Why HR is on the frontline in the fight against modern slavery

As modern slavery continues to pose a growing threat to vulnerable workers in Australia and abroad, the founder and managing director of The Freedom Hub says HR departments are in a powerful position to drive change – if they are prepared to step up.

As pressure mounts on Australian businesses to take meaningful action against modern slavery, Sally Irwin, founder and managing director of The Freedom Hub, calls on HR leaders to step up and lead the charge from within.

Irwin stressed that HR professionals are uniquely positioned to lead the integration of modern slavery risk into company policies, as they are “the heart of any organisation, they steward the people, culture, and values”.

“They’re already managing onboarding, induction, the supply of labour, recruitment agencies, and employee wellbeing, each a potential touchpoint for exploitation if not handled with due diligence,” she said.

With an estimated 41,000 people living in modern slavery conditions in Australia, Irwin warned that many businesses are overlooking risks that may already be embedded within their operations.

“The biggest gap I see is awareness. Many HR professionals still don’t recognise that modern slavery can exist in Australia and that it may be closer to their business than they think. They often assume it’s just a legal or compliance issue, rather than a human issue that affects real lives,” she said.

“Another gap is practical implementation. Even when policies exist, there’s a lack of training on how to spot red flags in recruitment or subcontracting practices, or how to create safe channels for vulnerable workers to speak up.”

For change to be meaningful, Irwin stressed that HR professionals must stop viewing modern slavery as solely the responsibility of “legal or procurement” and instead recognise it as “part of their responsibility”.

More urgent than ever to act

While modern slavery has long been a global issue, Irwin emphasised that the urgency to address it is greater than ever, noting that “the risks are growing, and so are the expectations on businesses to act”.

Despite Australia’s Modern Slavery Act already mandating that entities with over $100 million in revenue report on risk and mitigation strategies, she stressed that reporting alone does not go far enough.

“We’re seeing an increase in false recruitment agencies, particularly in high-risk sectors like cleaning, construction, and hospitality, where vulnerable workers are being exploited through deceptive contracts and debt bondage,” she said.

With the recent establishment of Australia’s first Anti-Slavery Commission, she observed that “there’s a shift happening”, marking a clear move “towards real accountability”.

“Penalties for non-compliance are being considered, and scrutiny is intensifying. But beyond legal risk, there’s a reputational cost. Customers and employees are no longer passive – they’re actively choosing brands that align with their values. They expect transparency, ethical sourcing, and human rights due diligence,” she said.

Bridging DEI, ESG and human rights

For HR leaders looking to align their modern slavery response with broader diversity, equity and inclusion (DEI) and environmental, social and governance (ESG) strategies, Irwin recommends “embedding ethical practices” into core HR systems and values.

Irwin outlined practical actions HR leaders can take:

• Recruitment integrity: “Ensuring robust checks are in place to avoid deceptive recruitment practices. This includes verifying the legitimacy of labour hire agencies and guaranteeing transparency in employment terms, contracts in native languages, Australian Fair Work guidelines are given to employees and adhered to, especially for migrant or casual workers,” she said.

• Staff training: “Equipping teams to recognise red flags such as employees with shared bank accounts, inconsistent pay records, or those who seem overly controlled or fearful. These signs can often be missed without proper education. Including modern slavery training, company ESG and DEI policies and remediation into induction helps this process.”

• Confidential reporting channels: “Establishing secure and anonymous ways for staff to report suspicious behaviour or exploitation. Many whistleblower methods are not known by employees, and they don’t trust the anonymity of them. Demonstrating them and ensuring the process is clearly displayed, builds a culture of safety and accountability,” she said.

HR’s blind spots

Irwin noted that one of the most significant blind spots for HR teams in identifying potential modern slavery risks within their workforce is the assumption that workers with visas or contracts are not at risk.

“There’s often a false sense of security that if someone has a visa or a contract, they’re safe. But exploitation is hidden, particularly through third-party labour hire, subcontracting, and cleaning or hospitality services where oversight is limited,” she said.

She also pointed out that many HR professionals miss subtle behavioural red flags because they lack training in recognising signs of trauma or exploitation.

“Another blind spot is not recognising behavioural red flags in staff. For example, workers who seem overly fearful of authority, avoid eye contact, or are reluctant to speak about their living conditions,” she said.

“HR often misses these signs because they’re not trained to look for trauma responses or don’t have systems that allow employees to disclose concerns safely.”

Where to begin

For businesses just starting to address modern slavery, Irwin said human-centred training and education is the “best first step”.

She explained that incorporating survivor-informed training into onboarding and leadership programs helps ensure the issue is addressed early and consistently, but cautioned that it “must go beyond ticking boxes”.

“The most impactful training programs include lived experience, real stories from survivors that bring humanity into the room. When people hear firsthand how exploitation happens, their understanding shifts. Empathy takes root. That’s when company values move from posters on the wall to behaviour in action,” she said.

Beyond training, Irwin recommends embedding ethical practices throughout the employee life cycle, from recruitment and induction to grievance procedures and supplier management.

“HR can also ensure that ethical practices are woven into every part of the employee life cycle, from recruitment and onboarding to grievance procedures and contractor relationships. This is how you build a workplace that not only complies with the law but champions human rights,” she said.