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Conclusion: With both the NSW and commonwealth parliaments passing respective Modern Slavery Acts in 20181, there are now real implications and consequences for business leaders and their suppliers who ignore the risks of slavery within their supply chains.

Unlike the California Transparency in Supply Chains Act 2010 which applies to tangible goods offered for sale, Australian firms will need to disclose their efforts to eradicate slavery and human trafficking from their supply chain of both goods and services. This means at least 2,100 public and private firms2 have until 1 July 2019 to ask explicitly of suppliers, whether local or foreign, off-premise Cloud or on-premise device manufacturer: What are you and your organisation doing with respect to modern slavery risks?

For many organisations in Australia this will mean more than just adding new evaluation criteria to be applied to current and potential suppliers. Rather it requires providing an accurate attestation on the issue of modern slavery which will require lifting the hood on all manner of “as-a-Service” offerings. Thereby exposing aspects of service delivery that the majority of firms previously thought they no longer needed to concern themselves with, having “transferred” risks, such as those found in supply chains, to their vendor partners.

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