11 May 2020
Introduction
In light of the unprecedented impact of the COVID-19 pandemic, and the potential impact on a reporting entity's ability to assess, mitigate and adequately report on the risks of modern slavery, the Federal Government has announced an extension to the deadlines for reporting entities to lodge their modern slavery statements under the Modern Slavery Act 2018 (Cth) (Act).
The relevant new deadlines are set out in the below table:
|
Reporting period |
Original deadline for submission of modern slavery statement |
New, extended deadline for submission of modern slavery statement |
|
1 April 2019 – 31 March 2020 |
30 September 2020 |
31 December 2020 |
|
1 July 2019 – 30 June 2020 |
31 December 2020 |
31 March 2021 |
|
Reporting periods ending after 30 June 2020 |
The 6 month deadline for reporting periods after 30 June 2020 remains unchanged. |
|
New guidelines
In addition to extending the deadline for the submission of modern slavery statements, the Australian Border Force (ABF) has also published guidance for reporting entities on reducing the risk of vulnerable workers in their operations and supply chains becoming exposed to modern slavery as a result of the COVID-19 pandemic.
As part of the guidance, the ABF is strongly encouraging reporting entities to consider how factory shut downs, order cancellations, workforce reductions and changes to supply chain structures can disproportionately affect some workers and increase their risk of exposure to modern slavery and other forms of exploitation.
The guidance also recognises that due to COVID-19 impacts, many entities may be unable to adequately address all of the mandatory reporting criteria as required by the Act in their modern slavery statement as a result of:
-
an inability to undertake planned activities to address modern slavery risks;
-
a limited capacity to prepare statements due to staffing changes; or
-
significant changes to supply chains.
As such, the ABF recommends reporting entities address in their statements, in detail, how COVID-19 has impacted their capacity to assess and address modern slavery risks.
A copy of the ABF Modern Slavery Act Information sheet: coronavirus can be accessed here.
For further information, please contact:
Kristy Peacock-Smith, Partner, Bird & Bird
kristy.peacock-smith@twobirds.com
