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Modern Slavery Action Tracker

In the lead-up to the first reporting period deadline, our third Modern Slavery Action Tracker provides analytics on key statistics around Modern Slavery Statements submitted to the Government Register to date and highlights notable practices. Our aim is to provide consolidated information for those interested in following Australia’s Modern Slavery response and a resource for organisations required to publish their own Modern Slavery Statements and response strategies.

Total Reporting Effort & Progress

As of 25 February 2021, 501 statements covering 1,049 reporting entities were submitted and uploaded to the Government’s Register.

Based upon the Commonwealth’s initial estimate of total reporting entities, 35% of the total have now reported, leaving 65% outstanding. This shows an 11% increase since December 2020 when 24% had reported.

Modern Slavery Action tracker Ndevr Human Rights

  • In the period between 28 January and 25 February 2021, an additional 321 reporting entities submitted a joint or stand-alone statement.
  • This includes 80 voluntary statements, up by 13 from 67 in January.

When subtracting voluntary statements from the reporting effort, based on the assumptions we discussed in Issue 2 of our Action Tracker Report, it is possible that closer to 80% of entities legally required to report are yet to do so.

This analysis suggests that while there is steady progress in reporting under the MSA, there may still be a significant number of entities that are not aware of their reporting obligations or that have simply not yet submitted their statements.

In the coming months we expect NGOs and academic organisations to begin analysing statements and highlighting reporting practices both poor and strong. Ndevr Human Rights will be following these analyses and including key findings from them in our Action Tracker Reports.

For more analysis and key statistics as well as insights into notable reporting practices, read our Report.

Webinar with Baker McKenzie

View our Webinar with Baker McKenzie which discusses practical considerations for submitting a compliant Modern Slavery Statement and year on year reporting success.

How We Can Help

We help organisations prepare for and respond to the Modern Slavery Act by measuring their operations and supply chains for slavery risk, and building mitigation and remediation plans. Our specialisation is guiding clients to reduce risk and access new opportunities by operating more sustainably and ethically. Consumers, investors, regulators, and employees are all asking more of organisations, and we know how to get ahead of the curve. Get in touch to find out more about your obligations and how we can support and offer guidance on submitting your Modern Slavery Statement.

Contact Us

Please do get in touch, we are always happy to chat about human rights and how we can support your organisation to reach its ambitions and purpose.


Level 2, 27 – 31 King Street
Melbourne, VIC 3000


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    ​AWESOME STREETFOOD, ZERO CARBON – that’s Atiyah. With its launch in 2020, Atiyah became Australia’s first 100% renewable-run street food zero-carbon kitchen certified under Climate Active. Atiyah sets operational carbon efficiency benchmarks and raises awareness about the global warming impact of food choices. They even disclosed the footprint of every item on their menu to empower their customers’ low-carbon lifestyle. We assist ATIYAH with their carbon neutrality certification.



    Responsible business is at the heart of what Intrepid does. Intrepid has been a pioneer in measuring and reporting carbon emissions since 2010. When it joined the Climate Active family in 2018, it became the largest global provider of carbon neutral certified travel adventures and the first company to voluntarily include all global operations in its certification.


    CARBON NEUTRAL ORGANISATION & PRODUCT NEXTDC are one of Australia‘s most trusted providers of data centre solutions. Since 2018 we’ve been assisting them with their Greenhouse Gas (GHG) accounting and in March 2021, the company broke ground with the launch of NEXTneutral, an innovative Climate Active-compliant colocation opt-in program for their customers. Learn more.


    Goodman Group is an ASX20 global property expert in logistics and business space. It owns, develops and manages industrial property in 17 countries. We provide strategic advisory on Goodman’s operational GHG inventory and trajectory, the GHG intensity of its investment portfolio, net zero pathway and carbon neutral certification, as well as the renewable energy delivery strategy.


    ISPT is one of Australia’s largest unlisted property fund managers, with over $11.9 billion of funds under management. We assist ISPT with its net zero pathway, land-based offset strategy as well as maintaining its carbon neutral certification. When ISPT joined the Climate Active network, it pioneered many concepts. It became the first participant under Climate Active to voluntarily include base building operations on all its owned and operated properties into its organisational certification and, as an industry first, procured 100% Australian Carbon Credit Offset Units (ACCUs).


    BHP is an ASX listed, world-leading resources company and are among the world’s top producers of major commodities, including iron ore, metallurgical coal and copper. They also have substantial interests in oil, gas and energy coal. We assist BHP comply with energy and greenhouse gas legislation and advise facilities on matters related to energy use and production emissions.


    Intrepid Travel is the largest small group adventure travel company in the world. Responsible business is at the heart of what Intrepid does. We assist Intrepid with their Human Rights reporting obligations as well as many aspects of its GHG accounting and reporting. This includes its Science-based target (SBT), making them the first tour operator with approved SBT. When Intrepid joined the Climate Active family in 2018, it became the largest global provider of carbon neutral certified travel adventures and the first company to voluntarily include all global operations in its certification.


    Lion is a global beverage company with a portfolio of brands in beer, cider, wine, spirits, seltzers, and non-alcoholic drinks. Lion has four large and four small Australian breweries, and its brands include XXXX, GOLD, Tooheys New, and Little Creatures. We assisted Lion to become Australia’s first large-scale brewer to be certified as carbon neutral under Climate Active in 2020.

    QANTAS Airline

    Founded in the Queensland outback in 1920, Qantas has grown to be Australia’s largest domestic and international airline. We have worked with Qantas since 2016 on a variety of emissions reduction projects.


    Orica is the world’s largest provider of commercial explosives and innovative blasting systems to the mining, quarrying, oil and gas and construction markets, a leading supplier of sodium cyanide for gold extraction, and a specialist provider of ground support services in mining and tunnelling. We assist Orica with their regulatory reporting such as NGERs and also carbon abatement projects.

    Fulton Hogan

    Fulton Hogan has more than 80 years experience in the transport, water, energy, mining, civil construction and land development infrastructure in New Zealand, Australia and the South Pacific.
    We assist Fulton Hogan comply with NGER and NPI legislation for their extensive national operations. We work Fulton’s team to streamline reporting procedures to avoid duplicating data handling and transparently demonstrate data flows and aggregations.


    Toyota Australia was founded in 1963 and is one of Australia’s leading automotive companies. We have worked with Toyota since 2018 on many aspects of its GHG accounting, target setting, reduction initiatives, and reporting. We continue to inform strategic decisions around the contribution of the Australian business to the realisation of Toyota’s global Environmental Challenge 2050.

    H&H Group / Swisse Wellness

    H&H Group is a global health and nutrition company listed on the Hong Kong Stock Exchange. Consumer brands include Biostime, Solid Gold Pet, Dodie, Good Goût, Aurelia Probiotic Skincare, CBII, and Swisse Wellness, a vitamin, supplement, and skincare brand, born in Australia in 1969. We have been working with Swisse and the group on many aspects of its GHG accounting and reporting, including the ongoing management of its Climate Active certification.


    AGL is one of Australia’s leading energy companies offering electricity, gas, solar and renewable energy services, plus internet and mobile plans. We have assisted AGL for over five years on a variety of activities including audit and assurance projects.


    Viva Energy is a leading energy company which supplies about a quarter of Australia’s fuel requirements. Viva Energy make, import, blend and deliver fuels, lubricants, solvents and bitumen through extensive national and international supply chains. We assist Viva Energy with a range of energy and greenhouse gas related projects. These include annual NGER reporting, Safeguard baseline setting, advice on Emission Reduction Fund opportunities and emission trajectories.