Executive summary

This report examines the information disclosed regarding grievance mechanisms and remediation in the FY2024 modern slavery statements of 39 large ASX100 financials and materials companies. It introduces the 8R Framework, a 40-question rubric anchored in the effectiveness criteria of the United Nations Guiding Principles on Business and Human Rights (UNGPs). The assessment is strictly disclosure-based, evaluating what companies report rather than verifying underlying practices. Key findings indicate that disclosure remains limited across the sample, with an average score of 14.28 out of 40, or 36 per cent. Materials companies disclosed substantially more than financials companies, averaging 17 points compared with 11 points. The strongest area in both sectors is respect, while the weakest areas are remedy and relationships.

Introduction

Large companies face heightened expectations to manage social risks across their operations and global supply chains. Maintaining a social licence to operate requires identifying, managing, and remediating human rights violations and modern slavery practices in a transparent manner. Businesses must establish channels through which potentially affected stakeholders can raise concerns. Grievance mechanisms function as early warning systems and pathways to remedy. Under Australia’s Modern Slavery Act (MSA), effective grievance mechanisms are key actions for reporting entities. This research aims to develop a structured framework grounded in international standards to understand current disclosure practices.

What is a grievance mechanism?

A grievance is a complaint or expression of dissatisfaction raised by individuals or groups about a real or perceived impact of a company’s operations. The UNGPs define a grievance mechanism as any routinised, State-based or non-State-based, judicial or non-judicial process through which concerns regarding business-related human rights abuse can be raised and remedy sought. These mechanisms should be accessible to direct employees, contractors, supply chain workers, and community members. In the context of modern slavery, they provide a structured channel to report actual or suspected harms and seek redress rather than relying solely on third-party audits.

Existing guidance and literature

The 8R Framework is founded on international standards including the UNGPs, the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, and ILO manuals. While there is a range of normative guidance, significant gaps persist between principles and practice. Few non-State-based mechanisms fulfill their role due to limited accessibility and a lack of adequate remedies. Existing industry benchmarks often treat grievance mechanisms as secondary issues rather than the primary focus. Furthermore, there is currently no clear government regulation to monitor and enforce the effectiveness of corporate grievance mechanisms handling human rights claims.

Framework development

The project team developed the 8R Framework as a structured tool to guide companies and investors in evaluating effective disclosure. It integrates core principles derived from international standards, such as legitimacy and transparency, into eight interrelated pillars: Representation, Respect, Relationship, Receiving grievances, Response, Remedy, Review, and Reporting. These pillars represent a baseline set of good practices for designing, implementing, and reporting on grievance mechanisms. The framework was refined through consultations with responsible investment practitioners and civil society organisations to incorporate rights-holder perspectives.

The UNGPs’ effectiveness criteria

The study assesses whether statements disclose information regarding the UNGP 31 effectiveness criteria. These criteria specify that non-judicial grievance mechanisms must be legitimate, accessible, predictable, equitable, transparent, rights-compatible, a source of continuous learning, and based on engagement and dialogue. Each question in the 8R Framework maps to at least one of these criteria, ensuring that the reported features are consistent with international expectations for meaningful stakeholder engagement and remediation.

The 8R Framework for grievance mechanism and remediation

The 8R Framework comprises three overarching foundational pillars—Representation, Respect, and Relationships—and five lifecycle pillars: Receipt, Response, Remedy, Review, and Reporting. Representation emphasises stakeholder engagement in design, while Respect underscores the necessity for equitable and accessible processes. Relationships address how mechanisms interact with external remedy ecosystems. The lifecycle pillars track the intake of grievances, case handling, substantive outcomes, continuous learning through analysis, and transparent external communication about processes and results.

8R pillars and questions

Forty scoring questions sit beneath the eight pillars, guided by UNGP 31 and guidance from bodies like the World Bank and IFC. Representation includes questions on normative grounding and stakeholder consultation. Respect examines confidentiality, anti-retaliation protections, and trauma-informed principles. Relationships focus on referral protocols to authorities and supplier requirements. The lifecycle pillars address proactive communication, multiple reporting channels, support for complainants, published timeframes, the range of available remedies, and formal reporting processes to the board.

Data and methodology

This descriptive content analysis focused on the disclosure of grievance mechanisms in the FY2024 modern slavery statements of 39 ASX100 companies, comprising 20 financials and 19 materials firms. Only information contained within the statements was scored. Sector comparisons are descriptive, contrasting a services sector with a physically intensive sector with concentrated supply chain risks. Each statement was assessed against the 8R Framework, where a ‘YES’ received one point for explicit evidence. The study acknowledges limitations, such as binary scoring and a single reporting period, which may understate practices well-developed but briefly referenced.

Findings

Overall, information provided in modern slavery statements remains limited, with an average score of 14.28 out of 40 points. Only five companies provided information on at least 20 questions, while nine scored below 10. The distribution shows substantial variation, from a high of 33 to a low of 2 out of 40. Eight of the top 10 companies are in the materials sector, whereas eight of the lowest 10 are financials firms. Most companies exhibit underdeveloped disclosure regarding specific mechanism design, the complainant journey, and outcomes achieved.

Sectoral analysis

Materials companies noticeably disclose more information than financials firms, averaging 17 versus 11 questions. Materials sector statements are more likely to discuss grievance mechanisms in connection with operational settings, workers, and suppliers. In contrast, the financials sector often relies on high-level ethics or whistleblowing disclosures, which may provide less insight into whether complainants can access dialogue or support. Respect is the strongest pillar for both sectors, indicating that many companies mention scope, confidentiality, and anti-retaliation protections.

Findings by pillar

Disclosure is uneven across the framework. Under Representation, only 10 per cent of the sample provided evidence of consulting affected stakeholders during the design process. Under Respect, 100 per cent of materials firms mentioned that their mechanisms cover human rights, compared with 85 per cent of financials. The Relationships pillar is weak across both sectors, with very few companies describing collaborative mechanisms or cooperation with external bodies like the OECD. While companies perform well on basic features under Receipt, fewer describe supporting complainants so they can participate in a fair and informed way.

What the sector gap means in practice

The gap points to different implementation challenges driven by sector-specific operations. Materials companies have tangible, high-risk multi-tier global supply chains, making grievance mechanisms more operational. They also benefit from existing sector-specific guidance. Financials companies are linked to risks through lending and investment rather than direct site operations. Many use existing whistleblowing mechanisms designed for misconduct reporting, which often lack details on consultation with targeted users or links to external remediation mechanisms.

Case study

The University of Sydney (USYD) applied the 8R Framework for an internal review. While its modern slavery statement reflected only part of its practice, scoring 23 out of 40, its internal assessment identified 34 ‘YES’ responses. This illustrates that organisations may have more mature internal arrangements than are visible through public disclosure. Benchmarking against the framework highlighted areas for improvement, including multilingual accessibility and tracking the time taken to complete remedied grievances. The framework served as both a practical management tool and a disclosure tool.

Implications and recommendations

This report suggests that clearer disclosure expectations and regulatory guidance are needed for modern slavery statements to serve as meaningful accountability mechanisms. For government and regulators, the 8R Framework offers a consistent reference point for developing guidance under the Modern Slavery Act. The proposed reform of introducing a “failure to prevent modern slavery” offence increases the relevance of the framework, as companies may need to demonstrate they have taken reasonable steps to prevent exploitation. For investors and civil society, the framework helps distinguish between high-level statements and credible pillar-level evidence.