Big ASX financial and materials firms disclose little about what follows a modern slavery complaint

The sample has 39 companies, so the small percentages are small counts. Five per cent of 39 is about two firms, and 10% is about four ^[20][21]. That puts roughly two companies in the group that disclosed remediation outcomes or the share of cases resolved to complainants' satisfaction ^[7][20]. About two disclosed a full range of potential remedies, and about two said they asked complainants whether the remedy was adequate ^[6][20].

Most firms sit in the middle of the scale. Take out the five companies that addressed at least half of the questions and the nine that addressed fewer than 10, and 25 are left in the band between 10 and 19 ^[22].

The weak spots match the pattern described by Nga Pham, the lead author and an associate professor at the Monash Centre for Financial Studies ^[19]. "Our findings suggest that companies are much more comfortable reporting on their policies, committees and complaint channels than explaining what happens after a concern is raised," she said ^[12]. Her test for a working channel asks more than a statement usually shows. "A grievance mechanism should be more than a hotline or a policy on paper. It must be safe and trusted by workers, warn companies early of harm and provide a pathway to remedy," Pham said ^[13].

The scale itself is new. The 8R Framework is the authors' own 40-question instrument for grading how openly a company describes the design and operation of its grievance channels and whether its remedies work ^[2]. Here it has been applied to one year of statements, FY2024, from two sectors ^[1]. Because the framework is new, there is no earlier score on the same questions to show whether disclosure is improving ^[2].

The larger limit is one the researchers state themselves. The report grades public disclosure in modern slavery statements, and they caution that it does not necessarily represent companies' underlying practices or information available through other channels ^[11]. A firm could run a channel workers trust and describe it badly. Another could describe a channel well that nobody uses.

That gap between disclosure and practice matters for the proposed law. Under the federal government's proposed reforms, showing that reasonable steps were taken to prevent modern slavery could become critical to a company's defence ^[10]. I'd expect that to raise the value of records about what happened after complaints, which is the part these statements report least ^[6][7]. Whether firms hold such records privately, the report cannot say ^[11].

Pham proposes the questions as a basis for official guidance. "The 8R Framework could support government and regulators in developing clearer guidance about the systems, processes and evidence relevant to reasonable steps," she said ^[15]. Esty Marcu, director of responsible business and human rights at the University of Sydney, said many organisations have found it challenging to set up effective grievance mechanisms ^[16]. "This framework has been incredibly valuable because it not only provides a clear set of principles to guide good practice, but also enables organizations to self-assess their maturity and identify opportunities for improvement," Marcu said ^[17].

The workers these channels exist for are why the after-complaint record counts. "Workers, especially migrant, temporary and low-skilled workers, are vulnerable due to limited knowledge of their rights, language barriers and fear of retaliation," Pham said ^[14]. Co-author Matthew Coghlan, a business and human rights lawyer, said effective mechanisms should be designed with affected people and should respond safely and promptly to concerns, according to Human Resources Director ^[18].