Modern Slavery Programs are Creating Work. Not Enough of Them are Creating Control

Modern slavery obligations have driven significant investment across procurement functions over the past few years. Most organisations are doing more than they were. Fewer are seeing proportionate improvement in how supplier risk is actually managed. This post looks at why that gap exists and what practically makes a difference.

A lot of effort is going into modern slavery in procurement right now. Very little of it is changing outcomes.

Organisations are investing significant time in supplier questionnaires, risk ratings, and reporting frameworks without materially changing how supplier risk is managed. The volume of data collected often exceeds the value of insight gained. It becomes a compliance exercise that creates work but not control.

The issue is not intent. It is where the focus goes. If modern slavery risk is not connected to how suppliers are actually selected and managed, it stays theoretical.

These are four practical shifts that will actually make a difference.

Focus on where the risk really sits. Not every supplier carries the same exposure. Labour-intensive services, complex subcontracting, and offshore supply chains tend to carry higher risk. Start there. This means segmenting your supplier base by risk profile before designing your program, not after. A cleaning contractor with a large casual workforce warrants far more attention than a software vendor.

Go deeper on a smaller group of suppliers. Spreading effort across hundreds of suppliers creates activity, not insight. Fewer suppliers means better conversations and clearer visibility. A deep dive conversation with ten high-risk suppliers will tell you more about your actual exposure than a questionnaire sent to two hundred.

Link it to the contract and governance model. If expectations are not reflected in contractual obligations and followed up through supplier governance, they will not hold. Review your standard contract terms. If modern slavery expectations are not written in as obligations with consequence, they are aspirations not requirements.

Involve operations. This is where most programs fall down. Procurement can design the framework but operations see what is actually happening on the ground. Get them engaged from the beginning and listen to their feedback. Operations teams often have direct visibility of supplier practices that procurement never sees. A site manager who has concerns about a contractor's labour practices is your most valuable source of intelligence. Build a clear and simple channel for that feedback.

None of this requires a large ESG program or significant additional cost. It requires focus and follow-through. That is where modern slavery moves from something you report on, to something you actively manage.

Debbie Hack is the founder and Principal Procurement Advisor at QBE Consulting. She has contributed to the Property Council of Australia's Modern Slavery Working Group and holds Supply Nation accreditation.