Avetta's Lynda Richards says grievance mechanisms must be tested as a proposed failure to prevent offence raises the stakes for employers
Australian employers that log zero modern slavery grievances in a year should treat the result as a warning sign, not a win, a supply chain risk specialist has cautioned, as new research finds the country's largest companies say little about what happens after workers raise a concern.
Lynda Richards, health, safety and environment principal at supply chain risk management company Avetta, told HRD that too many organisations misread an empty complaints log. She pointed to "organisations thinking that we don't have any reports, grievance reports for the last year, that's something to be celebrated."
"I don't consider that is something to be celebrated. [I'd] probably question how effective is our process if we're not getting one within a year," she said.
Her warning comes weeks after a Monash University-led report found grievance and remediation disclosure in the modern slavery statements of Australia's biggest listed companies remains underdeveloped – and as the federal government weighs a criminal offence for large companies that fail to prevent modern slavery in their supply chains.
The report, Grievance Mechanisms and Remediation, released by the Monash Centre for Financial Studies, assessed the FY2024 modern slavery statements of the 39 largest Financials and Materials companies in the Australian Securities Exchange (ASX) 100.
Grievance mechanisms are the channels through which workers, communities and other stakeholders report actual or suspected harm, such as exploitation or unsafe conditions. Remediation is the action taken to put that harm right and stop it recurring.
Measured against the researchers' new 40-question 8R Framework, companies disclosed information on an average of 14.28 questions, or about 36 per cent. Only five companies scored 20 or more, while nine scored below 10. Materials companies averaged 17 points, against 11 for Financials.
The gaps were sharpest after a complaint is made. Only 10 per cent of companies disclosed consulting affected stakeholders when designing their mechanisms, 5 per cent disclosed remediation outcomes, and none reported the average or median time taken to complete remediation. The authors stress the study measures disclosure, not whether the underlying practices exist.
"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," said lead author Associate Professor Nga Pham of Monash Business School in Melbourne, as covered in our earlier report on the Monash University modern slavery disclosure findings.
The report backs Richards' point. It states that zero complaints is not the objective of a grievance mechanism and may instead reflect limited awareness, barriers to access or a lack of trust.
Why a failure to prevent offence raises the stakes
Under the Modern Slavery Act 2018 (Cth), entities with annual consolidated revenue of at least $100 million must report on modern slavery risks in their operations and supply chains. On 16 July 2026, the federal government announced plans for a criminal offence for failing to prevent modern slavery, applying to corporations above that threshold, with a defence for those that took reasonable steps.
The Attorney-General's Department consulted from 21 August to 25 September 2026 on the offence's scope and defence, a possible Deferred Prosecution Agreement (DPA) scheme – under which prosecution can be suspended if a company meets agreed conditions – and avenues for victims and survivors to pursue civil remedies.
The department said the reforms aim to lift corporate accountability, better protect workers vulnerable to exploitation and level the playing field for businesses already acting on modern slavery risks. It intends to publish submissions on its consultation hub.
In New South Wales, the NSW Parliament's Modern Slavery Committee reported in August 2026 on risks faced by temporary migrant workers in rural and regional areas, making 31 recommendations.
Richards said the legislation had moved the dial, but enforcement had not kept pace.
"I know the Modern Slavery Act in Australia has gone a long way towards that. But interestingly, it's still paper, and I don't think there's enough enforcement still in Australia in this space," she said.
She was concerned about "the ability for a lot of companies to still do this exploitation whilst they're still demonstrating compliance to the Modern Slavery Act." Her view that the risk sits close to home is consistent with Australian Institute of Criminology data on hidden exploitation in Australian workplaces.
Where HR fits in grievance and labour hire risk
Richards, who held the modern slavery portfolio during her time at Sydney Airport, said complaints from contractors' workers can fall between the cracks.
"When you've got the whistleblower program coming through from the supply chain, it's quite easy for HR to push that to the side because it's not a direct worker," she said.
"Quite often these external workers, they don't have the confidence to talk to within their company. They don't have the grievance processes within the company."
At the airport, she said, "we had suppliers talking to us versus talking to their own direct grievance lines. And that told us a story."
She flagged temporary and casual staff as particularly exposed. "I think temporary and casual workers don't feel they have the same voice as a full-time employee," she said. Appetite for anonymous reporting is also rising, with anonymous tip-offs to the Fair Work Ombudsman hitting a record high in 2025–26.
What should HR leaders do about modern slavery risk?
Richards urged HR to work with procurement to map which suppliers engage labour and whether they subcontract it further. Many contracts carry modern slavery clauses that are rarely tested, she said.
"How often do they enforce them? How often do they oversee them? How often do they conduct due diligence on them? How often do they sit down with those recruitment companies or labour hire companies and actually say, show me evidence of? How often do we test timesheets?"
She also cautioned against squeezing labour hire contracts without weighing the consequences. "It's not just about the risk that the supplier brings to you. It's about the risk you're forcing on that supplier through your sourcing activities."
Grievance systems, she added, need external scrutiny. "Don't just test it internally, test it through an external independent party to see how effective it is."
On that measure, the Monash report found just 23 per cent of companies disclosed involving independent third parties in reviewing their grievance mechanisms.
Help is available for anyone experiencing or at risk of modern slavery. In an emergency call Triple Zero (000). The Australian Federal Police can be reached on 131 237, the Salvation Army's Additional Referral Pathway on 1800 000 277, and Anti-Slavery Australia on (02) 9514 8115. Free interpreters are available through the Translating and Interpreting Service on 131 450.
