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Freedom251 › Blog › ASX

New Report Finds Gaps in Modern Slavery Disclosures by 39 ASX Companies

By Freedom251 Team · · 4 min read

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A Monash University-led assessment of FY2024 modern-slavery statements from 39 large ASX100 Financials and Materials companies found limited public evidence about how grievance mechanisms are designed and operated, and whether remediation works. Companies addressed an average of 14.28 of 40 questions in the report’s 8R Framework, according to Monash University’s 6 October 2026 announcement. The researchers caution that weak disclosure does not necessarily mean a company lacks effective practices; the assessment measures what its public statements disclosed.

What the report examined

The report, Grievance Mechanisms and Remediation, assesses FY2024 modern-slavery statements from 39 of the largest companies in the ASX100 Financials and Materials sectors. Its findings do not cover every Australian company or establish how companies in other sectors report.

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Monash describes a grievance mechanism as a channel through which workers, communities and other stakeholders can raise actual or suspected harm, unsafe or unfair working conditions, exploitation or other rights violations. Remediation means action to redress harm and prevent it from recurring.

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The report uses a 40-question 8R Framework to assess how transparently companies describe the design and operation of these mechanisms and the effectiveness of remediation. Monash’s announcement reports headline findings but does not set out the full framework, methodology or company-by-company scores. Read Monash University’s announcement.

What companies disclosed about grievance mechanisms and remedies

Across the 39 statements, companies addressed an average of 14.28 of the framework’s 40 questions—about 36 per cent—according to Monash University’s 2026 announcement. Five companies addressed at least half the questions, while nine addressed fewer than 10.

The reported gaps extend beyond whether a company says it has a policy or complaint channel. The figures below describe evidence in the statements, not necessarily all practices or information held by the companies.

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  • Stakeholder involvement: 10 per cent disclosed evidence that affected stakeholders or their representatives had been consulted in designing grievance mechanisms.
  • Range of remedies: 5 per cent disclosed a full range of potential remedies.
  • Whether a remedy was adequate: 5 per cent reported consulting complainants about the adequacy of a remedy.
  • Outcomes: 5 per cent disclosed remediation outcomes or the proportion of cases resolved to complainants’ satisfaction.
  • Time to resolve: No company disclosed the average or median time to complete remediation.

Each percentage and count is reported by Monash University for the FY2024 statements assessed; the announcement does not provide company-level results.

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Why a hotline or policy does not show whether harm was remedied

A channel’s existence is only one part of the question. Workers and other affected people also need to be able to use it safely and accessibly, and the company needs a way to respond to concerns and address harm. Reporting that a channel exists does not, by itself, show what happened after a complaint, whether the response was adequate, or whether the harm was prevented from recurring.

Associate Professor Nga Pham, the report’s lead author at the Monash Centre for Financial Studies, Monash Business School, said: “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,” Monash University’s announcement quotes her as saying.

Pham also said: “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.” The assessment’s low disclosure of remedy consultation, outcomes and resolution times illustrates that gap in the statements reviewed.

Does weak disclosure prove a company has no effective process?

No. The authors explicitly caution that the assessment concerns the quality of public disclosure in modern-slavery statements and does not necessarily represent underlying company practices or information available through other channels. A company may have processes that its statement does not describe. The findings show what readers could see in the statements assessed, not a definitive verdict on each company’s actual performance.

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What the authors say companies and policymakers should improve

The authors recommend clearer communication and disclosure about grievance and remediation processes, stronger participation by affected stakeholders, and more transparent reporting on outcomes. They also stress safeguards for complainants’ privacy and safety. In practice, more informative reporting would help readers understand not only how to raise a concern, but also how the company assesses a response, follows through on remedy and learns from cases—without exposing complainants to risk.

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Pham said the 8R Framework “could support government and regulators in developing clearer guidance about the systems, processes and evidence relevant to reasonable steps,” according to the Monash announcement. Esty Marcu, Director of Responsible Business and Human Rights at The University of Sydney, described the framework as useful for guiding practice and helping organisations assess maturity and identify improvements.

The announcement places the findings in the context of federal consultation on strengthening Australia’s modern-slavery laws. It refers to a proposed criminal offence for companies that fail to prevent modern slavery in their operations and supply chains, and says demonstrating reasonable steps could become critical under that proposal. This is a proposed reform described in the consultation context, not evidence that the offence is enacted law.

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ASXcorporate disclosuregrievance mechanismsmodern slaveryMonash Universityremediation

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