Many of Australia’s largest companies fail to show enough public evidence that workers affected by modern slavery can safely report concerns, a new Monash University-led report has found.
The report, Grievance Mechanisms and Remediation, assessed the FY2024 modern slavery statements of the 39 largest ASX100 Financials and Materials companies.
The report found that companies had major gaps in disclosing information about grievance mechanisms and remediation.
Grievance mechanisms are a way for workers, communities and other stakeholders to report actual or suspected harms, unsafe or unfair working conditions, exploitation, or other rights violations, while remediation involves actions to correct and redress the harm suffered and prevent its recurrence.
The findings come as the federal government consulted on strengthening Australia’s modern slavery laws, including a proposed criminal offence for companies that fail to prevent modern slavery in their operations and supply chains.
Lead author Associate Professor Nga Pham, from the Monash Centre for Financial Studies at Monash Business School, said that without safe, accessible grievance channels and effective remediation processes, workers are at risk because they may be unable to report exploitation, causing harms to remain hidden.
“Workers, especially migrant, temporary, and low-skilled workers, are vulnerable due to limited knowledge of their rights, language barriers, and fear of retaliation,” Associate Professor Pham said.
The report introduces a new 40-question 8R Framework to assess how transparently companies disclose information about the design and operation of modern slavery grievance mechanisms and whether their remediation processes are effective.
On average, companies addressed 14.28 of the 40 questions in the 8R Framework – about 36 per cent. Only five companies addressed at least half of the questions, while nine addressed fewer than 10.
Associate Professor Pham said the findings raised questions about whether companies’ complaint systems actually worked.
“A grievance mechanism should be more than a hotline or a policy on paper. It must be safe and trusted by workers, warn companies early of harm and provide a pathway to remedy,” Associate Professor Pham.
“Our findings suggest that companies are much more comfortable reporting on their policies, committees and complaint channels than explaining what happens after a concern is raised.”
The report found that:
- Only 10 per cent of companies disclosed evidence of consulting affected stakeholders or their representatives when designing grievance mechanisms.
- Just 5 per cent disclosed a full range of potential remedies, and only 5 per cent reported consulting complainants about whether the remedy provided was adequate.
- Only 5 per cent disclosed remediation outcomes or the proportion of cases resolved to complainants’ satisfaction.
- No company disclosed the average or median time taken to complete remediation.
Under the federal government’s proposed modern slavery reforms, demonstrating that reasonable steps were taken to prevent modern slavery could become critical to a company’s defence.
Associate Professor Pham said the 8R Framework could act as an assessment and improvement tool to help companies identify gaps in their grievance and remediation reporting.
“The 8R Framework could support government and regulators in developing clearer guidance about the systems, processes and evidence relevant to reasonable steps,” Associate Professor Pham said.
Ms Esty Marcu, Director of Responsible Business and Human Rights at The University of Sydney, said many organisations have found it challenging to establish effective grievance mechanisms.
“This Framework has been incredibly valuable because it not only provides a clear set of principles to guide good practice, but also enables organisations to self-assess their maturity and identify opportunities for improvement,” Ms Marcu said.
The authors recommend clearer communication and disclosure of grievances and remediation processes, stronger stakeholder participation, improved transparency around remediation outcomes, and safeguards that protect complainants’ privacy and safety.
The researchers caution that the report assesses the quality of public disclosure via their modern slavery statements and does not necessarily represent companies’ underlying practices or information available through other channels.
