AICD submission on the Anti-Slavery Commissioner's Strategic Plan 2025-2028

Wednesday, 16 April 2025

On 11 April 2025 the AICD lodged a submission on the development of the Anti-Slavery Commissioner’s Strategic Plan (the Strategic Plan), as required by the Modern Slavery Act 2018 (the Act).


The AICD has been a strong and consistent supporter of the establishment of an independent Anti-Slavery Commissioner. We consider that the Commissioner is uniquely positioned to play a pivotal leadership role in driving improved compliance with the Act by supporting reporting entities meet their reporting obligations through a range of initiatives.

The AICD considers that the priorities for the Commissioner in the Strategic Plan should include the following:

  • Development of codes of practice and certification measures for suppliers to reduce duplicative supplier due diligence and verification processes within sectors, and to provide greater certainty and assurance for entities regarding supply chain compliance.
  • Publishing an annual list of high risk regions, locations industries, products, suppliers or supply chains to serve as a reference point for entities in undertaking due diligence activities.
  • Developing practical guidance for high-risk sectors, NFPs, Aboriginal and Torres Strait Islander organisations and small and medium enterprises (SMEs), including by promoting best practice and drawing on successful domestic and international examples.
  • Conducting thematic or sectoral assessments of modern slavery statements to provide real-word insights into current practices and highlight areas of due diligence and reporting that require improvement.
  • Facilitate stronger collaboration and engagement between industry, government, and civil society to address the geopolitical and systemic barriers that inhibit robust supply chain due diligence.

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