Big ASX financial and materials firms disclose little about what follows a modern slavery complaint
Monash University researchers found 39 large ASX financial and materials firms addressed about 36% of 40 questions on modern slavery grievances and remedies. The thinnest answers cover remedies, the record a firm may need if a proposed criminal offence makes reasonable steps its defence.
The Scientist · Science desk

What happened
- Just 10% disclosed evidence of consulting affected stakeholders or their representatives when designing their grievance mechanisms.
- No company in the sample disclosed the average or median time it took to complete remediation.
- The report lands as the federal government has consulted on a criminal offence for companies that fail to prevent modern slavery in their operations and supply chains.
Why it matters
- Who's exposed exposure Firms that publish nothing on remediation outcomes would have to build any reasonable-steps defence from records outside their public statements, if those records exist.
- What it limits constraint A low 8R score cannot tell a regulator or investor whether a company's channel fails workers or simply goes undescribed, so the score alone cannot rank actual practice.
- What it sets up precedent If regulators build reasonable-steps guidance on the 8R questions, as Pham proposes, 34 of these 39 firms would start out having addressed fewer than half of the items.
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The sample has 39 companies, so the small percentages are small counts. Five per cent of 39 is about two firms, and 10% is about four [20][21]. That puts roughly two companies in the group that disclosed remediation outcomes or the share of cases resolved to complainants' satisfaction [7][20]. About two disclosed a full range of potential remedies, and about two said they asked complainants whether the remedy was adequate [6][20].
Most firms sit in the middle of the scale. Take out the five companies that addressed at least half of the questions and the nine that addressed fewer than 10, and 25 are left in the band between 10 and 19 [22].
The weak spots match the pattern described by Nga Pham, the lead author and an associate professor at the Monash Centre for Financial Studies [19]. "Our findings suggest that companies are much more comfortable reporting on their policies, committees and complaint channels than explaining what happens after a concern is raised," she said [12]. Her test for a working channel asks more than a statement usually shows. "A grievance mechanism should be more than a hotline or a policy on paper. It must be safe and trusted by workers, warn companies early of harm and provide a pathway to remedy," Pham said [13].
The scale itself is new. The 8R Framework is the authors' own 40-question instrument for grading how openly a company describes the design and operation of its grievance channels and whether its remedies work [2]. Here it has been applied to one year of statements, FY2024, from two sectors [1]. Because the framework is new, there is no earlier score on the same questions to show whether disclosure is improving [2].
The larger limit is one the researchers state themselves. The report grades public disclosure in modern slavery statements, and they caution that it does not necessarily represent companies' underlying practices or information available through other channels [11]. A firm could run a channel workers trust and describe it badly. Another could describe a channel well that nobody uses.
That gap between disclosure and practice matters for the proposed law. Under the federal government's proposed reforms, showing that reasonable steps were taken to prevent modern slavery could become critical to a company's defence [10]. I'd expect that to raise the value of records about what happened after complaints, which is the part these statements report least [6][7]. Whether firms hold such records privately, the report cannot say [11].
Pham proposes the questions as a basis for official guidance. "The 8R Framework could support government and regulators in developing clearer guidance about the systems, processes and evidence relevant to reasonable steps," she said [15]. Esty Marcu, director of responsible business and human rights at the University of Sydney, said many organisations have found it challenging to set up effective grievance mechanisms [16]. "This framework has been incredibly valuable because it not only provides a clear set of principles to guide good practice, but also enables organizations to self-assess their maturity and identify opportunities for improvement," Marcu said [17].
The workers these channels exist for are why the after-complaint record counts. "Workers, especially migrant, temporary and low-skilled workers, are vulnerable due to limited knowledge of their rights, language barriers and fear of retaliation," Pham said [14]. Co-author Matthew Coghlan, a business and human rights lawyer, said effective mechanisms should be designed with affected people and should respond safely and promptly to concerns, according to Human Resources Director [18].
What to watch
- Whether the government legislates the proposed criminal offence after consultation, and how it defines reasonable steps.
- Whether regulators' guidance on reasonable steps draws on the 8R Framework's 40 questions.
- A scoring of FY2025 statements on the same questions, which would give the first measure of whether disclosure is improving.
Clarity's read
What the record supports and how the coverage leans. The claims behind it follow.
Reality
- Evidence60
- Adoption
- Not scored
- Hype gap+5
- Incentives40
- Confidence62
Claim ledger
Ranked by verification strength, evidence, and original report placement.
- [1]
The Monash University-led report Grievance Mechanisms and Remediation assessed the FY2024 modern slavery statements of the 39 largest ASX100 financials and materials companies.
- [2]
The report introduces a new 40-question 8R Framework to assess how transparently companies disclose information about the design and operation of modern slavery grievance mechanisms and whether their remediation processes are effective.
- [3]
On average, companies addressed 14.28 of the 40 questions in the 8R Framework, about 36%.
- [4]
Only five companies addressed at least half of the questions, while nine addressed fewer than 10.
- [5]
Only 10% of companies disclosed evidence of consulting affected stakeholders or their representatives when designing grievance mechanisms.
- [6]
Just 5% disclosed a full range of potential remedies, and only 5% reported consulting complainants about whether the remedy provided was adequate.
- [7]
Only 5% disclosed remediation outcomes or the proportion of cases resolved to complainants' satisfaction.
- [8]
No company disclosed the average or median time taken to complete remediation.
- [9]
The federal government consulted on strengthening Australia's modern slavery laws, including a proposed criminal offence for companies that fail to prevent modern slavery in their operations and supply chains.
- [10]
Under the federal government's proposed modern slavery reforms, demonstrating that reasonable steps were taken to prevent modern slavery could become critical to a company's defence.
- [11]
The researchers caution that the report assesses the quality of public disclosure via companies' modern slavery statements and does not necessarily represent companies' underlying practices or information available through other channels.
- [12]
"Our findings suggest that companies are much more comfortable reporting on their policies, committees and complaint channels than explaining what happens after a concern is raised."
- [13]
"A grievance mechanism should be more than a hotline or a policy on paper. It must be safe and trusted by workers, warn companies early of harm and provide a pathway to remedy."
- [14]
"Workers, especially migrant, temporary and low-skilled workers, are vulnerable due to limited knowledge of their rights, language barriers and fear of retaliation."
- [15]
"The 8R Framework could support government and regulators in developing clearer guidance about the systems, processes and evidence relevant to reasonable steps."
- [16]
Esty Marcu, director of responsible business and human rights at The University of Sydney, said many organisations have found it challenging to establish effective grievance mechanisms.
- [17]
"This framework has been incredibly valuable because it not only provides a clear set of principles to guide good practice, but also enables organizations to self-assess their maturity and identify opportunities for improvement."
- [18]
Co-author Matthew Coghlan, a business and human rights lawyer, said effective mechanisms should be designed with affected people, respond safely and promptly to concerns, provide appropriate remedies and draw on lessons from grievances to prevent repeat harm.
- [19]
Lead author Nga Pham is an associate professor at the Monash Centre for Financial Studies at Monash Business School.
- [20]
5% of the 39 companies is about two companies.
- [21]
10% of the 39 companies is about four companies.
- [22]
25 companies addressed between 10 and 19 of the 40 questions.
- [23]
34 of the 39 companies addressed fewer than half of the 40 questions.
Sources
2 independent publishers whose own reporting we read for this story.
- hcamag.comModern slavery reporting: Are Australia's largest firms falling short? | Human Resources Director
1 article · October 5, 2026
- phys.orgNew report reveals gaps in corporate modern slavery disclosures
1 article · October 6, 2026
Topics and entities
Topics
- Grievance mechanisms and remediation
- Modern slavery reporting
- Business and human rights
Entities
- Monash University
- Monash Centre for Financial Studies
- University of Sydney