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Modern Slavery Checklist | Fioro Legal

Fioro Legal’s Modern Slavery Checklist can help businesses identify modern slavery risks as well as areas which might benefit from improved compliance processes or enhanced focus on sustainability.

by The AFC

14 September 2021

The AFC’s High Fashion to High Vis report revealed that the Australian fashion industry contributed over $27.2 billion to the Australian economy. It is therefore unsurprising that the industry is subject to significant regulatory controls, particularly in relation to exports and imports.

One key regulatory area which has gained significant focus in recent years is modern slavery, with changes including the introduction of a new legislative regime and increased reporting obligations. Modern slavery can take many forms, including debt bondage, where a worker is forced to work for free to pay off a debt, child slavery, forced marriage, domestic servitude and forced labour governed by violence and intimidation.

Modern slavery affects more than 40.3 million people across the world, with the fashion and textiles industries frequently contributing to the issue, often without their knowledge and/or seemingly beyond their control. Whilst the Australian fashion industry has an increased focus on sustainability, home-grown textiles and workers, and despite customers increasingly seeking out “conscience driven” businesses, many big players in the market are continuing to reap cost benefits from “turning a blind eye” to modern slavery practices abroad. The introduction of the modern slavery regime is intended to bring the issue out of the shadows by requiring certain businesses to identify key areas of risk for modern slavery in their supply chains, with the overriding intention being a shake-up of industry culture and the progressive elimination of modern slavery.

The new modern slavery regime imposes extensive obligations on businesses with a consolidated annual turnover of at least $100 million to identify suppliers and areas of risk within their supply chains and to report on the mechanisms they are implementing to mitigate instances of modern slavery in their supply chain. Such businesses are required to prepare and submit modern slavery statements reporting on these issues. However, even if you are not an entity which needs to report, you will likely supply to such an entity and you will be ever-increasingly asked to provide information to them on the issues they need to report on. Further, reporting obligations aside, adopting practices which aim to eliminate modern slavery is a moral obligation on all businesses and simply the right thing to do, with sustainability and social conscience becoming key pillars of many leading brands.

Our Modern Slavery Checklist is the first step that you can take in assessing your business’ modern slavery knowledge and maturity. It will help you identify areas of your business in which you are managing modern slavery risks well, and areas which might benefit from improved compliance processes or enhanced focus on sustainability.

AFC Members can access The Modern Slavery Checklist here.

About Fioro Legal:

Fioro Legal is a boutique law firm in Sydney which advises on a broad range of commercial matters, including regulatory compliance. We have prepared a robust six-step compliance program to assist businesses within the fashion and textiles industry to assess their modern slavery risks and obligations. We assist clients to map their supply chains and conduct risk assessments to allocate risk levels across their supply chain. This assists businesses to identify gaps they may have in their supplier onboarding procedures and to develop procedures to identify risk of modern slavery at the earliest of stages. We also assist businesses to navigate modern slavery provisions which are becoming common in supply agreements, to develop training programs to educate personnel at all levels of the business on modern slavery risks and, finally, to prepare their modern slavery statement (where they meet the relevant revenue threshold).

Importantly, where instances of modern slavery are identified within a supply chain, Fioro Legal works with businesses to educate such suppliers. This is because the focus is not on immediately cutting ties with such suppliers (which could result in worse conditions for the impacted workers), but rather to assist them in developing procedures to eliminate modern slavery risks in order to remain part of your supply chain.

Fioro Legal also advises businesses who do not meet the $100 million annual turnover threshold. This is because the purpose of the modern slavery regime is to encourage a culture of compliance and increased modern slavery awareness, regardless of whether an entity is subject to specific reporting obligations. Businesses may also find themselves having to provide relevant data and information to entities upstream in their supply chain who are required to report. Having clear processes and procedures in place makes delivering such information smoother, enhancing relations and reputation with upstream suppliers.

Member Offer:

We offer a FREE 1-hour business check-up and a subsequent 30-minute follow-up for AFC members to help them better understand the modern slavery regime, how to identify their operations and supply chain and to provide initial guidance on how to improve their regulatory compliance processes. We can also discuss your broader regulatory requirements, whether that be sustainability more generally, privacy, whistleblowing, general corporate governance (such as Board procedures), financial services or other regulation.

We also offer a 5% discount on our outsourced legal counsel services, which are intended to provide ongoing legal expertise to your business without the overhead of employing a full-time legal counsel, or 10% off our legal precedent packages, which include template modern slavery clauses for your agreements, template supply agreements and business policies to address modern slavery or other regulatory risks.

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