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1 January 2019 marked the commencement of Australia’s landmark Modern Slavery Act 2018 (Modern Slavery Act), reflecting a renewed commitment in Australia to address the exploitation of people in the supply chains of the goods and services that we purchase. The Australian Government is a committed leader in the fight against modern slavery. The Australian Border Force (ABF) is leading the Government’s efforts and has committed to working in close collaboration with the Cleaning Accountability Framework (CAF) and their multi-stakeholder base to address modern slavery risks present in the property services industry.

Modern slavery, exploitation and procurement practices

Modern slavery is an umbrella term that refers to a range of exploitative practices, including human trafficking, servitude forced labour and the worst forms of child labour. It describes situations where coercion, threats or deception are used to exploit victims and undermine or deprive them of their liberty. Promoting decent work and protecting vulnerable workers from dangerous or substandard working conditions is an essential step to eradicating modern slavery. 

WhereDoesModernSlaveryFit 02Source: Department of Home Affairs (2019) Commonwealth Modern Slavery Act 2018 Guidance for Reporting Entities.

Cleaning services are a high-risk sector for modern slavery, including in Australia. Examples of modern slavery practices occurring within the cleaning sector include the withholding of wages, immigration-related coercion and threats, deceptive recruitment, debt bondage, confiscation of personal and travel documents, and dangerous and substandard working conditions. Many of these practices originate at the point of procurement, with low levels of due diligence with regard to contracting practices and poor oversight of contractor compliance. 

Procurers of cleaning services have a responsibility to protect cleaners in their supply chains from human rights violations. One of the first steps any entity can take is to review their procurement practices to see how they can use purchasing power and contract management to encourage responsible employment practices throughout the supply chain.

CAF is an anti-slavery mechanism

CAF is an independent multi-stakeholder body that aims to improve working conditions for cleaners through a supply chain accountability mechanism – CAF Building Certification. CAF works with supply chain stakeholders at a building to identify, investigate and remedy labour rights violations and implement the conditions for decent work within that supply chain. 

As part of the assessment of working conditions against the CAF 3 Star Standard, CAF’s assessment includes a process to diagnose the presence of slavery-like practices through worker engagement. A CAF Star rating is awarded when the conditions for decent work are implemented.

Critical to the success of the CAF Building Certification scheme is the involvement of cleaners. Cleaners are the eyes and ears on the ground and a workforce that feels able and empowered to speak up is the best defence against exploitation and modern slavery.

The Australian Government

Under the Modern Slavery Act the Government is required to prepare an annual Modern Slavery Statement (Commonwealth Statement). The Commonwealth Statement will explain how the Government is assessing and addressing modern slavery risks in its procurement and investment activities. The first Commonwealth Statement will cover the 2019/20 financial year and will be published by 31 December 2020.

The Government is committed to taking a best practice approach to complying with its obligations under the Modern Slavery Act. On 1 June 2020, the ABF released a public scoping paper which outlines the content that will be included in the Government’s first Commonwealth Statement. The scoping paper provides an overview of key high-risk areas the Government has identified across Commonwealth procurement and investments, highlighting cleaning as one of these high-risk areas.

What will the ABF and CAF achieve?

The Government is a significant procurer of cleaning services, spending almost $3 million on cleaning services for domestic office accommodation and shop fronts during the 2018-19 financial year. This brings significant leverage to drive improved standards across the industry. The ABF and CAF are working together to strengthen the Government’s approach to identifying and addressing modern slavery risks in the Commonwealth’s cleaning procurements.

4 National Circuit Canberra LR 1In April 2019, base building cleaning for 4 National Circuit, Barton – an ISPT-owned building tenanted by the Department of Home Affairs – was certified by CAF. This means the supply chain has been independently verified as free from slavery and exploitation, and measures have been implemented to ensure this continues beyond formal audits. The ABF is continuing to promote CAF Certification across Government.

Government action to assess and address modern slavery risks in the cleaning sector will promote positive change across the industry and ensure that workers providing cleaning services in government buildings are not subject to modern slavery. With this commitment to action, the Government will continue working with CAF to explore options, including building certification, to effectively leverage the Government’s purchasing power to drive improved standards across the cleaning services industry.

Cleaning Accountability Framework Ltd.