Modern Slavery


The Commonwealth Modern Slavery Act requires all businesses and other organisations with a consolidated revenue over $100 million to report annually on the risk of slavery in their operations and supply chains by submitting a Modern Slavery Statement.

The first reporting period is July 2019-June 2020 with reports initially due by 31 December 2020 – now extended to 31 March 2021.

In this follow up to our webinar in May last year, Kimberly Randle, of Fair Supply, addressed issues that businesses are facing as we approach the end of the first reporting period.

The Modern Slavery Statements

Reporting entities are required to speak to the steps they have taken to identify, address, and mitigate modern slavery risks in their supply chains, and the effectiveness of their response. These statements must be approved by the Board of Directors or equivalent and signed by a director.

Australian Border Force Guidance

On 21 April the Australian Border Force issued the following guidance in relation to the impact of COVID-19 on modern slavery reporting requirements under the Modern Slavery Act.

The ABF encourages entities to take steps to protect vulnerable workers in their global operations and supply chains from the impacts of COVID-19. Entities should also integrate consideration of modern slavery risks into their broader response to the pandemic. This should include providing information about modern slavery risks to the board or executives as part of COVID-19 updates and using internal sustainability, human rights or modern slavery working groups to identify opportunities for action

In summary, reporting entities should address the impact of COVID-19 in their modern slavery statements by specifically reporting on supply chain and operational disruptions and the impact this has on addressing modern slavery during the reporting period.

This informative and timely webinar provided practical guidance on the following:

  • identifying and mapping modern slavery in operations and supply chains
  • utilising supplier contracts, codes of conduct and workplace policies to reduce modern slavery risks
  • preparing legally compliant modern slavery statements
  • addressing the impact of the COVID-19 crisis in modern slavery statements in light of recently released Australian Border Force guidance.

The webinar recording and Kimberly Randle’s slides are available to download below:


About Kimberly Randle and FairSupply

Kimberly Randle

Kim Randle, Fair Supply’s Executive Director and Principal Lawyer is an experienced and innovative human rights advocate and lawyer specialising in modern slavery. Kimberly played an instrumental role in both the formation of, and advocacy for, the passage of the NSW and Commonwealth Modern Slavery Acts. Prior to co-founding Fair Supply, Kimberly held the role as Senior Director of Corporate and Legal for International Justice Mission Australia and worked at top tier law firms in both Australia and the United States. Kimberly appeared as an expert witness at both the NSW Legislative Committee Inquiry into Modern Slavery and the Commonwealth Joint Law Enforcement Committee Inquiry into Modern Slavery. Following the Parliamentary Inquiries, Kimberly acted as a key liaison to the Australian Senate and NSW Legislative Committee in drafting of necessary provisions to combat the Online Sexual Exploitation of Children. In 2017 Kimberly was a finalist in the Women in Law Awards for Not For Profit Lawyer of the Year.


Fair Supply is a specialised law firm that utilises world class subject matter expertise and experience in the legal profession to provide organisations with a revenue-positive multidisciplinary solution to comply with the NSW and Commonwealth Modern Slavery Acts.

The Fair Supply team comprises of individuals with more than 30 years cumulative experience in the modern slavery sector. Fair Supply consultants include legally-qualified personnel who have worked at top tier commercial firms both in Australia and internationally. Our physical presence is in Australia and Singapore. The Fair Supply team all have management experience working with multinational and publicly listed companies.