Beyond compliance in the renewable energy sector: Assessing UK and Australian Modern Slavery Act statements
This report assesses the statements of 60 renewable energy companies under the UK and Australian Modern Slavery Acts, identifying their compliance gaps. Though most firms disclose their modern slavery policy, few extend it beyond tier one, limiting worker protection. The report calls for improved guidance, supply chain transparency, and stronger government enforcement measures.
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OVERVIEW
The report recommends developing better supply chain transparency, improving reporting under the Acts, and encouraging greater participation in industry and non-industry initiatives. Governments should significantly enhance their monitoring, review, guidance, and enforcement of reporting entities under current legislation while developing financial penalties, debarment from government procurement, and injunctive relief for non-compliance.
Key findings
- Reporting obligations: The study reveals that a significant number of firms are failing to fulfil their reporting obligations without facing severe consequences. Only 37% (UK) and 32% (Australia) of firms reviewed meet the minimum requirements for the enacted legislation, while 3 of 63 required companies were unable to produce a statement.
- Renewable vs mixed energy firms: The assessment showed that firms dealing exclusively in renewable energy performed considerably worse than mixed energy firms across several key indicators. For instance, renewable firms provided less detail on their supply chains, failed to identify modern slavery risks, and, in some cases, included no information on these risks.
- Supply chain transparency: A lack of transparency in the supply chains of renewable energy companies is a significant issue. Companies must map their supply chains carefully to identify risks and disclose these in their MSA statements. Firms need to disclose specific incidents of modern slavery and steps taken to resolve these incidents, with a focus on worker remediation.
Recommendations
The authors present several recommendations, including the development of enhanced reporting and compliance standards for renewable energy firms, along with the implementation of stronger government enforcement measures. These obligatory compliance measures include improved guidance, monitoring, review, and financial penalties, debarment from government procurement, and injunctive relief for non-compliance. Firms must map out their supply chains to identify the risks of modern slavery and work towards improving reporting standards. Additionally, the report suggests that the Australian Government should lower the monetary threshold of MSA reporting to match those of the UK and New Zealand. The UK Government should establish mandatory reporting requirements, and reform the MSA announced in 2020.
