“Modern slavery” can sound like something far removed from day-to-day operations in a small Australian business. But if you buy products (even simple items like uniforms, electronics, packaging or cleaning supplies), use labour hire, engage overseas contractors, or work with suppliers who do, there’s a real chance some part of your supply chain could be exposed to modern slavery risks.
Using a modern slavery policy template is a practical way to document what your business stands for, what you expect from suppliers and partners, and how you’ll identify and respond to risks. Even if you’re not legally required to publish a Modern Slavery Statement under the Modern Slavery Act 2018 (Cth), having a policy can still be a smart move for customer trust, tender requirements, investor expectations and overall risk management.
Below, we’ll walk you through how to create a modern slavery policy template tailored to an Australian small business, including what to include, how to implement it, and common mistakes to avoid.
What Is A Modern Slavery Policy (And What Does It Actually Do)?
A modern slavery policy is a written document that sets out your business’s commitment to preventing and addressing modern slavery risks across your operations and supply chain.
It usually explains:
- what “modern slavery” means (in plain English);
- your business’s expectations for ethical labour and sourcing;
- how you identify risk areas (like certain products, regions, or labour arrangements);
- what due diligence steps you take (supplier screening, contract clauses, checks or reviews, training);
- how staff and suppliers can raise concerns safely;
- how you respond if issues are found.
For small businesses, the policy’s value is often in building a consistent process. If a customer asks you to confirm your supply chain is ethically managed, a clear policy helps you respond with confidence. If you’re bidding for government or corporate work, you’ll often be asked about modern slavery risk management, even if you’re not a “reporting entity”.
Think of the policy as your foundation. It doesn’t replace practical actions, and having one doesn’t automatically mean you comply with all legal or contractual requirements - but it does show you have a system in place and understand your responsibilities.
Do You Need A Modern Slavery Policy Template If You’re A Small Business?
In Australia, the Modern Slavery Act 2018 (Cth) requires certain larger organisations to publish a Modern Slavery Statement each year (generally, entities with consolidated revenue of at least $100 million).
Most small businesses won’t meet this threshold. However, you may still need a modern slavery policy in practice because:
- Your customers may require it: larger clients often “flow down” their compliance expectations to suppliers.
- You may be tendering: procurement processes commonly ask for modern slavery risk management evidence.
- You want to manage reputational and operational risk: modern slavery issues can cause major disruption, even for smaller operators.
- You’re growing: putting the right framework in place early is easier than scrambling later.
Also, “small business” doesn’t always mean “low risk.” Some common risk areas for Australian SMEs include:
- importing goods (apparel, promotional merchandise, electronics, building products);
- using labour hire, subcontractors, or seasonal labour;
- engaging overseas contractors or offshore manufacturing;
- operating in industries with complex subcontracting chains (construction, cleaning, hospitality, security).
If you’re creating a modern slavery policy template because a client asked for it, it’s worth making sure it reflects what your business actually does. A policy that looks good but doesn’t match reality can create its own risks.
What To Include In A Modern Slavery Policy Template (A Practical Outline)
A modern slavery policy template should be easy to read, tailored to your operations, and clear about who is responsible for what. Below is a practical structure you can adapt.
1. Purpose And Commitment
Start with a short statement of what the policy is for and your business’s commitment to ethical sourcing and human rights.
- Why the policy exists (e.g. to prevent, identify and address modern slavery risks).
- A clear commitment to lawful and ethical operations.
- A note that the policy applies to your people and your supply chain.
2. Scope (Who And What The Policy Covers)
Be specific about what parts of your business are covered, for example:
- employees, contractors and labour hire;
- direct suppliers and key subcontractors;
- procurement and purchasing decisions;
- any overseas operations or offshore suppliers (if relevant).
If you operate through a company structure (or multiple entities), it can help to be clear which entity the policy applies to, and who “owns” it internally. In some cases, your governance documents (like a Company Constitution) may influence how policies are approved and who has authority to implement them.
3. Definitions (Plain English)
Include a short “definitions” section so your team understands what you mean. Keep it practical.
- Modern slavery: can include forced labour, debt bondage, human trafficking, slavery-like practices, and the worst forms of child labour.
- Supply chain: the suppliers, subcontractors and labour arrangements involved in delivering your products/services.
- Due diligence: steps you take to identify, prevent and reduce risk.
4. Roles And Responsibilities
This is where small businesses can keep things simple and workable. For example:
- Business owner/director: approves the policy, ensures resources are available, reviews incidents and actions.
- Operations/procurement lead: screens suppliers, maintains records, reviews higher-risk suppliers.
- Managers/supervisors: ensure labour practices are compliant and concerns are escalated.
- All staff: complete training and report concerns.
If you have co-founders or multiple decision-makers, it can be useful to align on who is accountable for procurement and compliance. In some businesses, a Shareholders Agreement can help clarify decision-making responsibilities at a high level, which can make policy ownership clearer in practice.
5. Risk Assessment (How You Identify Higher-Risk Areas)
Your policy should explain how you assess modern slavery risk. This doesn’t need to be complicated, but it should be real.
Common risk indicators include:
- country risk: sourcing from regions with weak labour enforcement or known forced labour concerns;
- sector risk: industries with vulnerable workforces (e.g. textiles, agriculture, cleaning, construction);
- product/service risk: goods made with high labour intensity and low margins (often linked to exploitation);
- workforce risk: use of labour hire, short-term visa workers, subcontracting chains;
- business model risk: aggressive timelines and pricing pressures that may encourage unethical subcontracting.
A good approach for small businesses is to categorise suppliers as low/medium/high risk and apply different checks depending on the category.
6. Due Diligence Steps (What You’ll Actually Do)
This is often the most important part of a modern slavery policy template. It should set out practical actions such as:
- Supplier onboarding checks: collect basic information about labour practices, locations, and subcontracting.
- Contractual protections: include clauses requiring compliance with applicable labour laws and allowing termination if serious breaches occur.
- Ongoing monitoring: periodic reviews, spot checks, or supplier questionnaires (as appropriate for your business and level of risk).
- Training: educate staff who purchase goods/services or manage contractors.
- Record keeping: keep a paper trail of steps taken (important for tenders and accountability).
If you buy goods from suppliers or manufacturers, your contracts matter. For example, using a properly drafted Supply Agreement can help you set expectations around sourcing, subcontracting and compliance (and document what happens if those expectations aren’t met).
7. Reporting Concerns And Grievance Mechanisms
Your policy should make it clear how people can raise concerns and that your business will take them seriously, without fear of retaliation. While anonymous reporting isn’t always practical for every small business setup, you can still offer confidential reporting and limit access to reports on a need-to-know basis.
Even for a small business, you can include reporting channels such as:
- a dedicated email address monitored by the owner/director;
- a nominated manager contact;
- a third-party reporting tool (optional);
- an option to raise concerns verbally and have them documented.
If your business already uses a whistleblowing framework (or is considering one), aligning your modern slavery reporting pathway with a Whistleblower Policy can help create a consistent and safer reporting process.
This part is often overlooked, but it matters. Your policy should explain what you’ll do if a risk is identified or an incident occurs.
Your response steps might include:
- assessing immediate safety risks and taking urgent action where needed;
- pausing the relationship with a supplier while investigating;
- working with the supplier on corrective action (where appropriate);
- ending contracts if issues are serious or not remediated;
- reviewing your own purchasing practices to reduce pressure that could contribute to exploitation.
Be careful not to promise things you can’t deliver. It’s better to commit to a clear, staged process than to guarantee outcomes that depend on third parties.
9. Training And Awareness
Training doesn’t have to mean long courses. For many small businesses, it can start with:
- a short onboarding briefing for relevant staff;
- a once-a-year refresher;
- practical guidance for procurement (what to look for, when to escalate).
Make it clear who must complete training (e.g. anyone involved in hiring, procurement, or supplier management).
10. Review And Continuous Improvement
Set a realistic review cycle (e.g. annually, or when there’s a material change to suppliers, locations, or your business model). Include:
- who reviews the policy;
- how changes are approved;
- how you track whether the policy is working (even simple KPIs like “supplier checks completed” or “training completion rates”).
How To Put Your Modern Slavery Policy Into Practice (So It’s Not Just A PDF)
A modern slavery policy template is only useful if it’s implemented in a way that fits your business. The goal is to build repeatable habits, not create extra admin for no benefit.
Step 1: Map Your “Real” Supply Chain (At Least The Key Parts)
You don’t need to map every supplier immediately. Start with:
- your top suppliers by spend;
- suppliers in higher-risk categories (imports, labour hire, subcontracting);
- suppliers critical to delivering customer work.
Document what they supply, where they operate, and whether they subcontract.
Step 2: Update Your Procurement Process
Even small businesses can build a simple procurement checklist, such as:
- Do we know where this supplier sources labour/materials?
- Are there any red flags (cash-in-hand labour, no written contracts, unclear subcontracting)?
- Do we have the right terms in place?
If you provide services (rather than products) and engage contractors or subcontractors, you may also want your client and contractor documentation to clearly reflect expectations and responsibilities. In many setups, a tailored Service Agreement can help set boundaries around how work is delivered and who is responsible for labour and compliance.
Step 3: Add A Contract “Hook” For Compliance
Your policy should be supported by your contracts. This often means including clauses about:
- compliance with laws (including labour laws);
- not engaging forced labour or exploitative practices;
- notification obligations if issues arise;
- rights to request information or conduct checks (scaled to your size);
- termination rights for serious breaches.
This is a practical way to move from “we care about this” to “this is part of how we do business.”
Step 4: Create A Safe Internal Reporting Pathway
Make it easy for your team to raise concerns. If you collect personal information while handling reports (names, contact details, allegations), you should also think about how you manage privacy and sensitive information.
In many cases, it’s sensible to ensure your Privacy Policy and internal handling practices align with how you collect and store report-related information (especially if reports come in via online forms or email).
Step 5: Keep Records (Because Evidence Matters)
Small businesses often do a lot of good work informally, but struggle to show it later when a customer asks questions.
Practical records to keep include:
- supplier questionnaires and onboarding notes;
- copies of contracts and key compliance clauses;
- training attendance notes;
- any incidents reported and actions taken;
- annual policy review notes.
This makes responding to client due diligence requests much easier.
Common Mistakes With A Modern Slavery Policy Template (And How To Avoid Them)
It’s normal to want to move quickly, especially if a customer or tender requires a modern slavery policy. But a rushed policy can create problems later.
Mistake 1: Copy-Pasting A Policy That Doesn’t Match Your Business
Generic templates can be a starting point, but your final policy should reflect your actual supply chain and processes. If your policy says you “audit suppliers annually” but you don’t (and realistically can’t), that’s a risk.
A better approach is to start small, describe what you do now, and include a plan for improvement.
Mistake 2: Over-Promising
A policy isn’t a guarantee that modern slavery will never occur in your supply chain. Avoid absolute statements like “we ensure there is no modern slavery in any part of our supply chain.”
Instead, commit to reasonable steps: assessing, monitoring, responding, and improving.
Mistake 3: Treating It As “Procurement Only”
Modern slavery risk can show up in hiring, subcontracting, labour hire, and contractor arrangements too. Your policy should connect across your business functions, including HR and operations.
If you have staff, it’s also helpful to ensure employment documentation and workplace processes are consistent with ethical labour practices. Having clear Employment Contract documentation can support lawful, transparent arrangements and reduce confusion about working conditions and expectations.
Mistake 4: No Clear Reporting Pathway
If someone sees something concerning, they need to know what to do next. A policy that tells staff to “report concerns” but gives no channel (or no commitment to non-retaliation) isn’t very effective.
Mistake 5: Not Reviewing The Policy When Your Business Changes
Small businesses change quickly: new suppliers, new markets, new products, new subcontractors. If your operations change, your risk profile changes too.
Build in an annual review, and also update the policy when you:
- start importing goods;
- begin using labour hire or subcontracting at scale;
- move into higher-risk regions or industries;
- take on a major enterprise client with stricter requirements.
Key Takeaways
- A modern slavery policy template helps you document your ethical sourcing commitments and build a clear, repeatable process for identifying and responding to risk.
- Even if you’re not required to report under the Modern Slavery Act, you may still need a policy to meet customer, tender, or investor expectations.
- A practical policy should cover scope, responsibilities, risk assessment, due diligence steps, reporting pathways, response actions, training, and review.
- Your policy should match what your business actually does today, and include realistic commitments you can implement.
- Supplier contracts and onboarding processes are often the most effective “real world” tools for managing modern slavery risk.
- Keeping records of checks, training, and actions taken makes it much easier to respond to due diligence requests and show progress over time.
If you’d like help tailoring a modern slavery policy for your business (and making sure it aligns with your contracts and internal processes), contact Sprintlaw on 1800 730 617 or email team@sprintlaw.com.au for a free, no-obligations chat.
