Guidelines, to support the due diligence process?

A: Companies should focus on identifying and addressing the activities within their operations and business relationships that pose the greatest risk of harm to people.

Book recommendation: Alison Taylor’s Higher Ground, explains how the UNGPs and OECD guidelines are a foundation on which to build your responsible business approach.

Q: Where do we start with assessing risk?

A: Start by assessing risks within your own operations, then move outwards. Prioritisation is key: organisations are encouraged to group suppliers by risk factors such as geography, sector, and strategic value, then focus attention and resources where risks to workers are highest.

Q: How do we apply a risk lens to our suppliers?

A: Recognising not all suppliers can be assessed at once, starting with high-risk or core suppliers is the most effective approach. Keep your risk assessment and due diligence practical, with clear policies, regular monitoring, and a shared commitment to transparency. This is a continual process, involving regular conversations, monitoring, and follow-up actions, especially when potential issues and indicators are identified.

Q: What tools and approaches work best?

A: Robust onboarding, strong contracts and regular engagement with suppliers, using tools like audits, supplier questionnaires, worker voice surveys, and independent third-party investigations support effective supply chain management.

Q: How do businesses go deeper?

A: Advanced tools such as risk scoring, social listening platforms, and adapted audit standards (like ERSA) provide ongoing, evidence-based monitoring. These tools help detect specific risks (e.g., recruitment fees, ID document retention, excessive overtime) and move beyond static country or sector labels by focusing on most serious risks and actual practices.

Q: What cautions are there around relying on external ESG ratings?

A: According to Behind ESG ratings: Unpacking sustainability metrics, OECD Publishing, Paris, which compares over 2,000 ESG metrics from eight major ESG rating products, ESG ratings reflect companies’ policies and activities rather than their impacts. Human rights and corruption are not included in some rating products, and there is significant variation in the assessment of the same issues across products. Supply chain sustainability and due diligence is not widely measured.

Q: Guidance in the past has focussed on exiting supplier relationships. Is that still appropriate?

A: Building long-term, trust-based relationships is emphasised as more effective than transactional interactions. Trust and transparency open up more honest dialogue about issues, especially when suppliers initially fear losing business if they disclose problems. Collaboration across the supply chain, including with other businesses and through collective initiatives, helps address systemic risks and build supplier capability. Recognising and rewarding good supplier practices is recommended, such as offering preferential financing or other incentives for ethical and sustainable performance, while also having clear consequences for misrepresentation or non-compliance.

Q: How do we build greater trust when there are barriers?

A: Ongoing dialogue and support are fundamental – understanding supplier challenges and providing capacity-building, particularly in high-risk or complex regions, strengthens the potential for and effectiveness of engagement.

Q: How can worker voice programs strengthen due diligence programs?

A: They can provide insight that audits can’t – especially around treatment, grievance access, and power dynamics. Workers often raise concerns that aren’t picked up via a normal review or in records management. For further information, see Session 3 of this series, which focusses on grievance mechanisms and remedy.