Beyond Audits:
Worker Voice Whitepaper
WHITEPAPER
Modern slavery law is changing.
Is your supply-chain assurance keeping up?
New Australian criminal penalties, expanding whistleblower protections and US forced-labour tariffs are turning trusted worker reporting from good practice into a governance expectation. This whitepaper explains why and how to build a Worker Voice Program that holds up under scrutiny.
$100M+
Annual revenue threshold for Australia's new criminal offence for failing to prevent modern slavery
60
Economies (including Australia) hit by US Section 301 forced-labour tariffs from 23 July 2026
Part 9.4AAA
Corporations Act whistleblower protections that already extend to supplier and labour-hire workers
The risks were always there. What's changed is who's watching.
Wage theft, debt bondage, document confiscation, coerced labour and kickbacks rarely show up in a supplier questionnaire. They surface through the people experiencing them — if those people have a safe, trusted way to speak up.
Periodic audits remain useful, but they're a snapshot. They can be undermined by coached interviews, falsified records and workforce conditions that shift the week after the auditor leaves. Meanwhile, the ground is moving fast: a new Australian criminal offence for large companies, UN Guiding Principles expectations on grievance mechanisms, evolving obligations in the UK and New Zealand, APRA's CPS 230 service-provider requirements, and US trade tariffs that now tie forced-labour enforcement directly to market access.
Beyond Audits sets out why a trusted Worker Voice Program, not another audit, is becoming the control that regulators, boards and trading partners expect to see.
What's Inside?
- The hidden, people-dependent risks that audits routinely miss — and the warning signs to watch for
- What a genuine Worker Voice Program is (and why it's more than a hotline)
- How Worker Voice complements — and differs from — traditional whistleblowing
- Why Australian whistleblower protections under Part 9.4AAA of the Corporations Act may already extend to workers in your supply chain
- A regulator-by-regulator view: Australia's Modern Slavery Act, the UK's Section 54, New Zealand's proposed Bill, APRA CPS 230 and US Section 301 tariffs
- A nine-point framework for building or benchmarking an effective program, from access channels to remedy and governance reporting
- The governance and performance measures boards should actually be tracking — beyond report volume
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