Every third-party relationship can unlock substantial growth - but also comes with hidden compliance risks, especially concerning the Modern Slavery Act.
Compliance with Australia's Modern Slavery Act is vital for safeguarding your organisation's integrity, brand reputation, and operational resilience. With increasing expectations from regulators, customers, and investors, demonstrating continuous compliance and transparency is crucial.
Using Microsoft Forms and spreadsheets to manage compliance heightens the risk of inadvertently supporting unethical labour practices deep within your supply chains.
What is the Modern Slavery Act and Why Should It Concern Your Business?
Modern slavery includes forced labour, human trafficking, debt bondage, and child exploitation, impacting over 50 million people worldwide, including around 15,000 in Australia.
Australia’s updated Modern Slavery Act is a response to the persistent risks of forced labour and exploitation across global supply chains. As regulatory, investor, and public expectations have evolved, your organisation needs to move from reactive, box-ticking compliance exercises to continuous, risk-first oversight.
By discussing potential civil penalties, expanding reporting obligations, and appointing the first Federal Anti-Slavery Commissioner, Australia is signalling that passive compliance is no longer enough.
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Who Must Comply with Australia's Modern Slavery Act?
| Criterion | Detail |
|---|---|
| Entity Type | Australian businesses or foreign entities operating in Australia |
| Revenue Threshold | AU$100 million or more annual consolidated revenue |
| Affected Entities | Approximately 3,000 businesses |
| Reporting Deadline | Within six months of financial year-end |
| Approval Process | Board-approved and director-signed |
What Are the Key Compliance Reporting Requirements?
| Criterion | What Regulators Expect in 2025 |
|---|---|
| Entity identification (name, structure, ownership) |
• Full legal name(s) and ABN/ACN. • Corporate-structure chart showing parents, subsidiaries, and joint ventures. • Primary locations and industry sectors. |
| Operations & supply chains | • Clear description of what the entity does and buys. • Tier-1 supplier list by category/country (aggregated data acceptable). • High-level view of downstream activities (distribution, resellers) if material. |
| Risk assessment | • Inherent risk factors: geography, sector, product, labour profile. • Methodology overview: data sources, scoring model, thresholds. • Coverage of risks beyond tier-1 suppliers (e.g., raw materials, recruitment agents). |
| Actions taken (due diligence & remediation) |
• Policies embedded (supplier code, contract clauses). • Screening and audit processes—frequency, scope, tools. • Remediation steps and examples (corrective actions, terminations). • Training delivered (audience, hours, completion rates). |
| Effectiveness assessment | • KPIs or metrics (e.g., % suppliers with valid audits, remediation close-out time). • Internal review cycle (who reviews, how often). • Planned improvements for the next reporting year. |
| Consultation process (controlled entities & stakeholders) |
• How information flowed between HQ and subsidiaries/JVs. • Cross-functional working-group membership and meeting cadence. • External-stakeholder engagement where relevant (unions, NGOs, community groups). |
| Additional relevant information | • Voluntary disclosures: grievance mechanisms, worker-voice tools, ESG ratings. • Future commitments or innovation pilots (e.g., blockchain traceability, AI risk scoring). |
Why Manual Approaches Undermine Modern Slavery Act Compliance
The Modern Slavery Act demands more than a box-tick once a year. It requires businesses to identify, assess, and mitigate risk across their operations and supply chains continuously. But many organisations still rely on disjointed tools like Microsoft Forms or spreadsheets to manage supplier responses.
That approach breaks down fast, especially as reporting obligations tighten and expectations rise around evidence, accountability, and proactive due diligence.
- Data is disconnected from action: Responses live in standalone forms with no link to the supplier record, contract, or risk profile. That fragmentation makes it almost impossible to demonstrate effective, end-to-end due diligence as required by the Act.
- Evidence is difficult to retrieve: Without a defensible audit trail, teams scramble to prove who was assessed for Modern Slavery Act compliance, when, how, and what action was taken. That puts organisations at risk of enforcement and reputational harm if challenged.
- Risk is reviewed too late: Many businesses only assess modern slavery risk once a supplier is active. By then, contracts are signed and risk exposure is already embedded. The Act expects meaningful action, focusing on risk prevention rather than reaction.
- Red flags are missed: Without automated workflows, low-scoring suppliers or non-responses often fall between the cracks. Teams rely on inboxes, reminders, or spreadsheets - none of which meet the bar for structured and ongoing risk-based decision-making.
- Sensitive data is insecure: Storing modern slavery assessments in email threads, spreadsheets, Microsoft Forms or PDFs lacks the access controls, encryption, and versioning necessary to protect sensitive data. It's also difficult to maintain compliance with broader data governance obligations.
How Gatekeeper Powers Proactive, AI-Driven Modern Slavery Act Compliance
Gatekeeper brings supplier, contract, and risk data into a unified platform - enabling continuous, evidence-led compliance with the Modern Slavery Act.
With LuminIQ AI agents embedded directly into your workflows, manual form-chasing and outdated risk screening for compliance become obsolete, allowing you to uphold ethical standards consistently across your entire supply chain.
These AI agents support Legal and Procurement teams in proactively preventing breaches, protecting margins, and ensuring continuous regulatory readiness with:
- Risk-first onboarding: LuminIQ agents extract and analyse supplier data upfront, blocking unacceptable supplier before any contract is drafted.
- Smart data extraction and review: AI agents automatically review Modern Slavery Due Diligence questionnaires, including all supporting documentation, and surface any Modern Slavery Risks with each supplier.
- Automated workflow routing for approval: Gatekeeper’s LuminiQ AI agents triage compliance requests and Gatekeeper's workflows route contracts seamlessly to the right stakeholders - freeing procurement and legal teams to focus on negotiations, performance management, and driving value.
- Continuous risk scoring and compliance tracking: AI agents reassess due diligence scores over time, track compliance indicators, and prompt annual modern slavery reviews, so your supplier risk view stays current without manual effort.
- Audit-ready evidence at your fingertips: Every assessment, approval, and escalation is logged in an immutable timeline, making regulator-ready reporting for Modern Slavery Act instantaneous and reliable.
Instead of relying on outdated spreadsheets and chasing incomplete documentation, procurement, legal, and compliance teams gain an automated, unified, and continuously updated view of supplier risks directly related to forced labour and unethical practices. Gatekeeper’s LuminIQ AI proactively identifies and blocks high-risk suppliers, ensures ongoing due diligence, and maintains instant audit readiness - enabling your business to confidently demonstrate compliance, protect your brand reputation, and drive ethical growth across your entire supply chain.
Frequently Asked Questions About Modern Slavery Compliance
What is the Modern Slavery Act, and who needs to comply?
Australia’s Modern Slavery Act 2018 requires companies with at least AUD $100 million in annual revenue, including foreign entities operating in Australia, to report on modern slavery risks in their operations and supply chains.
What does modern slavery include?
Modern slavery refers to serious human rights violations such as forced labor, human trafficking, debt bondage, and child exploitation. The Act requires businesses to assess and address risks not just in direct suppliers but across their broader supply chains.
What’s expected in Modern Slavery Act reports from 2025?
Updated expectations include clear reporting on entity ownership, supplier risk, due diligence actions, effectiveness assessments, and future improvements. Reports must be board-approved and signed by a company director.
Why are spreadsheets and manual tools risky for compliance?
Manual systems create fragmented records, weak audit trails, and delayed responses to red flags. They make it harder to prove timely risk reviews or demonstrate continuous compliance if regulators or stakeholders investigate.
How does Gatekeeper help with Modern Slavery Act compliance?
Gatekeeper unifies supplier, contract, and compliance data in one secure system. LuminIQ AI Agents automate supplier reviews, track risk over time, and maintain a full audit trail, making it easy to demonstrate due diligence at every stage.
Can Gatekeeper flag risky suppliers before contracts are signed?
Yes. Gatekeeper uses risk-first onboarding to screen and block non-compliant suppliers early in the process, before contracts are drafted or approved—reducing exposure and strengthening compliance.
What kind of audit evidence does Gatekeeper provide?
Gatekeeper automatically logs every decision, approval, and risk score in an immutable timeline. This gives Legal, Procurement, and Compliance teams instant access to audit-ready documentation, whenever needed.
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