Modern slavery is often thought of as a problem that exists overseas or in industries far removed from everyday business operations. However, modern slavery affects every region of the world, including Australia, and can occur within workplaces, supply chains and labour hire arrangements across a wide range of sectors.
For employers, modern slavery is no longer just a social issue. It is a compliance, governance and reputational risk that demands attention. Businesses are increasingly expected to understand where modern slavery risks may exist, take reasonable steps to address them, and demonstrate accountability through policies, training and reporting.
This guide explains what modern slavery is, the legal obligations facing Australian employers, common risks in the hospitality industry, and the practical steps organisations can take to strengthen compliance.
What is modern slavery?
Modern slavery refers to situations where a person is exploited and cannot refuse or leave because of threats, violence, coercion, deception or abuse of power.
Under Australian law, modern slavery includes a range of serious exploitation offences, including:
- Human trafficking
- Slavery
- Servitude
- Forced labour
- Debt bondage
- Forced marriage
- Deceptive recruiting practices
- The worst forms of child labour
Modern slavery can affect people of any nationality, age or background. However, migrant workers, temporary visa holders and vulnerable individuals are often at greater risk of exploitation.
Examples of modern slavery may include:
- Workers being forced to work excessive hours without appropriate pay
- Employees having their passports confiscated
- Individuals being threatened with deportation if they leave a job
- Recruitment agencies charging excessive fees that trap workers in debt
- Suppliers using forced labour within manufacturing or agricultural operations
While these practices may seem extreme, investigations have uncovered cases across numerous Australian industries, including hospitality, agriculture, cleaning services, construction and manufacturing.
Modern slavery in Australia
Modern slavery is not limited to overseas supply chains.
Australian authorities have identified cases involving wage exploitation, forced labour and trafficking occurring within Australia. Many incidents remain hidden due to victims' fear of reporting, language barriers or dependence on employers for accommodation, visas or income.
The hospitality sector can be particularly vulnerable because of:
- Large casual workforces
- High employee turnover
- Reliance on migrant labour
- Labour hire arrangements
- Complex supplier networks
- Seasonal workforce demands
As a result, hospitality employers should understand both workplace and supply chain risks.
Understanding Australia's modern slavery legislation
The Modern Slavery Act 2018 (Cth) was introduced to improve transparency and encourage organisations to identify and address modern slavery risks in their operations and supply chains.
The legislation applies to entities with annual consolidated revenue above the reporting threshold and requires those organisations to publish annual Modern Slavery Statements.
The purpose of the Act is not simply to generate reports. It aims to drive meaningful action by encouraging organisations to:
- Assess modern slavery risks
- Conduct due diligence
- Implement policies and controls
- Measure the effectiveness of their actions
- Improve transparency across supply chains
Modern Slavery Statements are published on a central government register, making them accessible to investors, customers, employees and the wider public.
Employer responsibilities
Even where an organisation is not legally required to submit a Modern Slavery Statement, employers still have important responsibilities.
Good practice includes:
Understanding risks
Employers should identify where modern slavery risks may exist within their workforce, suppliers and business operations.
Establishing policies
Policies should clearly outline expectations regarding ethical conduct, human rights and responsible sourcing.
Conducting due diligence
Businesses should assess suppliers, labour hire providers and contractors to identify potential risks.
Creating reporting pathways
Employees should know how to report concerns confidentially and without fear of retaliation.
Providing training
Awareness training helps employees recognise warning signs and understand how to respond appropriately.
Monitoring effectiveness
Organisations should regularly review controls, supplier arrangements and reporting processes to ensure they remain effective.
Modern slavery risks in hospitality
Hospitality businesses face several unique risk factors.
Labour exploitation
Hospitality often relies on casual employees, international students and temporary visa holders. These groups may be more vulnerable to exploitation due to financial pressures or limited understanding of workplace rights.
Labour hire arrangements
Third-party staffing providers can create additional risks if businesses fail to monitor recruitment and employment practices.
Accommodation-linked employment
Workers who depend on their employer for accommodation may be vulnerable to coercion or unfair treatment.
Supplier risks
Restaurants, hotels and catering businesses source products from complex supply chains that may extend across multiple countries.
Potential risk areas include:
- Food production
- Seafood sourcing
- Agriculture
- Uniform manufacturing
- Cleaning services
- Linen and textile suppliers
Businesses should understand where products originate and whether suppliers have appropriate human rights safeguards in place.
Supply chain obligations
Many modern slavery risks exist beyond an organisation's direct workforce.
Businesses are increasingly expected to understand:
- Who their suppliers are
- Where products and services originate
- Whether suppliers conduct human rights due diligence
- How risks are identified and addressed
Practical steps may include:
- Supplier questionnaires
- Vendor risk assessments
- Contractual compliance requirements
- Supplier audits
- Ongoing monitoring programs
Supply chain transparency is becoming an increasingly important expectation from regulators, investors and customers alike.
Why training and awareness matter
One of the most effective ways to reduce modern slavery risk is through education.
Employees and managers are often the first people who may observe warning signs. Without appropriate training, these indicators can be overlooked.
Modern slavery awareness training can help employees:
- Understand what modern slavery is
- Recognise warning signs
- Identify high-risk situations
- Understand reporting obligations
- Respond appropriately when concerns arise
Training also demonstrates an organisation's commitment to ethical business practices and supports broader compliance efforts.
For hospitality businesses, awareness training can be particularly valuable for managers, supervisors, procurement teams and frontline staff.
Reporting requirements
Organisations required to report under the Modern Slavery Act must prepare annual Modern Slavery Statements outlining:
- The organisation's structure and operations
- Modern slavery risks within operations and supply chains
- Actions taken to assess and address risks
- How effectiveness is measured
- Consultation processes across the organisation
Statements must be approved by the organisation's governing body and submitted to the Australian Government's Modern Slavery Statements Register.
Increasingly, stakeholders expect these reports to demonstrate meaningful action rather than simply describe policies.
Future reforms and emerging expectations
Modern slavery compliance continues to evolve.
Governments, investors and consumers are placing greater emphasis on corporate accountability, supply chain transparency and human rights due diligence.
Potential future developments may include:
- Expanded reporting requirements
- Lower reporting thresholds
- Stronger enforcement mechanisms
- Increased scrutiny of supply chain practices
- Greater expectations around due diligence and remediation
Even organisations that are not currently subject to mandatory reporting may face increasing pressure from customers, investors and larger clients to demonstrate their commitment to ethical business practices.
Forward-thinking employers are already taking steps to strengthen governance, improve supplier oversight and build awareness across their workforce.
Taking a proactive approach
Modern slavery compliance is no longer solely a concern for large corporations. Every employer has a role to play in identifying risks, protecting vulnerable workers and promoting ethical business practices.
By understanding legal obligations, strengthening supply chain oversight and investing in employee awareness, organisations can reduce risk, support human rights and demonstrate responsible leadership.
For hospitality businesses, modern slavery awareness should form part of a broader compliance strategy that promotes safe, ethical and respectful workplaces while protecting both employees and brand reputation.