Modern Slavery Statement Template: Step-by-Step Guide For Australian SMEs & Startups

Many Australian founders and small business owners are surprised to learn that “modern slavery compliance” isn’t only an issue for huge multinational brands. If you sell products, import goods, use contractors, or rely on suppliers (even indirectly), modern slavery risks can exist somewhere in your operations or supply chain.

That’s why more SMEs and startups look for a modern slavery statement template for Australia – not only to meet legal requirements (where they apply), but also to respond to customer expectations, procurement questionnaires, and investor due diligence.

In this guide, we’ll walk you through what a modern slavery statement is, when you need one, and how to draft a clear, practical statement that reflects your business reality (without drowning in legal jargon). We’ll also share a simple template structure you can adapt, plus a checklist to keep you on track.

What Is A Modern Slavery Statement (And Why Do SMEs Care)?

A modern slavery statement is a public report that explains what your business is doing to identify, assess, and address risks of modern slavery in its operations and supply chains.

“Modern slavery” can include serious exploitation such as forced labour, human trafficking, debt bondage and other practices where people are not free to leave work or are being controlled or coerced.

Even if you’re a smaller business, a modern slavery statement can matter because:

• Bigger customers may require it as part of onboarding you as a supplier.
• Investors and partners may expect it during due diligence (especially if you’re scaling fast).
• It helps protect your brand by showing you take supply chain ethics seriously.
• It supports better risk management (including contractual risk allocation and supplier governance).

For many startups, it becomes part of “good corporate hygiene” in the same way that having proper customer terms, a Privacy Policy, and basic governance documents becomes more important as you grow.

Do You Legally Need A Modern Slavery Statement In Australia?

Under the Modern Slavery Act 2018 (Cth), certain entities must prepare and give a modern slavery statement to the Australian Government for inclusion on the public Modern Slavery Statements Register each reporting year.

In broad terms, you may be required to report if you:

• Are an Australian entity or carry on business in Australia; and
• Have an annual consolidated revenue of at least $100 million (AUD).

If you are required to report, there are some technical requirements to be aware of. For example, a statement must:

• Address the mandatory reporting criteria set out in the Act;
• Be approved by your principal governing body (for many companies, this is the board);
• Be signed by a responsible member (for example, a director); and
• Be submitted within the required timeframe (commonly within 6 months after the end of the relevant reporting period) for publication on the Commonwealth register.

Most SMEs and startups won’t hit the $100m threshold. However, there are two common scenarios where smaller businesses still prepare statements:

1) You’re Not Required To Report, But You’re Asked To

If you’re supplying to government, enterprise customers, or large corporates, you may be asked to provide modern slavery information (or a statement) as part of procurement. In practice, many SMEs create a voluntary modern slavery statement so they can respond quickly and consistently.

2) You Want A Scalable ESG Baseline Early

If you plan to scale quickly (or raise capital), having a simple, honest statement early can make future compliance easier. It can also help you bake supplier due diligence into your processes from day one.

Keep in mind: even if you’re not legally required to prepare a statement, whatever you publish should still be accurate and not misleading. This is where good internal processes and clear drafting matter.

Modern Slavery Statement Template Australia: A Practical Template Structure

If you’ve been searching for a modern slavery statement template in Australia, what you usually need is a structure that aligns with the Australian reporting criteria (where relevant) and still makes sense for a smaller business.

Below is a practical template structure you can adapt. You don’t need to copy it word-for-word. Treat it as a checklist for what to include and how to organise it.

Section A: About Your Business (Entity, Structure, Operations)

Explain who you are in plain English. Include:

• Your legal entity name (and any trading names).
• Your business structure and group structure (if applicable).
• What you do (products/services) and where you operate.
• Who your customers are (high-level).

Example wording: “We are an Australian [company/partnership/sole trader] providing [goods/services] to customers in [locations]. We work with suppliers in [Australia/overseas] for [manufacturing/logistics/software/contracting].”

If you operate through a company, make sure your governance documents support your reporting and decision-making processes (for example, a properly adopted Company Constitution can help clarify director powers and internal approvals as you scale).

Section B: Your Supply Chain Overview

You don’t need to list every supplier publicly, but you should describe your supply chain in a meaningful way. For instance:

• Key categories of suppliers (manufacturers, logistics, raw materials, packaging, labour hire, tech vendors).
• Which countries you source from (especially if sourcing overseas).
• Whether you use agents, distributors, or intermediaries.

Tip: If you’re early-stage and your supply chain is still evolving, say that. Stakeholders generally prefer honesty over overconfident statements.

Section C: Modern Slavery Risks You’ve Identified (Or Are Most Likely)

This is the section where many businesses get stuck, because it feels like you’re “admitting” risk. But a modern slavery statement is not about claiming you have zero risk. It’s about showing you understand where risks can exist and what you’re doing about them.

Common risk areas (depending on your business model) can include:

• Manufacturing and production (especially if you source from higher-risk regions or industries).
• Cleaning, hospitality, warehousing, and labour hire supply chains.
• Seasonal or low-wage labour and contractor-heavy models.
• Complex or multi-tier supply chains where you don’t directly contract with the source.
• Rapid scaling where procurement moves faster than compliance processes.

Example wording: “We recognise modern slavery risks may arise in parts of our supply chain such as [category] and [category], particularly where work is performed by subcontractors or suppliers outside Australia.”

Section D: Actions You’re Taking (Policies, Due Diligence, Contracts)

This is where you explain what you’re actually doing. For SMEs, “action” can be practical and lightweight while still meaningful, such as:

• Supplier onboarding checks (even a basic questionnaire).
• Contractual clauses requiring suppliers to comply with laws and ethical standards.
• Supplier code of conduct (or expectations set out in purchase orders).
• Training for staff who engage suppliers (even informal training or documented guidance).
• Incident reporting channels and escalation steps.

From a legal risk perspective, modern slavery measures often tie into your broader contract management and procurement controls. If you’re updating supplier terms or customer-facing terms more generally, it can help to take a “whole system” approach rather than treating modern slavery as a standalone document.

Section E: How You Assess Effectiveness

Australian modern slavery reporting expects you to consider how effective your actions are. For SMEs, effectiveness measures can be simple:

• How many suppliers were screened or asked questions this year.
• Whether any red flags were found and how they were handled.
• Whether supplier contracts now include modern slavery clauses.
• Whether you reviewed high-risk supplier categories.

Example wording: “We assess the effectiveness of our actions by tracking supplier onboarding checks, monitoring reported concerns, and reviewing our approach annually as our supply chain evolves.”

Section F: Consultation And Approvals (If You’re Part Of A Group)

If you’re in a group structure (for example, a holding company and operating company setup), you may need to explain consultation across entities and who approved the statement.

Smaller groups often overlook this governance step. If there are multiple owners involved, it’s also worth aligning your approach with your ownership arrangements (for example, decision-making processes in a Shareholders Agreement can help avoid disputes about who signs off on public statements and ESG commitments).

Step-By-Step: How To Draft Your Modern Slavery Statement As An SME Or Startup

Here’s a step-by-step process you can follow to turn the template structure into a statement you can confidently publish or share with customers.

Step 1: Confirm Whether You’re Reporting Voluntarily Or Because You Must

Start with clarity on the “why”:

• If you’re legally required, you should ensure you meet the mandatory reporting criteria, approval/signature requirements, and lodgement timeframes.
• If you’re doing it voluntarily, you’ll usually still want to align with Australian expectations so it’s credible to procurement teams.

This also affects how detailed your statement needs to be.

Step 2: Map Your Supply Chain (At Least At A High Level)

You don’t need a perfect map. You do need enough visibility to identify where risk might reasonably occur.

Create a simple spreadsheet with:

• Supplier name and what they provide
• Country (or countries) of operation
• Whether they subcontract
• How critical they are to your operations
• Any known risk indicators (industry, region, labour intensity)

If you’re very early stage, start with your “top 10” suppliers and expand as you grow.

Step 3: Identify Your Risk Areas (Don’t Overcomplicate It)

Risk identification is not about guessing. It’s about reasonable assessment.

Ask:

• Which suppliers involve labour-intensive work?
• Which suppliers operate in regions with weaker labour protections?
• Where do we have low visibility (multiple layers of subcontracting)?
• Are there price pressures that could encourage unethical practices?

Write down your risk assessment in plain language. This becomes the backbone of your statement.

Step 4: Decide What Actions Are Proportionate For Your Business Right Now

SMEs sometimes copy what large corporates do and end up with policies that don’t match their actual operations. A better approach is to commit to measures you can realistically implement.

Examples of proportionate actions include:

• Adding modern slavery clauses to supplier agreements or purchase orders.
• Asking new suppliers a short set of questions about labour practices.
• Creating an internal escalation process if red flags are identified.
• Training your operations/procurement team on what to look for.

If you’re also hiring staff or contractors, remember that good internal compliance habits tend to be connected. For example, clear documentation and expectations in an Employment Contract helps you build a stronger compliance culture generally (which supports modern slavery governance too).

Step 5: Draft The Statement Using A Clear, Scannable Format

A modern slavery statement should be easy for a customer, investor, or partner to skim. Use headings, short paragraphs, and bullet points. Avoid vague promises like “we have zero tolerance” without explaining what you do in practice.

If you’re looking for a simple drafting rule: describe what you do, not what you wish you did.

Step 6: Get Internal Sign-Off And Keep Records

Even if you’re issuing a voluntary statement, treat it like a formal document:

• Decide who is responsible for it (founder, operations lead, CFO, general counsel).
• Document approvals (board or director resolution if applicable).
• Keep evidence files (supplier questionnaires, contract clauses, training notes).

This matters if you later need to show how you reached your conclusions, or if a customer audits your processes.

What Else Should SMEs Put In Place Alongside A Modern Slavery Statement?

A modern slavery statement often sits within a broader compliance and risk framework. You don’t need to build an “enterprise-level” system overnight, but it helps to think about the legal foundations that support your statement.

Depending on your business model, you may also need:

• Supplier/customer terms that allocate risk and set expectations (particularly if you sell B2B).
• Employment documentation so your internal labour practices align with what you expect of suppliers.
• Privacy compliance if you collect personal information as part of supplier onboarding or reporting (a Privacy Policy can be a key baseline document).
• Clear contracting processes so procurement doesn’t become a “handshake deal” as you scale.

And if your business is growing quickly and bringing on new owners, investors, or entities, the way you document decision-making can directly impact public reporting (including modern slavery statements). Putting good governance in place early can save a lot of time later.

Key Takeaways

• A modern slavery statement explains how your business identifies and addresses modern slavery risks in its operations and supply chain.
• Most SMEs and startups aren’t legally required to report, but many still prepare a statement due to procurement requirements, investor expectations, or future-proofing.
• A practical modern slavery statement template for Australia usually includes: business overview, supply chain description, risk areas, actions taken, effectiveness measures, and approvals/consultation (if relevant).
• If you are required to report, you also need to meet the Act’s mandatory criteria and governance requirements (approval/signature) and lodge the statement for publication on the Modern Slavery Statements Register within the required timeframe.
• The best statements are clear, honest, and proportionate to your business size and supply chain complexity.
• Supporting documents and processes (contracts, onboarding checks, governance and privacy compliance) make your modern slavery commitments more credible and easier to maintain as you scale.

Important: This article is general information only and isn’t legal advice. If you’d like help preparing or reviewing a modern slavery statement (whether voluntary or mandatory), or tightening up supplier and governance documents to support it, you can reach Sprintlaw at 1800 730 617 or team@sprintlaw.com.au for a free, no-obligations chat.