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An Anti-Slavery and Human Trafficking Policy sets out a company's commitment and actions to prevent modern slavery in its operations and supply chains. Under Australia's Modern Slavery Act 2018, larger organizations must show how they identify and address slavery risks through clear policies and procedures.

The policy typically outlines steps for due diligence, risk assessment, and reporting of concerns. It helps protect vulnerable workers, ensures compliance with modern slavery laws, and guides staff on spotting warning signs like restricted movement, withheld wages, or unsafe working conditions. Organizations use these policies to demonstrate their ethical standards and meet their legal obligations.

Large Australian businesses need an Anti-Slavery and Human Trafficking Policy when they meet the $100 million annual revenue threshold under the Modern Slavery Act. This policy becomes essential before submitting your first modern slavery statement, which must detail how you address slavery risks in your operations.

Companies also benefit from implementing this policy when expanding supplier networks, especially in high-risk industries or regions. It proves particularly valuable during tender processes, investor due diligence, or when entering contracts with government agencies. The policy helps protect your organization from legal risks while demonstrating your commitment to ethical business practices.

• Basic Compliance Policy: Focuses on meeting minimum Modern Slavery Act requirements, including reporting mechanisms and risk assessment procedures.
• Comprehensive Supply Chain Policy: Extends beyond basic compliance to detail supplier vetting, auditing processes, and corrective action procedures.
• Industry-Specific Policy: Tailored for high-risk sectors like manufacturing, agriculture, or construction, with specific risk indicators and control measures.
• Global Operations Policy: Designed for multinational companies, addressing international supply chains and multiple jurisdictional requirements.
• SME-Focused Policy: Simplified version for smaller businesses not meeting reporting thresholds but wanting to demonstrate ethical practices.

• Board Members and Executives: Approve and oversee the Anti-Slavery Policy, ensuring organizational commitment and resource allocation
• Compliance Officers: Draft, implement, and monitor the policy, coordinating reporting requirements and due diligence processes
• HR Managers: Train staff on policy requirements and manage internal reporting mechanisms
• Procurement Teams: Apply policy guidelines when selecting and managing suppliers
• Suppliers and Contractors: Must comply with policy requirements and demonstrate their own anti-slavery measures
• All Employees: Required to understand, follow, and report potential violations of the policy

• Supply Chain Mapping: Document all suppliers, contractors, and business partners across your operations
• Risk Assessment: Analyze high-risk areas in your operations and supply chains, focusing on industry and geographical factors
• Current Processes: Review existing procurement, recruitment, and supplier management procedures
• Training Needs: Identify which staff roles need detailed training on modern slavery issues
• Reporting Systems: Set up clear channels for raising concerns and reporting violations
• Performance Indicators: Define measurable targets to track policy effectiveness
• Legal Requirements: Check Modern Slavery Act obligations specific to your organization's size and structure

• Policy Statement: Clear commitment to preventing modern slavery and human trafficking
• Scope Definition: Outline which operations, suppliers, and entities the policy covers
• Legal Framework: Reference to Modern Slavery Act 2018 and related Australian legislation
• Due Diligence Process: Steps for assessing and managing slavery risks in operations
• Reporting Procedures: Clear mechanisms for raising concerns and whistleblower protections
• Training Requirements: Staff awareness and competency development obligations
• Enforcement Measures: Consequences for non-compliance and remediation processes
• Review Schedule: Timeframes for policy updates and effectiveness assessment

People often confuse an Anti-Slavery and Human Trafficking Policy with a Compliance and Ethics Policy. While both address ethical business conduct, they serve distinct purposes and have different legal requirements.

• Scope and Focus: Anti-Slavery policies specifically target modern slavery risks in operations and supply chains, while Compliance and Ethics policies cover broader ethical conduct including corruption, fraud, and general business integrity
• Legal Requirements: Anti-Slavery policies must meet specific Modern Slavery Act reporting requirements for companies over $100M revenue, whereas Compliance and Ethics policies aren't subject to the same strict statutory obligations
• Implementation: Anti-Slavery policies require detailed supply chain mapping and risk assessments, while Compliance and Ethics policies typically focus on internal conduct and decision-making frameworks
• Reporting Obligations: Anti-Slavery policies must align with mandatory annual modern slavery statements, but Compliance and Ethics policies have more flexible reporting structures