What is a Modern Slavery Statement? And why it matters to your business.

A Practical Guide for Small Businesses in Interior Design, Fitout, and Furniture Supply

If you’re in the interiors industry then you’re closer to modern slavery than you think.

It’s embedded in the products you specify, hidden in the supply chains you rely on, and too often, it’s ignored.

Since the Commonwealth Modern Slavery Act 2018 came into effect in 2019, awareness of modern slavery has increased across the building and interiors sector.

Architects, designers, project managers, and clients are asking questions—not just about sustainability or price, but about ethics. And they’re turning to their suppliers—manufacturers, distributors, retailers—to find out: What are you doing to address modern slavery? And do you have a Modern Slavery Statement?

If these questions have left you unsure of where to begin, then this article is for you.

Even if you're not legally required to report under the Modern Slavery Act (Cth), many of your clients are. And increasingly, they expect their suppliers to step up – especially those providing furniture, textiles, fittings, finishes, or design services.

In this article, we’re going to explore what modern slavery is, the key points of the Commonwealth Modern Slavery Act 2018, what a modern slavery statement actually is, why it matters and some simple steps to help you get started.

What is Modern Slavery?

Before we get into the details of Modern Slavery Statements, it’s important that we get clear on what modern slavery actually is.

Modern slavery refers to situations where a person’s freedom is taken away, often through coercion, violence, deception, or abuse of power—and they are exploited for profit.

There are eight recognised forms of modern slavery:

• Trafficking – moving or harbouring people for exploitation

• Slavery – exercising power or ownership over a victim and treating people as a commodity

• Servitude – significantly restricting a person’s freedom

• Forced labour – forcing a person to work against their will

• Forced marriage – using coercion, threats or deception to force a victim into marriage

• Bonded labour – working to repay an unpayable debt

• Deceptive recruiting – where a victim is deceived about their job and conditions of employment

• Worst forms of child labour – work harmful to a child’s safety, morals and development. This includes hazardous and dangerous work.

In the interiors sector, incidents of modern slavery can be found at raw material extraction, factory production, and even labour hire.

And we can’t simply ignore it.

This is why in Australia, large companies are required to adhere to the Modern Slavery Act.

What is the Modern Slavery Act?

The Commonwealth Modern Slavery Act 2018 (Cth) requires companies in Australia with over $100 million in annual consolidated revenue to submit a modern slavery statement each year.

A Modern Slavery Statement outlines what the company has done to assess and address modern slavery risks in its business operations and supply chains.

The statement must be:

• Approved by the board (or equivalent)

• Signed by a director

• Uploaded to the government’s online Modern Slavery Register

Smaller businesses aren’t legally required to report, but they can report voluntarily.

Many are now doing so in response to client demand or industry requirements (e.g., certification schemes like GECA).

It’s important to note that The Act doesn’t require businesses to be “slavery-free.”

The goal isn’t perfection. It’s about transparency, responsibility, meaningful action and continuous improvement.

What is a Modern Slavery Statement?

Let’s clear this up:

A modern slavery statement is not the same as a policy.

A policy says: “Here’s our stance on modern slavery.”

A statement says: “Here’s what we’re actually doing about it.”

If your clients are asking for your Modern Slavery Statement, they’re expecting you to report on the seven mandatory criteria outlined in the The Act.

What are the 7 Mandatory Criteria of the Modern Slavery Act?

Modern Slavery Act Criteria	What it Means
1. Identify the entity	State your business/trading name
2. Describe your structure, operations & supply chains	Who are you, what do you sell, how and where do you source materials or services?
3. Describe risks of modern slavery	Where could modern slavery be happening in your operations or supplier chain? For example, geographical locations, products, services, sectors and worker types.
4. Describe actions taken	This is asking you to describe your due diligence process, i.e. what has your business done to identify, prevent, mitigate and account for modern slavery risks? What steps have you taken to address your risk, e.g., training, policies, supplier engagement, supplier risk assessments etc.?
5. Assess effectiveness	Monitoring and measuring the effectiveness of your actions is essential to understanding whether your policies, programs, procedures, and training are genuinely being integrated into day-to-day business operations AND having an impact. Ask yourself: Are our actions making a difference to workers in our supply chain?
6. Consult with owned entities	If you own or control other businesses, how are they contributing to your efforts to address modern slavery? You are required to consult with them to ensure they understand their responsibilities and are taking appropriate action to identify and manage modern slavery risks.
7. Other relevant info	Future goals or priorities, lessons learned, case studies

You can see very clearly that a Modern Slavery Statement is not a one line policy you pop on your website.

It’s a clear commitment to understanding and mitigating the risk of modern slavery in your supply chains.

And it’s something that clients and stakeholders are starting to expect.

Expert Tip

Even if you're not yet ready to write a full statement, just starting to map your supply chain or talking to suppliers is a huge first step.

What do clients and stakeholders expect?

Even if you’re not required to report under the mandatory reporting threshold required by The Act, you might still be getting these questions:

• “Do you have a modern slavery statement?”

• “Have you mapped your supply chain?”

• “What steps have you taken to reduce labour exploitation in your supply chain?”

These questions are showing up consistently in:

• Prequalification documents

• Supplier onboarding forms

• Government and university tenders

• Sustainability certifications (e.g., GECA)

This is because forward-thinking clients want to work with suppliers who take this seriously, even if they’re a small business.

And increasingly, those clients need you to demonstrate action so they can meet their own reporting obligations.

Why Addressing Modern Slavery Matters More Than Ever

There are an estimated 49.6 million people trapped in modern slavery around the world today.

The interiors sector is not immune. From the extraction of raw materials to the sewing of upholstery fabrics, the true cost is often carried by vulnerable workers, concealed by low prices and lengthy supply chains.

And here's where your business can make a difference.

By asking questions, setting expectations with your suppliers, and being transparent with clients, you contribute to an industry where dignity, ethics, and transparency matter.

Every conversation matters. Every improvement matters.

And that’s why it’s so important to get things started with a Modern Slavery Statement for your business.

5 Simple Steps for Getting Started with your Modern Slavery Statement

Not sure where to begin?

Start small.

Here’s 5 simple things you can do right now to start understanding the modern slavery risk in your supply chain -

1. Map your supply chain
What products and services do you procure? Where do they come from? Are they from high-risk regions, sectors etc.?

2. Talk to your suppliers
Ask what steps they are taking to address modern slavery and labour exploitation in their supply chains?

3. Document your actions
Keep a record of policies, training, supplier conversations, risks identified.

4. Consider a voluntary Modern Slavery Statement
It shows leadership and can strengthen client trust.

5. Seek support
The issue of Modern Slavery can be complex and overwhelming. But you don’t have to go it alone. I support small businesses to take meaningful, practical steps, no matter your size or starting point.

Taking action on modern slavery isn’t just about compliance.

Taking meaningful action towards ending modern slavery is about more than complying with the Modern Slavery Act.

It’s about leadership, integrity, and choosing to be part of something bigger than ourselves.

As small businesses, you may not always feel like you have the power to create change, but you do.

Every product you choose, every supplier you question, every value you stand behind, these are the building blocks of a more ethical industry.

By stepping up and taking meaningful action, you show your clients and the industry that addressing modern slavery isn’t optional, it’s essential.

Behind every fabric swatch, every piece of joinery, and every finished fit-out, there’s a supply chain—and with it, the risk of exploitation. A Modern Slavery Statement is your chance to acknowledge that risk, take responsibility, and lead with transparency.

You don’t need to have all the answers. You just need to start.

If you’d like some support with your Modern Slavery Statement, I can help.

I work with designers, architects, product & material manufacturers and retailers, helping them identify labour exploitation and modern slavery in their supply chains – and take meaningful action to address them.

If you’d like to book a review of your Modern Slavery Statement, organise some training for your organisation, or simply find out how your business can take the first step, reach out to me here.

How to take Meaningful Action against Modern Slavery in your Supply Chain

Over the last two decades, I’ve witnessed strides in environmental sustainability across the building and construction sector. A lot of emphasis on reducing carbon, addressing circular economy, biodiversity - we're seeing a real shift.

But let’s be honest: when it comes to the ‘S’ in ESG—Social—it’s still the poor cousin.

We’ve come a long way in terms of sustainability—now it’s time to put people front and centre.

Yes, the Modern Slavery Act 2018 came into force in 2019. Yes, it raised awareness.

But has it driven meaningful change? For too many, the answer is still no.

And we can’t fix what we’re not willing to face.

In this article we’ll explore how you can do a better job of tackling modern slavery and labour exploitation in your supply chain.

The uncomfortable truth? Modern slavery exists in our supply chains.

And it’s not because we’re doing nothing.

Everywhere I look, companies are trying—identifying risks, signing Codes of Conduct, filling out Supplier Self-Assessment Questionnaires, and developing Modern Slavery Statements.

But good intentions don’t always lead to meaningful outcomes.

I know this because I’ve spent over 17 years working with product manufacturers and retailers in the fit-out and construction sector.

I’ve seen where progress stalls, where gaps remain, and where action should be—but isn’t.

We need to move beyond compliance.

Tackling modern slavery in your supply chain is not just a box to tick—it’s a responsibility to act.

That means actively looking for modern slavery and labour exploitation, not passively hoping we don’t find any. Because make no mistake—it’s there.

Over the past decade, manufacturers and retailers have been overwhelmed with requests from architects, designers, governments, and builders to prove they’re addressing modern slavery. They’re asked to sign up, show up, and self-assess.

But too often, follow-through is lacking.

Commitments fade. Priorities shift. And workers—real people—remain invisible, unheard, and unprotected.

As an industry, we need small and medium businesses to take action.

Change won’t happen without them.

But they need to be empowered.

They need to be equipped with the tools and resources to act – many of which already exist – and more importantly, they need incentive to drive meaningful action.

This will come through procurement specifications that prioritise ethical practices, and by evaluating and selecting suppliers based on their commitment to understanding and addressing modern slavery and labour exploitation risks within their supply chains.

Evaluation and incentivisation are critical to shifting industry practice and embedding lasting change.

What can you do right now? Start with Meaningful Action.

It’s time for all of us—suppliers, specifiers, designers, architects, builders, procurement teams, executives, boards, building rating tools, Ecolabelling bodies and certifiers—to step up and take the challenge.

We need to dig deeper. Get uncomfortable. Be honest.

Most importantly, we need to act.

And we can do that by using the 5 Principles of Meaningful Action.

The 5 Principles of Meaningful Action to End Modern Slavery

1. Connection

Connection is about recognising that every procurement decision connects us to workers around the world.

It’s the first step in being able to take meaningful action, and it involves:

• Connecting on a heart level—this is about people’s lives.

• Reflecting on how your decisions (tight budgets, deadlines, lowest-cost options) might contribute to exploitation.

• Engaging with workers, NGOs, unions, and industry experts.

• Educating your team—not just on policy, but on purpose.

• Building real relationships with your suppliers—let them know this matters.

2. Curiosity

Curiosity is the pathway to actual change. Question everything. Demand better answers. Keep learning.

If you’re ready to get curious, you should:

• Learn where modern slavery and labour exploitation occur—understand the risks in products, sectors, materials, and regions.

• Reflect on your own business practices—how might you be linked to harm?

• Challenge simple yes or no answers. Ask suppliers how they ensure safe and fair working conditions—not just whether or not they do.

• Ask your suppliers: “Have you found modern slavery in your supply chains?”
  If they say no, ask: “What meaningful actions are you taking to understand risk?”
  No findings may indicate the need for a deeper, more rigorous approach.

• Look for more than policies—ask for evidence.

• Understand what to do when you do find modern slavery.

• Keep asking: what does real commitment look like?
  
  

3. Commitment

Commitment to taking action is about moving from awareness to impact. And then making a choice, on a regular basis, to stay the course.

Commitment looks like:

• Developing a long-term strategy grounded in the 5 Principles of meaningful action.

• Prioritising robust due diligence aligned with the UN Guiding Principles.

• Measuring real impact—not just how many people were trained, but what’s changed.

• Providing meaningful feedback to suppliers. Following up. Tracking progress.

• Keep going—even when it gets complex or uncomfortable.
  
  

4. Courage

This type of global change takes courage. You will have to face discomfort. Speak the truth, (even when its hard). Lead with heart.

Courage in taking action shows up as:

• Questioning the status quo. Are we really making an impact?

• Confronting inconsistencies—do all departments align on this?

• Advocating for more resources if you’re in sustainability or procurement roles.

• Finding the courage to have uncomfortable and sometimes confronting conversations with suppliers

• Being brave enough to say: Yes, we’ve found exploitation. And here’s what we’re doing about it.

• Taking decisive action when harm is uncovered. That’s leadership.
  
  

5. Collaboration

While everything you do has an impact, you can’t do it alone. We must work together if we want to end exploitation.

Collaboration is key. And you can help by:

• Joining or forming multi-stakeholder initiatives with NGOs, unions, industry groups, and worker organisations.

• Co-creating ethical standards that prioritise workers’ rights.

• Taking part in shared training and capacity-building.

• Encouraging supplier collaboration and support worker voice.

• Partnering with local organisations who understand conditions on the ground.

Ask yourself the hard question: Is what we’re doing making a real impact?

Whether you're a designer, builder, industry body, board member, ecolabel, or certifier—this is the time to pause and reflect:

• Are we enabling real change—or just meeting minimum requirements?

• Are we evaluating suppliers on what they do—not just what they say?

• Are building rating tools, tenders, Ecolabels and procurement processes rewarding companies that lead on this?
  
  

The truth is: people are still being exploited to build our buildings.

While we focus on carbon, circularity, and biodiversity – essential areas, no doubt —

we can’t keep overlooking the people making the products we use every day.

So, we must ask ourselves:

• How long will we accept this?

• How long will we tolerate exploitation as an inconvenient truth?

• When will real impact become our baseline—not the exception?
  
  

It’s time to draw a line.

To stop treating human rights as optional.

Because if we keep ticking boxes, nothing will ever change.

It’s time to act.

Modern slavery doesn’t end with policies. It ends with people.

And it starts with you.

Are you ready to take meaningful action?

If you’d like to know what your organisation should do next when it comes to tackling modern slavery in your supply chain, I’m here to help you do that.

Book a call with me here, and let’s explore your next step towards meaningful action.

How Modern Slavery is embedded in your supply chain: and why you should care

Labour exploitation and modern slavery remain deeply embedded in the supply chains that support the design, building, and construction industries

Modern slavery isn’t always visible, but it remains a widespread risk in almost every supply chain.

Since the introduction of the Commonwealth Modern Slavery Act 2018, awareness has grown, but awareness alone isn’t going to end modern slavery.

Tackling the complex issues around modern slavery requires more than compliance—it needs meaningful action.

Even small businesses, while not legally required to report under the Act, are being called upon by clients, specifiers, government, certification schemes to show leadership and accountability.

This isn’t just a regulatory expectation—it’s an opportunity to build trust, protect vulnerable people, and contribute to lasting change.

Understanding the risks is a critical step in building ethical, human-centered supply chains.

In this article, I’m going to show you what modern slavery and labour exploitation look like, how to identify the signs, and why addressing both in your supply chain is crucial—especially in industries like design, construction, and manufacturing. 

What is Modern Slavery?

Modern slavery occurs when a person’s freedom is taken away.

Their freedom to control their body, their freedom to refuse certain work, or their freedom to stop working.

This is often carried out through threats, violence, coercion, abuse of power, or deception.

When we think about slavery, we’re often imagining someone in chains, but modern slavery is more complex than that.

And it’s often hidden in plain sight. Every day people are tricked or forced into modern slavery situations they cannot refuse or escape.

There are eight forms of modern slavery. They are:

1. Trafficking: Harbouring or moving a victim for the purpose of exploitation.

2. Slavery: Exercising power or ownership over a victim, including treating them like a commodity.

3. Servitude: Significantly restricting a victim’s freedom, such as in domestic work.

4. Forced Labour: Compelling a victim to work against their will.

5. Forced Marriage: Coercing, threatening, or deceiving someone into marriage.

6. Bonded Labour: Lending money to a victim who cannot repay, forcing them to work under conditions they cannot control to pay off the debt. This is the most widespread form of slavery globally.

7. Deceptive Recruiting: Misleading a victim about their job or employment conditions.

8. The Worst Forms of Child Labour: Work likely to harm the health, safety, or morals of a child. This includes hazardous work such as operating dangerous machinery, handling toxic substances, carrying heavy loads, or working in extreme conditions. It can also involve excessive hours or night shifts that prevent children from attending school.

What is Labour Exploitation?

While labour exploitation isn’t classified as modern slavery, it often paves the way for more serious abuses.

Labour exploitation involves the unfair treatment of workers, where their rights, dignity, and well-being are compromised for the benefit of others. It takes many forms, including unsafe working conditions, inadequate pay, wage theft, and excessive working hours.

Common examples of labour exploitation include things like:

Wage Exploitation

• Unpaid wages or wage theft (e.g., being paid for 30 hours while working 40 hours).

• Being paid below the minimum wage.
  

Denial of Employment Entitlements

• Lack of paid leave (e.g., annual, sick, or maternity leave).

• No access to benefits like superannuation entitlements.
  

Excessive Work Hours and Overwork

• Mandatory overtime without pay.

• No rest periods or meal breaks.
  

Discrimination and Harassment

• Gender-based discrimination: Female workers being paid less than male counterparts.

• Racial or ethnic discrimination: Migrant workers assigned the most dangerous tasks, while local workers are given safer, higher-paying roles.

• Other examples include verbal abuse, bullying, or sexual harassment by supervisors or colleagues.
  

Unsafe Working Conditions

• Lack of protective equipment (PPE).

• Hazardous environments (e.g., poor ventilation, exposure to harmful chemicals).

• Absence of safety measures, leading to overwork and fatigue-related risks.

What does a world without modern slavery look like?

A world without modern slavery and labour exploitation is one where workers throughout the world are able to:

• Choose or refuse the type of work they do.

• Join a trade union and bargain collectively.

• Work in a safe and hygienic environment.

• Be provided with appropriate safety gear.

• Be paid at least the minimum wage.

• Be protected against bullying, harassment, and discrimination.
  

And the good news, is that your business has the power to be a part of the solution.

It starts with understanding where modern slavery is occurring in your supply chain.

How to know if your supply chain or industry are high-risk for modern slavery

To effectively address modern slavery, it is essential to understand which products,  materials and industries are high-risk, the worker types most vulnerable (e.g., migrant workers), and high-risk regions or countries. Some examples of high-risk products include furniture, bricks, textiles, rugs, timber, and stone.

A great starting point is the Global Slavery Index, which provides national estimates of modern slavery for 160 countries.

Labour exploitation is often overshadowed by the more extreme cases of modern slavery, yet it remains a critical issue. One that can quietly take root in industries like building, construction and manufacturing.

Ignoring labour exploitation isn’t just an oversight; it’s a missed opportunity to intervene before conditions escalate into modern slavery.

The International Labour Organization (ILO) offers an extensive range of free resources on forced labour and labour exploitation.

The ILO has also published an excellent guide on the indicators of forced labour to help identify how and where it occurs.

What your business should be doing to help end modern slavery

In Australia, the Commonwealth Modern Slavery Act 2018 established a reporting requirement for entities with an annual consolidated revenue of more than $100 million.

These entities are obligated to report on their actions to assess and address modern slavery risk in their supply chains and submit an annual Modern Slavery Statement to the Attorney-General's Department (AGD).

The problem is that reporting alone rarely creates a meaningful impact for the people most affected by modern slavery.

And your business doesn’t have to have a revenue of more than $100 million for you to join the movement to end modern slavery.

What the world needs, is for all businesses to accept the challenge of taking meaningful action.

To do this well, we need to engage with the 5 Principles of Meaningful Action:

• Connection: Recognising that the choices we make are linked to the lives of workers around the world.

• Curiosity: Asking deeper questions about where our products come from, who makes them, and under what conditions.

• Commitment: Choosing to move beyond surface-level actions by prioritising, continuous improvement and long-term impact.

• Courage: Willingness to confront uncomfortable truths and take action in the face of complexity.

• Collaboration: Working together across sectors and supply chains to raise standards and create shared solutions.

By taking a values-driven, curious, and collaborative approach, we can shift from reactive compliance to proactive impact—where people, not just products, are placed at the heart of our business decisions. 

By being informed, curious, and proactive, we can create better conditions for the workers who are all too often overlooked. Together, we can make a difference.