Strengthening modern slavery reporting across multiple jurisdictions
Human Rights & Modern Slavery | read time: 3 min
Evolving modern slavery legislation across jurisdictions is making compliance increasingly complex for multinational organisations. Rather than dealing with a single set of requirements, companies must navigate overlapping frameworks that may differ in scope and expectations, while avoiding duplication or inconsistency in their disclosures.
In this context, a global luxury group engaged GoodCorporation to strengthen its modern slavery reporting for the 2020 reporting year. The aim was to bring together the requirements of the Australian Modern Slavery Act, the UK Modern Slavery Act and the California Transparency in Supply Chains Act within a single, unified statement.
The engagement built on previous work undertaken by GoodCorporation to assess the company’s human rights governance and supply chain management against the UN Guiding Principles on Business and Human Rights, OECD Due Diligence Guidance for Responsible Supply Chains in the Garment and Footwear Sector, and peer practices. This provided an in-depth understanding of the company’s existing policies and procedures, enabling a more informed review of its modern slavery disclosure. This meant the review could be targeted and efficient, building directly on an in-depth understanding of their systems.
Our approach
GoodCorporation began a comparative analysis of the three legislations and related guidance in-scope. We then conducted a structured desk-based review, examining the company’s existing disclosures alongside the requirements of each applicable legislation. This was complemented by benchmarking against statements from ten peer organisations, selected from both the luxury sector and beyond. Given its level of regulatory development, the Australian Modern Slavery Act repository served as a key reference point throughout the analysis.
The findings were brought together to highlight where the company’s statement could be strengthened. In particular, the review identified opportunities to clarify how risks are identified and managed, and to strengthen the level of detail provided on monitoring and effectiveness.
The second phase focused on revising the company’s existing modern slavery statement. This involved close engagement with the client to refine both structure and content.
Rather than drafting a new statement, the work concentrated on enhancing the existing disclosure within the available timeframe and in line with the company’s reporting timeline. This approach ensured continuity while allowing improvements to be embedded efficiently. The revised draft was then submitted to the company for review and finalisation, together with guidance on submission to the Australian Modern Slavery Statements Register.
Results
The approach enables us to produce a single modern slavery statement that brought together the requirements of three legislative frameworks in a clear and consistent way. By consolidating reporting in this manner, the company was able to reduce duplication and streamline its overall approach to reporting across jurisdictions.
The project also helped provide a clear view of how existing disclosures compared with both regulatory requirements and peer practices. This enabled the identification of targeted improvements, supporting stronger alignment with expectations while ensuring that reporting remained grounded in documented internal processes assessed by GoodCorporation as part of the previous gap analysis of their approach to managing human rights risks in the supply chain.
Why this matters
For multinational organisations, modern slavery reporting often requires navigating multiple regulatory frameworks that may overlap without being fully aligned. Without a coordinated approach, this complexity can lead to fragmented disclosures that are challenging to maintain over time.
This project demonstrates how an evidence-based methodology can help address this challenge. By combining legislative analysis, peer benchmarking, and a detailed assessment of internal practices, the engagement supported the development of a disclosure that reflects both evolving regulatory expectations and the realities of the company’s operations. It also underscored the importance of ensuring that external reporting is underpinned by effective governance and documented processes, so that statements are supported by tangible evidence rather than commitments alone.
How GoodCorporation can help
GoodCorporation supports organisations in meeting modern slavery reporting requirements in single as well as across multiple jurisdictions. We help clients benchmark disclosures, assess alignment with legislation and good practice, and strengthen reporting through structured review and evidence-based recommendations. To find out more, visit our human rights and modern slavery webpage or get in touch with a member of the team.
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