Modern Slavery in cleaning supply chains

Cleaning has been recognised as a key risk area for modern slavery in Australia by the Department of Home Affairs. Withholding of wages, immigration-related coercion and threats, deceptive recruitment, excessive overtime, debt bondage, confiscation of personal and travel documents, and dangerous and substandard working conditions are all practices that are found in the cleaning industry in Australia.

The term ‘modern slavery’ is only used to describe serious exploitation and exists at the extreme end of the worker exploitation continuum. Modern slavery does not include practices like substandard working conditions or underpayment of workers but these practices are also illegal and harmful and when left unchecked, these practices may also escalate into modern slavery.

CAF’s approach to addressing modern slavery is founded on the promotion of ‘decent work’ which is one of the UN’s Sustainable Development Goals. The infographic below situates decent work on the continuum of exploitation that encompasses modern slavery and dangerous or substandard working conditions.

CAF ExploitationContinuum FA WebStrip

Adapted from the Department of Home Affairs (2019) Commonwealth Modern Slavery Act 2018 Guidance for Reporting Entities.

How does CAF address Modern Slavery risk in supply chains?

CAF has been recognised as a leading anti-slavery in supply chains initiative by business and human rights and corporate social responsibility experts. CAF Membership and certification is at the cutting edge of human rights due diligence to address modern slavery risk

By becoming a CAF Member, organisations are contributing to ending systemic exploitation and preventing modern slavery in the cleaning industry. Members also benefit from exclusive access to a range of CAF-developed tools and resources that will assist in the implementation of responsible business practices.

The process of CAF certification addresses modern slavery risk by working with entities at the top of the supply chain because procurers of cleaning services have significant power to determine the working conditions of cleaners, despite not being in an employment relationship with them. CAF’s assessment of labour standards at a building or precinct is centered on identifying dangerous or substandard working conditions and implementing best practice employment practices and supply chain conduct, therefore identifying indicators of modern slavery that may require investigation and remediation. 

CAF takes a more holistic approach than standard auditing methods. We combine social audits, meaningful worker engagement, and education and training for the whole supply chain. Our model is based on worker-driven social responsibility (WSR) which is a relatively new concept but one that is fast gaining traction globally as a best-practice supply chain management approach. Engaging workers is critical to managing modern slavery risk in your supply chain as they are your eyes and ears on the ground.

CAF certification takes a preventative approach to modern slavery: ensuring that workers are receiving fair pay, are working safely, and have the ability to speak up helps prevent slavery-like practices from occurring. The entire cleaning supply chain benefits from fair and transparent pricing, quality cleaning and employment practices that eliminate the risk of exploitation and unfair competition. Furthermore, the lower the risk of modern slavery and exploitation in your supply chain, the lower the risk of reputational, legal and financial damage as a result of any regulatory or industrial action. 

Modern Slavery Act Reporting 

Australia’s Modern Slavery Act requires that reporting entities respond to a set of mandatory criteria. Organisations that are involved with CAF either through Membership or certification can use this to respond to the mandatory criteria. 

The Commonwealth’s Modern Slavery Act 2018 – Guidance for Reporting Entities recommends collaborating with civil society organisations and multi-stakeholder initiatives that are focused on addressing modern slavery risk as a means to strengthen your response. CAF offers our Members comprehensive support and guidance on how to include their involvement with CAF in their Modern Slavery Statements.

Case Studies used in Members’ Modern Slavery Statements