Modern Slavery Policy: What It Is & Why It Matters
A modern slavery policy is a documented commitment setting out how an organisation identifies, assesses and addresses the risk of modern slavery in its operations and supply chains.
It's how a business turns "we don't tolerate exploitation" into a real, accountable process.
Modern slavery is not just a problem for far-away factories. Through outsourcing, offshoring and labour hire, it can reach into the contact centre industry's supply chains too — which is exactly why it's worth understanding.
ACXPA isn't an authority on modern slavery, and this isn't legal advice.
The aim of this guide is simpler: to explain clearly what modern slavery and a modern slavery policy are, how they connect to our industry, and — most importantly — where to go for help.
What it is
A public commitment and internal process for finding and addressing modern slavery risk across a business's operations and supply chains.
Why our industry should care
Outsourcing, offshoring and labour hire mean modern slavery risk can sit in a contact centre's supply chain — and large operators have legal reporting obligations.
What this guide covers
What modern slavery is, the Modern Slavery Act, the industry connection, what a policy covers, and where to get help.
What is Modern Slavery?
The term modern slavery refers to any situation of exploitation where a person cannot refuse or leave work because of threats, violence, coercion, abuse of power or deception.
It's about a loss of freedom, not just poor conditions.
Under Australia's Modern Slavery Act, the term covers serious exploitation defined by the existing human trafficking and slavery offences in the Commonwealth Criminal Code.
In practice it encompasses a range of practices, including:
What modern slavery can include
- Slavery, servitude and slavery-like practices
- Forced labour and the worst forms of child labour
- Human trafficking and debt bondage
- Forced marriage and deceptive recruiting for labour or services
It can look like a farm worker who can't leave because of threats from an employer, a person forced to work to pay off a debt they can never clear, or someone coerced into marriage.
It is a serious crime and a human rights abuse — and it happens in Australia, not only overseas.
If you or someone you know needs help
If someone is at immediate risk, call 000. If you or someone you know is in, or at risk of, human trafficking or slavery, contact the Australian Federal Police on 131 237 (131AFP) or visit afp.gov.au.
The Modern Slavery Act & the Policy
The Australian Government introduced the Modern Slavery Act 2018, which requires entities based or operating in Australia with annual consolidated revenue of more than $100 million to report each year on the risks of modern slavery in their operations and supply chains, and the actions taken to address them.
Businesses below that threshold may report voluntarily.
It's worth being clear about the difference between two things that are often confused:
A modern slavery statement
The public annual report that larger entities must lodge — describing their structure, supply chains, the modern slavery risks they've identified, and what they're doing about them.
Statements are published on a government register.
A modern slavery policy
The internal commitment and process that sits behind the statement — how the business governs the issue, assesses risk, does supplier due diligence, trains staff, and handles concerns.
The policy is the engine; the statement is the report.
The law is tightening
For years there were no financial penalties for non-compliance, and there still aren't civil penalties in force today.
But the landscape is shifting: Australia appointed its first Anti-Slavery Commissioner in December 2024, and the government has agreed in principle to introduce penalties for non-compliance, with consultation underway.
Treating a modern slavery statement as a box to tick is becoming a riskier position, not a safer one.
How Modern Slavery Touches the Call Centre Industry
It's easy to assume modern slavery has nothing to do with contact centres. But the risk rarely sits in your own office — it sits in your supply chain, and our industry has some specific exposure points.
Outsourcing & offshoring
When you outsource contact centre or back-office work — often to providers in regions with higher exploitation risk — those providers become part of your supply chain, and their labour practices become your concern.
Labour hire & recruitment
Temporary, agency and visa workers can be exposed to deceptive recruiting, recruitment fees and debt bondage. The recruitment supply chain is a recognised modern slavery risk area.
Procurement & reporting
Everyday procurement — hardware, uniforms, cleaning, security — carries risk too. And large operators (over $100M revenue) have a legal duty to report on all of it.
The practical takeaway
If your business outsources, offshores or uses labour hire, modern slavery risk is something to assess — not because ACXPA says so, but because it's the right thing to do and, for larger operators, a legal obligation.
Due diligence on your outsourcing and recruitment partners is the most relevant action most contact centres can take.
What a Modern Slavery Policy Covers
There's no single template, but an effective modern slavery policy generally addresses these elements. They're also the building blocks of a credible annual statement for entities that must report.
Governance & commitment
A clear statement of the business's commitment, who is accountable, and how modern slavery risk is overseen.
Map operations & supply chains
An honest picture of your operations and the suppliers behind them — including outsourcers, labour hire and procurement.
Assess the risks
Where in those operations and supply chains modern slavery is most likely — by geography, industry and labour type.
Supplier due diligence
How you vet and hold suppliers to account — often through a supplier code of conduct and contractual expectations.
Training & awareness
Helping the people who manage suppliers and recruitment recognise the warning signs and know what to do.
Grievance & remediation
A safe way for concerns to be raised, and a plan for how the business responds and remediates if modern slavery is found.
💡 Get qualified advice
This guide is general information, not legal advice.
If your business has reporting obligations or needs a policy, work from the official government guidance and seek qualified legal or compliance advice for your specific situation.
Common Modern Slavery Policy Mistakes
For our industry, the recurring mistakes are less about the document and more about what's behind it.
❌ Treating it as a tick-box statement
Lodging a polished statement with no real risk assessment or action behind it satisfies no one — and, as penalties approach, it's an increasingly exposed position.
❌ Ignoring the outsourced supply chain
The risk usually isn't in head office — it's in offshore providers and labour hire. A policy that only looks inward misses where exposure actually lives.
❌ No due diligence on partners
Signing an outsourcing or recruitment contract without checking the partner's own labour practices passes the risk straight through to your customers' experience and your reputation.
❌ Forgetting it's about people
Modern slavery is a human rights abuse, not just a compliance line item. A policy written only for the auditor misses the point entirely.
Remember the stakes: behind every supply-chain risk assessment are real people who may not be free to leave or refuse their work.
This is general information, not legal advice — but the human reality is the reason the law, and a genuine policy, exist.
Where to Get Help & Official Resources
ACXPA is not the right source for advice or support on modern slavery — these official channels are. Whether you're seeking help, reporting a concern, or building a compliant policy, start here.
If someone is at risk
- Immediate danger: call 000
- Report trafficking or slavery: Australian Federal Police on 131 237 (131AFP)
- AFP website: afp.gov.au
For business obligations & guidance
- Government guidance & the Modern Slavery Register: Attorney-General's Department
- The legislation: Modern Slavery Act 2018
- Independent advocate: the Australian Anti-Slavery Commissioner
A note on this guide
This page is a plain-English overview to help you understand the topic and find the right help.
It is not legal advice and is not a substitute for the official government guidance or qualified professional advice. If you have reporting obligations, start with the Attorney-General's Department.
Frequently Asked Questions About Modern Slavery
What is modern slavery?
Modern slavery is any situation of serious exploitation where a person can't refuse or leave work because of threats, violence, coercion, abuse of power or deception.
It includes slavery, servitude, forced labour, the worst forms of child labour, human trafficking, debt bondage, forced marriage and deceptive recruiting. It is a serious crime and a human rights abuse.
What is a modern slavery policy?
It's a business's documented commitment and internal process for identifying, assessing and addressing the risk of modern slavery in its operations and supply chains — covering governance, risk assessment, supplier due diligence, training and how concerns are handled.
What's the difference between a modern slavery policy and a statement?
The policy is the internal commitment and process.
The statement is the public annual report that larger entities are required to lodge, describing their structure, supply chains, the risks they've identified and the actions they've taken.
The policy is the engine; the statement is the report it produces.
Who has to report under the Modern Slavery Act?
Entities based or operating in Australia with annual consolidated revenue of more than $100 million must report each year.
Businesses below that threshold can choose to report voluntarily. The government has reviewed the threshold and, for now, kept it at $100 million.
Are there penalties for not complying?
Not currently — there are no civil penalties in force today for failing to report. But that is changing.
Australia appointed its first Anti-Slavery Commissioner in December 2024, and the government has agreed in principle to introduce penalties for non-compliance, with consultation underway.
Relying on the absence of penalties is becoming a weaker position over time.
How does modern slavery affect the call centre industry?
Mostly through the supply chain.
Outsourcing and offshoring contact centre or back-office work, and using labour hire or recruitment agencies, can introduce modern slavery risk — particularly where workers are offshore, on visas, or recruited through fees.
Large operators also have reporting obligations covering this risk.
What should a modern slavery policy include?
Typically: a governance and commitment statement, a map of operations and supply chains, a risk assessment, supplier due diligence (often via a supplier code of conduct), training and awareness, and a grievance and remediation process.
For specifics, use the official government guidance and seek qualified advice.
Where can I get help or report modern slavery?
If someone is in immediate danger, call 000. To report human trafficking or slavery, contact the Australian Federal Police on 131 237 (131AFP) or visit afp.gov.au.
For business obligations and guidance, see the Attorney-General's Department modern slavery resources.
Where to Next
Summary: Modern Slavery Policy
A modern slavery policy is a business's documented commitment and process for identifying and addressing the risk of modern slavery in its operations and supply chains.
Under the Modern Slavery Act 2018, entities with more than $100 million in annual revenue must report on those risks each year; smaller businesses can report voluntarily.
There are no financial penalties in force today, but with a new Anti-Slavery Commissioner appointed and penalties under active consultation, the bar is rising.
For the contact centre industry, the risk usually lives in the supply chain — outsourcing, offshoring and labour hire — which makes supplier due diligence the most relevant action most operators can take.
A policy only matters if there's genuine risk assessment and action behind it, not just a statement filed to tick a box.
ACXPA's role here is simply to explain and to point you in the right direction.
For help, call 000 in an emergency or the AFP on 131 237 (131AFP); for business obligations, start with the Attorney-General's Department and qualified professional advice. This guide is general information, not legal advice.
