Australian fashion buyers have been warned to comply with ethical sourcing obligations.
A number of experts have been recruited to advise the industry on the new Modern Slavery legislation next month.
Allens law firm partner Rachel Nicolson and Ethical Sourcing Agency's David Nesbitt will address the topic at the International Sourcing Expo in Melbourne.
The Australian fashion industry will soon face two new pieces of legislation: the NSW Modern Slavery Act and the Commonwealth’s Modern Slavery Bill.
Nicolson said the two pieces of legislation will work in tandem and, while the NSW Act is already in force, the Commonwealth Bill is yet to be enacted.
“If an entity has an employee in New South Wales and has consolidated revenue at the lower threshold of AUD $50 million, then they will be subject to the NSW Act,” Nicolson said.
“This is subject to the fact that once the Bill commences, entities with consolidated revenue over $100 million will be subject to the Commonwealth regime and only entities with consolidated revenue over $50 million and under $100 million will be regulated by the NSW Act.
“The Commonwealth Bill serves the twin aims of first requiring the entity to consider its exposure to modern slavery, and then undertake steps to mitigate any risk that is exposed.
“Second, to ensure that both the investigatory and mitigation steps are published in the form of the Modern Slavery Statement.”
Under the NSW Act, a misleading statement, or failing to provide a statement, can bring penalties of up to $1.1 million.
Irrespective of the Modern Slavery legislation, Nesbitt said every Australian fashion business that sources products or services should consider implementing an ethical sourcing plan that spans the entire supply chain.
Nesbitt said an ethical sourcing plan included seven key elements:
1. Framework that charts the direction of the program
2. Sourcing Code of Conduct for Suppliers
3. Sourcing Policies
4. Modern Slavery Statement in line with upcoming Australian legislation
5. Transparency – knowing all stages of your supply chain
6. Factory Assurance (Audit) Program encompassing
a. Social compliance
b. Health and safety
c. Human rights
d. Environment
e. Worker interviews
7. Remediation program
“Ultimately, brands should implement an ethical sourcing program because they know it is the right thing to do,” Nesbitt said. “The key drivers become the brand themselves and customer pressure”.
The International Sourcing Expo will run at the Melbourne Conference & Exhibition Centre from November 20 to 22.