As Australia’s Modern Slavery Act matures, corporate reporting quality is improving. Yet a persistent gap remains between disclosure and genuine supply chain visibility. This gap has shifted attention from reporting towards how risks are identified and managed across supply chains.
The Modern Slavery Disclosure Quality Ratings: ASX100 Companies Update FY2024, published by the Monash Centre for Financial Studies, provides a clear benchmark of where Australian businesses stand today. While progress is evident, the findings also highlight structural weaknesses that continue to limit effective modern slavery risk management, particularly beyond Tier 1 suppliers.
This is where robust supply chain due diligence programmes, grounded in independent audits and ongoing supplier engagement, play a decisive role.
What the ASX100 Disclosure Data Reveals About Modern Slavery Risk
The FY2024 analysis reviewed modern slavery statements from ASX100 companies. The results show a clear divergence in reporting maturity.
Key findings include:
- 65 ASX100 companies achieved an A-grade, up from 56 in the previous year
- Five companies received E or F ratings, indicating minimal or weak disclosure
- Disclosure beyond Tier 1 suppliers remains the weakest area, particularly in sectors such as healthcare and Industrials
- Companies demonstrating stronger performance increasingly reference audits, grievance mechanisms, supplier engagement and follow-up actions, rather than high-level policy statements alone
While reporting quality has improved, visibility into deeper supply chain tiers continues to lag. Companies demonstrating leadership are those embedding supplier due diligence into procurement and supplier management processes, supported by evidence and outcomes rather than compliance alone.
Why Supplier Due Diligence Is the Missing Link
Supplier due diligence is often discussed in the context of compliance. In practice, it is the mechanism that enables organisations to move from assumptions to insight.
Effective supplier due diligence allows organisations to:
- Understand who is in their supply chain, including subcontractors and labour providers
- Identify geographic, sectoral and labour-related risk factors
- Verify working conditions through independent assessment
- Track corrective actions and improvements over time
This shift from disclosure to verification is vital for identifying where modern slavery risks are most likely to occur.
Moving From Reporting to Ongoing Supply Chain Insight
One of the clearest distinctions between higher- and lower-performing companies is the use of independent audits as part of their supply chain due diligence approach. Achilles supports organisations through a structured audit framework that combines on-site social audits assessing labour practices, worker welfare, health and safety, and management systems with desktop assessments to validate policies and controls. Where gaps are identified, corrective action plans are developed with suppliers and tracked to closure. For organisations operating in Australia, these site-based inspections provide a practical way to validate modern slavery risk assessments and demonstrate credible action beyond self-reported information, while generating the evidence increasingly expected by regulators and stakeholders.
While audits provide depth, sustainable supply chain due diligence requires continuity. The Achilles Ethical Business Programme supports this by enabling organisations to assess how standards are applied across suppliers, contractors and subcontractors, demonstrate actions through independently verified evidence, and mitigate labour-related and reputational risks over time.
As highlighted in the ASX100 research, discontinuity in disclosures is a common reason for downgraded ratings. Embedding ongoing supplier due diligence helps organisations maintain visibility and governance year on year, while reducing duplication and disclosure fatigue for suppliers.
Control Comes From Evidence, Not Assumptions
A recurring theme in the Monash analysis is the shift among leading companies from activity-based reporting to evidence of effectiveness. This includes tracking:
- Supplier screening volumes
- Audit findings and corrective actions
- Training completion rates
- Grievances raised and resolved
Achilles enables this transition by integrating audit outcomes, supplier data and risk indicators into a single view. This allows procurement, sustainability and compliance teams to see where risks are emerging, where progress is being made, and where intervention is required.
In practice, control is not achieved through policies alone, but through the ability to act on verified insight across the supply chain.
Why This Matters Now for Australian Businesses
The ASX100 report makes clear that expectations are rising. What was considered good practice in early reporting years is no longer sufficient. With potential reforms to Australia’s Modern Slavery Act under consultation, organisations should expect:
- Greater scrutiny of due diligence processes, not just disclosures
- Increased focus on effectiveness, outcomes and remediation
- Higher expectations around supply chain mapping beyond Tier 1
Organisations that invest now in structured supplier due diligence and independent verification are better positioned to respond, not only to regulatory change but to broader stakeholder expectations around ethical business conduct.
Speak with an Achilles expert to understand how our social audits and Ethical Business Programme can strengthen supplier due diligence, improve visibility beyond Tier 1, and demonstrate credible action under Australia’s Modern Slavery Act.
Frequently Asked Questions
What is supplier due diligence?
Supplier due diligence is the process of identifying, assessing and managing risks within a company’s supply chain. In the context of modern slavery in Australia, it includes verifying labour practices, assessing risk exposure and monitoring supplier performance over time.
Why is supply chain due diligence important under Australia’s Modern Slavery Act?
The Act requires large organisations to identify and address modern slavery risks in their operations and supply chains. Effective supply chain due diligence provides the evidence needed to demonstrate how risks are assessed, mitigated and monitored.
What does the ASX100 modern slavery report say about supply chain visibility?
The FY2024 report shows that disclosure beyond Tier 1 suppliers remains the weakest area across most sectors. Many companies still struggle to map and monitor deeper supply chain tiers, limiting risk visibility.
How do social audits support modern slavery risk management?
Social audits provide independent, on-site verification of labour conditions and management systems. They help organisations identify real-world risks, validate supplier claims and track corrective actions.
How can Achilles help with supplier due diligence?
Achilles supports supplier due diligence through independent social audits and its Ethical Business Programme, which enables ongoing supplier verification, risk monitoring and performance improvement across global supply chains.
What constitutes modern slavery in Australia?
Modern slavery covers several severe forms of exploitation under Australian law. Common examples include forced labour, where people are made to work under threats or unsafe conditions; debt bondage, where individuals are trapped working to repay unfair or manipulated debts; domestic servitude, where people are forced to work in private homes with little freedom; and child labour, where children are used for work or services that compromise their wellbeing. These practices can occur in many settings and often remain hidden.
Why is modern slavery hard to detect in Australia?
It is often hidden in private or isolated work environments. Low awareness, language barriers, fear of job or visa loss and limited frontline detection all contribute to under-reporting.
