Modern slavery risk mitigation for suppliers

Suppliers play a vital role in reducing the risk of modern slavery in Victorian public health supply chains. We encourage suppliers to take a proactive approach to identifying risks and to drive meaningful change.

Suppliers on HSV collective agreements are required to:

comply with mandatory minimum standards (for procurement activities commencing from 1 July 2024)
if applicable, meet requirements under the Modern Slavery Act 2018.

Suppliers are also required to comply with the Victorian Government’s Buying for Victoria Supplier Code of Conduct and to follow the Fair Jobs Code for suppliers and businesses.

Mandatory minimum standards for HSV suppliers

Minimum standards now apply to suppliers to help reduce modern slavery risks in procurement activities linked to HSV collective agreements starting from 1 July 2024.

The standards are designed to reduce modern slavery risks in the goods and services supply chains that support Victoria’s public health services, build supplier awareness and encourage action to identify and address risks.

We’ll work with suppliers to help them put these standards into practice across their operations and supply chains. We’ll also carry out annual risk assessments to monitor progress and track improvements over time.

Over time, suppliers are expected to strengthen their approach and improve how they manage modern slavery risk.

The standards form part of HSV’s Modern Slavery Risk Mitigation Program.

Standards, examples and resources

The size of a supplier business will determine how each standard should be applied within the business. Small to medium businesses are not expected to show the same depth of compliance as large organisations. We have included examples of how this might work in your organisation under each of the standards set out below.

Standard 1 – Modern slavery policy

Suppliers must have a written policy that shows a commitment to addressing modern slavery risks faced by their business. The policy should be:

communicated to key stakeholders
embedded throughout the organisation
integrated formally into contracts where appropriate
incorporated into internal organisational training
approved at the highest organisational level and any breaches should be reported transparently.

Example: small to medium supplier

Supplier A is a small supplier of pharmaceutical products. Supplier A does not have a standalone modern slavery policy. To meet standard 1, it has implmented a modern slavery policy that is proportionate to the size of the business. Supplier A takes relevant steps to ensure it meets the commitments laid out in it's policy.

Example: large supplier

Supplier B is a large, global pharmaceutical company. Supplier B has a comprehensive modern slavery policy integral to its corporate social responsibility charter. The policy was approved by the company board and has been communicated to key stakeholders including Supplier B’s employees, suppliers and contractors. The policy is regularly reviewed and forms part of Supplier B’s governance practices.

Template

Use the following template as a guide when preparing your organisation's modern slavery policy.

Download the template here: HSV Modern Slavery Policy template.

Standard 2 – Due diligence

Suppliers must take actions to identify, prevent, and reduce modern slavery risks in their supply chains. Actions can include:

having a supplier code of conduct
incorporating modern slavery clauses into contracts with third party providers
pre-screening potential suppliers for their risks
undertaking regular supplier risk assessments, including safeguarding against workers paying recruitment fees for their employment
demonstrating real commitment to supply chains free of modern slavery.

Example: small to medium supplier

Supplier A is a small, Australian supplier of medical equipment. Supplier A requires all new employees to provide official documentation that establishes their right to work in Australia. This process of due diligence helps ensure Supplier A is not inadvertently employing people under conditions of modern slavery.

Example: large supplier

Supplier B is a large manufacturer of medical equipment and has rigorous due diligence processes. Supplier B incorporates modern slavery clauses into new contracts and conducts pre-screening of all potential suppliers prior to engaging with them. Supplier B’s pre-screening process involves using a modern slavery risk assessment tool to assess a potential supplier’s risks and the actions it will take should any significant risks be identified.

Resources

Guidance on Reasonable Steps to Manage Modern Slavery Risks in Operations and Supply-Chains: Inherent Risk Identification Tool: A tool that assigns modern slavery risk levels to 374 product categories procured by the NSW Government. It is provided by the NSW Government Department of Communities and Justice.
Modern Slavery Benchmarking Tool: A tool that helps companies establish best practices for assessing and addressing modern slavery risks across their operations and value chain. It offers an initial performance score and a list of improvement steps, including guidance on stakeholder disclosure. It is provided by Walk Free.

Standard 3 – Grievance mechanism, response and remediation

Suppliers must have a formal process for employees and suppliers to report modern slavery concerns. This includes a process for responding to and remediating incidents of modern slavery. The grievance process should be accessible to:

employees and contractors
external parties such as suppliers or communities affected by supplier business activities.

Suppliers should also require their suppliers to have grievance processes.

Example: small to medium supplier

Supplier A is a small business that specialises in medical supplies. Supplier A has a dedicated email address for reporting grievances. Employees can report concerns and suggestions by emailing the address. The process is confidential and can be anonymous. Supplier A follows up on concerns and suggestions raised and escalates to relevant authorities when required.

Example: large supplier

Supplier B is a major metropolitan hospital. Supplier B has a robust grievance reporting and remediation process available in multiple languages that all employees, patients, and suppliers can access. The process is transparent. Affected individuals are kept safe from repercussions, updated regularly throughout the process and informed about the outcome. Supplier B’s remediation process involves providing biennial training to its employees and external stakeholders. Supplier B also has strong connections with relevant authorities.

Resources

Effective Modern Slavery Grievance Mechanisms: A Case Study Publication for Business: A report supporting Australian businesses understand, establish, and operate effective grievance mechanisms to address modern slavery in their operations and supply chains. It was prepared by the United Nations Global Compact.
Modern Slavery Response & Remedy Framework: A framework to guide companies in the energy and resources sectors to address and remediate modern slavery in line with international and Australian standards. It was designed by Walk Free.

Standard 4 – Training

To raise awareness and build capability for identifying and preventing modern slavery risks, suppliers must provide training to their employees and within their supply chain. This can include:

providing specific modern slavery risk training for employees in relevant business functions
providing general modern slavery risk training to the whole workforce
engaging with their own suppliers to increase awareness of modern slavery risks.

Example: small to medium supplier

Supplier A is a small supplier of personal protective equipment. Supplier A requires its procurement employees to complete annual modern slavery risk training. Supplier A records the training and seeks feedback from employees to identify opportunities to make improvements to the training over time.

Example: large supplier

Supplier B is a large, global pharmaceutical distributor. To raise awareness on modern slavery risks, Supplier B conducts extensive modern slavery training for all employees and contractors, and throughout their supply chain. The training is compulsory and is required to be completed biennially. Supplier B records the training and seeks feedback from those who have completed the training to identify opportunities to make improvements to the training over time. Supplier B includes information on the training in its annual statement required under the Modern Slavery Act.

Template

Use the following guide and template to record and keep track of any modern slavery training completed by your staff.

Download the template here: Modern slavery training records - guide and template for suppliers

Resources

Free online modern slavery risk mitigation training: Increase your knowledge and awareness of modern slavery.
Modern Slavery Resources: e-Learning modules from beginner to advanced levels by the Supply Chain Sustainability School include
It’s healthy to Fight Modern Slavery: A video exploring modern slavery in healthcare. It looks at the role of NSW healthcare practitioners and the actions that can be taken to mitigate modern slavery in the healthcare sector.

Standard 5 – Determining effectiveness

Suppliers must be able to describe measures they use to identify the effectiveness of the actions they take to reduce or mitigate modern slavery risks. This can include:

monitoring and reviewing the modern slavery policy and its implementation
reporting on supplier due diligence activities
tracking and reporting on employee and/or supplier training
reporting on their grievance process and how effective it is.

Example: small to medium supplier

Supplier A is a medium-sized supplier of medical items. Supplier A sets key performance indicators to support modern slavery risk reduction and mitigation. For example, they aim to provide modern slavery risk mitigation training to all employees within the first year. The following year, Supplier A broadens its training program to include the first tier of its supply chain. Supplier A demonstrates it is progressively building modern slavery risk mitigation capacity by including different parts of its business in training over the ensuing years.

Example: large supplier

Supplier B is a large multinational healthcare corporation. Supplier B sets key performance indicators including undertaking regular audits, conducting supplier risk assessments, and providing employee training. Supplier B benchmarks its practices against applicable industry standards and includes this information in its annual statement required under the Modern Slavery Act. To assess the effectiveness of its modern slavery policy, Supplier B measures its performance against its key performance indicators and industry standards.

Resources

Addressing Modern Slavery in Long and Complex Supply Chains: A research paper examining how organisations understand and implement effective governance strategies to address modern slavery in long and complex supply chains. It was led by the University of Oxford Policy & Evidence Centre. It
2023 Corporate Human Rights Benchmark: A report evaluating the top 2,000 globally influential companies (SDG2000) on their performance in respecting human rights. The benchmark findings offer valuable insights for companies to improve human rights practices, promote leadership engagement, and explore collaborative solutions to key industry challenges. It was prepared by the World Benchmarking Alliance.

HSV risk mitigation training

We offer modern slavery risk mitigation training for suppliers.

The Modern Slavery Act

Under the Modern Slavery Act 2018, suppliers with annual revenue of at least $100 million are required to prepare an annual modern slavery statement. Businesses with revenue under $100 million can report voluntarily and are encouraged to do so.

To prepare a modern slavery statement, visit the Australian Government Attorney-General's Department modern slavery resources webpage, section 'Guidance material' for the Commonwealth Official Modern Slavery Act Guidance for Reporting Entities. The guide covers the actions to take to meet obligations under the Act.

For an overview of modern slavery, information on the Modern Slavery Act and how to prepare and submit statements, visit the modern slavery page on the Attorney-General’s Department website. For further guidance, suppliers should access the Attorney-General’s Department modern slavery resources.

Content reviewed: June 2026