Modern Slavery & Ethical Sourcing: What Procurement Teams Are Asking Labour Suppliers

The Modern Slavery Act 2018 (Cth) requires reporting entities with consolidated revenue above $100 million to publish an annual statement on the modern-slavery risks in their operations and supply chains. Labour hire sits squarely in that supply chain, and procurement teams are increasingly asking suppliers detailed questions before contract award.

Where the risk really sits

Modern slavery offences in Australia are rare in the literal sense - but the risks the Act asks reporting entities to consider include debt bondage, deceptive recruiting, withholding of identity documents and excessive recruitment fees. Each of these has been documented in labour-hire supply chains, particularly through sub-contracting layers.

Questions procurement teams now ask

• Do you charge any fees to workers - directly, indirectly or through a third party?
• Do you use sub-contractors? If yes, how do you verify their compliance?
• How do you verify identity and right to work without holding original documents?
• What is your process for workers to raise concerns confidentially?
• How do you audit pay, hours and accommodation arrangements?

How RELAY Labour Hire answers

We do not charge workers fees. We do not sub-contract supply through third parties. Identity documents are scanned and returned at the point of verification. Pay and hours are reconciled against rostered shifts every week. Workers have multiple confidential channels to raise concerns, including a route directly to a senior operator that does not sit in their reporting line.

What 'good evidence' looks like

The strongest supplier responses we have seen contain three things: written policy, documented procedure and operational evidence (audit logs, completed payslip reconciliations, whistleblower records). Procurement teams should ask for all three - not just the policy document.