Principal Statute: Act No. 153 of 2018 (Cth) as amended
Tool #2 • Quality & Gap Detection

Modern Slavery Statement Quality Audit

Audit draft statements against the 7 mandatory criteria in Section 16 of the Act before submitting to the Board of Directors or Attorney-General's Register.

100% Client-Side Privacy: Your draft statement is processed entirely within your local browser sandbox. No legal draft or supply chain text is uploaded to remote servers.
Zero Data Retention
78 / 100

Substantive with 2 Material Gaps

Meets standard for entity identity and structure, but requires remediation for consultation and effectiveness metrics before Board sign-off.

4 Compliant 2 Partial Gaps 1 Omission
1

Identify Reporting Entity

Section 16(1)(a) — Identity of the reporting entity
✓ Pass

Identifies Australasia Holdings Pty Ltd and establishes Australian corporate jurisdiction.

2

Describe Structure, Operations & Supply Chains

Section 16(1)(b) — Structure, operations and supply chains
✓ Pass

Logistics and facilities management activities in Australia and NZ are explicitly articulated.

3

Modern Slavery Risks in Operations & Supply Chains

Section 16(1)(c) — Risks of modern slavery practices
⚠ Partial Gap

Identifies security contractor sector risk, but omits geographic and product tier risk assessments.

Recommended Remediation for Board Compliance:
Distinguish between risks the entity may cause, contribute to, or be directly linked to. Incorporate supply chain depth analysis beyond Tier 1.
Suggested text: "We identified secondary risks directly linked to equipment components sourced through offshore distribution intermediaries."
4

Actions Taken to Assess & Address Risks (Due Diligence)

Section 16(1)(d) — Due diligence & remediation mechanisms
✓ Pass

Includes Supplier Code of Conduct, screening surveys, and whistleblower reporting provisions.

5

Effectiveness Assessment of Actions

Section 16(1)(e) — Assessing effectiveness of responses
⚠ Partial Gap

Text notes quarterly reviews by Legal Counsel, but fails to provide qualitative or quantitative KPIs measuring efficacy.

Mandatory Action Required:
Statutory guidance requires concrete indicators (e.g. audit resolution rates, employee training completion %, or independent grievance tracking).
6

Consultation with Controlled Entities

Section 16(1)(f) — Inter-entity consultation within corporate group
✕ Missing

No mention of consultation mechanisms between Australasia Holdings Pty Ltd and its operating subsidiaries or overseas branches.

Non-Compliance Warning:
Statements covering corporate groups are liable to statutory rejection if consultation with subsidiary entities is omitted.
7

Any Other Relevant Information

Section 16(1)(g) — Incident disclosures & forward roadmaps
✓ Pass

General governance and ESG context is sufficiently referenced.

Audit Summary Ready for Governance Committee

Export executive memo or copy the precise Section 16 gap remediation wording.