Corporate responses to tackling modern slavery: a comparative analysis of Australia, France and the United Kingdom

Fiona McGaughey, Hinrich Voss, Holly Cullen, Matthew Davis

Research output: Contribution to journalArticlepeer-review

16 Citations (Scopus)


The business and human rights agenda is gaining momentum internationally, perhaps best evidenced through recent legislative responses to tackling modern slavery. Using a reflexive law lens, we analyse three recent laws that address the business and human rights agenda - the UK Modern Slavery Act 2015, the French ‘duty of vigilance’ law of 2017, and the Australian Modern Slavery Act 2018 (Cth). The three laws, or their accompanying guidance, share characteristics in terms of reporting requirements: the supply chain; risk mapping/assessment and management; analysis of subsidiary and supply chain risk; and effectiveness. The French Act has a broader scope as it is a due diligence, rather than a reporting law and includes obligations to exercise due diligence with regard to human rights and fundamental freedoms, health and safety, and the environment. It is the only Act of the three with substantive penalty provisions. All reporting requirements in the French and Australian Acts are mandatory, but the UK Act has limited mandatory reporting requirements.
We find that only 22 companies globally will be required to report under all three laws. Using a subset of this dataset, we analysed 59 French vigilance plans and UK modern slavery statements published by nine manufacturing companies. This provided some preliminary analysis of how businesses have reported under the French Droit de Vigilance and the UK Modern Slavery Act (reports under the Australian Modern Slavery Act for these companies were not yet published at time of writing). Overall, businesses are using less demanding measures such as introducing policies and delivering training more commonly than the somewhat more resource intensive activities such as audits. The more onerous requirements of the French law were reflected in the content and level of detail in the vigilance plans, compared with the UK modern slavery statements. However, for some companies, there were strong similarities between the UK and French publications, indicating ‘creep’ from the French Act into UK reports or a ‘race to the top’.
Original languageEnglish
Pages (from-to)249-270
Number of pages22
JournalBusiness and Human Rights Journal
Issue number2
Early online date15 Nov 2021
Publication statusPublished - 15 Jun 2022


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