From Policy to Data: Why Australian Companies Are Now Mapping Their Supply Chains
For years, large Australian companies responded to modern slavery obligations by drafting policies, publishing statements, and completing questionnaires. The Australia Modern Slavery Act, enacted in 2018 and in force from January 2019, requires entities with annual revenue above AUD 100 million to publish annual modern slavery statements describing how they identify and address risks in their operations and supply chains. That disclosure-based framework created a first wave of compliance activity centered on documentation rather than deep supply chain intelligence. But that is changing. Companies that completed the paperwork phase are now recognising that policies alone do not tell them where forced labour actually exists in their supplier networks. As FRDM CEO Justin Dillon has observed, more and more Australian companies are saying they have done their policies and done everything they could on paper, and now they want to get it into data. That shift from documentation to data-driven mapping marks a significant maturation in how Australian businesses approach modern slavery risk. The stakes are also rising. Global enforcement regimes, led by the US Uyghur Forced Labor Prevention Act (UFLPA), have demonstrated that inadequate supply chain visibility can result in goods being detained at borders, creating real financial and reputational damage. As countries including Australia, the UK, Germany, Canada, and the EU adopt or tighten similar measures, Australian companies face pressure not only from domestic law but from the entire international trade compliance landscape.
Most forced labour is found at the informal, deeper tiers of supply chains — exactly where most companies have no visibility at all.
One of the most persistent and dangerous blind spots in supply chain compliance is the assumption that visibility into direct, tier-one suppliers is sufficient. In reality, forced labour and modern slavery tend to concentrate in the raw material extraction and informal sub-contracting layers that sit two, three, or more tiers removed from the buying company. FRDM's data suggests that less than six percent of companies have any visibility beyond their tier-one suppliers, and over 80 percent of supply chain data remains unstructured — meaning companies are working with incomplete and fragmented information. Australian regulators and legal experts have confirmed that the Modern Slavery Act's obligations extend beyond direct commercial relationships. Companies are expected to take reasonable steps no matter how far back in the supply chain the forced labour exists, though what is reasonable scales with a company's leverage over its business partners. This aligns with international norms, including the OECD Due Diligence Guidelines and the UN Guiding Principles on Business and Human Rights, which calibrate expectations based on the nature and depth of supplier relationships. FRDM's supply chain mapping platform addresses this by using AI-powered technology to automatically link sub-suppliers beyond a company's known network, filling in blind spots across multiple tiers without requiring supplier questionnaires. The platform can map up to eight tiers back and overlay risk signals related to forced labour, geopolitical instability, trade concerns, and regulatory exposure — giving procurement and compliance teams a far more accurate picture of where real risk lives.
Forced labour risk is now inseparable from tariff exposure, sanctions, and geopolitical concentration risk.
The compliance motivation for supply chain mapping has expanded well beyond ethical sourcing. Geopolitical tensions, particularly around China's Xinjiang region, have introduced a new layer of trade enforcement risk that directly affects Australian importers. The UFLPA in the United States creates a rebuttable presumption that any goods produced in whole or in part in Xinjiang are made with forced labour and are prohibited from import, and the burden falls on companies to prove otherwise with detailed supply chain documentation and traceability evidence. For Australian companies with US market exposure or suppliers operating in high-risk regions such as Xinjiang, Southeast Asia, or the Democratic Republic of Congo, this is not an abstract risk. CBP has detained shipments worth billions of dollars, and enforcement has spread to goods transshipped through Malaysia, Vietnam, Thailand, and other intermediary countries. Solar panels, cotton, electronics, and textiles are among the highest-scrutiny categories. The EU Forced Labour Regulation, which entered into force in late 2024 and will apply from 2027, adds further market-access consequences for companies unable to demonstrate traceability. For Australian businesses, this means that supply chain mapping is no longer purely a modern slavery compliance exercise — it is also a trade risk and market access strategy. Understanding where goods originate, which sub-suppliers are linked to sanctioned entities or high-risk geographies, and how to document those connections is now essential to protecting export revenues and import continuity.
Moving from scattered data and supplier surveys to a defensible, evidence-based, multi-tier risk intelligence system.
Effective supply chain mapping requires more than loading a supplier list into a spreadsheet. Most companies' supply chain data is fragmented across ERP systems, legacy IT platforms, and multi-language spreadsheets — a problem compounded by the fact that supplier questionnaires have low response rates and generate unverifiable answers rather than auditable evidence. Regulators across the UFLPA, EU Forced Labour Regulation, and Australia's Modern Slavery Act are increasingly looking for proof, not policies. FRDM assists major Australian organisations including ANZ Bank and Telstra in complying with the Modern Slavery Act by mapping and risk-monitoring entire supply chains, including sub-suppliers and commodities. The platform uses AI to transform basic invoice-level spend data into multi-tier supply chain intelligence without requiring direct supplier interaction, dramatically compressing the time needed to build a mapped view of risk exposure. Large Language Models have accelerated spend data cleansing by over 90 percent, meaning a company with tens of thousands of direct suppliers can achieve tier-three mapping in days rather than months. The practical output of good mapping is a defensible compliance record: defined scope by suppliers, sites, materials, and tiers; structured evidence collected once and reused across multiple regulatory frameworks; continuous risk monitoring with alerts for adverse media, sanctions changes, and geopolitical events; and documented corrective actions tied to specific suppliers. This evidence-based approach positions companies not just to meet current reporting obligations under the Australian Modern Slavery Act, but to adapt as the threshold is potentially lowered from AUD 100 million to AUD 50 million and as global enforcement continues to intensify.
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