Month: April 2025

Grievance Mechanisms to address Modern Slavery

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Strengthening Grievance Mechanisms to Address Modern Slavery: A Guide to Supporting Worker Voice and Justice

Modern slavery remains an often-hidden reality within global and local supply chains. While awareness is growing, the grievance mechanisms and systems that should support affected individuals are not always doing enough.

Nicholas Bernhardt, CEO of Informed 365, highlights a critical gap between intention and impact when it comes to grievance mechanisms. While over 70% of companies report having such systems in place, fewer than 50% of workers in surveyed global supply chains can access them in their own language (The Mekong Club, 2022). Even fewer see meaningful outcomes: the number of actual grievances reported in modern slavery statements is almost zero, revealing a significant disconnect between policy and practice.

Nicholas points out that there is some progress with larger suppliers (>$100M revenue) increasingly implementing formal grievance systems, with improved access to HR, trade unions, hotlines, and digital tools. However, smaller suppliers, lower-tier operations, and migrant workers are often left behind.

Recent Australian research by Macquarie University’s Business and Human Rights Access to Justice Lab found that only 10 of 25 top companies provided remedial mechanisms for external individuals and communities to raise human rights complaints.

Likewise, the KPMG and Property Council’s 2022 report notes that while grievance mechanisms are recognised as essential in the property and construction sectors, many businesses rely on suppliers’ systems rather than building their own. Implementation remains patchy, inconsistent, and largely ineffective without direct engagement and worker-centric design.

In this guide we bring together insights from leaders in the field, across business, law, humanitarian services, and technology; on what effective grievance mechanisms look like, and how they can be improved to truly support the people they’re meant to protect.

What Makes a Grievance Mechanism Work?

Grievance mechanisms come in many forms:

  • Informal options like worker forums and community-based organisations
  • Formal corporate channels like complaint procedures and codes of conduct
  • Independent third-party providers and anonymous hotlines
  • Certification body complaints systems (e.g. Cleaning Accountability Framework)
  • Trade union processes and statutory bodies (e.g. Fair Work Commission)

Regardless of format, effective mechanisms share a common foundation. Robin Mellon, CEO of Better Sydney, outlines eight essential elements for success:

The 8 Essential Elements of Effective Grievance Mechanisms
  1. Legitimate – Mechanisms must be trustworthy and accountable.
  2. Accessible – Workers must know they exist and be able to use them easily, with support if needed.
  3. Predictable – Steps, timelines, and potential outcomes should be clearly outlined.
  4. Equitable – Users must be treated fairly and given access to relevant expertise and information.
  5. Transparent – Stakeholders should have insight into how the mechanism functions and performs.
  6. Rights-Compatible – Outcomes must respect and uphold international human rights standards.
  7. Continuous Learning – Feedback from users should be used to improve processes.
  8. Dialogue-Based – Workers and affected parties must be engaged in the design and review of mechanisms.

Effective grievance mechanisms are not one-off interventions, they are part of a broader remediation pathway. After an issue is raised, organisations must commit to:

  • Safeguarding individuals’ rights
  • Understanding the harm and the organisation’s role
  • Using leverage to address root causes
  • Implementing remedies that are just and appropriate
  • Preventing future harm through systems improvement

Supporting People Through the Process

Natalie Maxwell-Davis, from the Australian Red Cross, brings critical insight into the real-life experiences of survivors in Australia. Since 2009, Red Cross has supported more than 750 individuals through the Support for Trafficked People Program (STPP) – many of whom only learned they were experiencing modern slavery once they accessed help.

One survivor shared:

“I had not even heard of the term modern slavery until I came into the Red Cross program.”

The Work Right Hub, developed by the Australian Red Cross, is a digital platform aimed at preventing and addressing labour exploitation. It provides both workers and responders with tools to recognise exploitation and find support, including:

  • A decision-tree tool to connect with free, confidential services
  • Basic rights checklists and workplace tips
  • Survivor stories to foster awareness
  • Multilingual flyers and brochures

Natalie highlights seven key actions for improving grievance mechanisms:

  1. Provide clear, accessible information for workers and suppliers
  2. Use inclusive and supportive language
  3. Raise awareness and encourage reporting
  4. Break down barriers to access
  5. Develop and test response procedures
  6. Engage workers in reviewing and refining systems
  7. Support suppliers to strengthen their own grievance processes

What Happens After You Speak Up?

Lauren Dale, of Anti-Slavery Australia, emphasises that grievance mechanisms must support survivors beyond the initial disclosure. Many people fear that speaking up may jeopardise their visa, employment, or safety, and these fears are not unfounded.

Quotes from survivors reflect this anxiety:

  • “Will I lose my visa?”
  • “Will my family and I be safe after this?”
  • “Do they actually care about what happens to me?”

Too often, survivors are left with unanswered questions and minimal support:

“They said they weren’t responsible, but it was their products I packed.”

Anti-Slavery Australia’s work, including legal support, research, and training, continues to push for stronger systems and survivor-centered responses. One major recommendation is the establishment of a National Compensation Scheme, to ensure all survivors can access meaningful justice and recovery.

Amplifying Worker Voice at Scale

Mark Taylor, from the Issara Institute, shared how worker-centered grievance mechanisms can be implemented at scale across global supply chains. Issara’s model places worker voice at the heart of ethical sourcing by integrating multiple communication channels, including:

  • Golden Dreams App – A job platform with reviews, guides, alerts, and a “Yelp-like” rating system
  • Multilingual helplines – Available 24/7 in languages including Khmer, Lao, Thai, Bengali, and more
  • Direct outreach – On-the-ground teams engage with communities, workers, and partners

With over 300,000 workers engaged and up to 20,000 monthly calls and messages, Issara operates one of the largest independent worker voice systems in the world.

Mark stresses the importance of moving from audit-based compliance to worker-driven human rights due diligence. This approach strengthens trust, drives systemic improvements, and centers the experiences and needs of workers.

Visit: Worker Voices

Everyone Has a Role to Play

Creating better grievance mechanisms requires collaboration across every level of business, government, and society. Whether you’re in procurement, operations, HR, legal, or advocacy, there’s something you can do:

  • Refer people to organisations that provide legal aid, support, and safe reporting channels
  • Collaborate with experts to build more responsive and inclusive systems
  • Provide feedback on existing grievance tools and platforms
  • Donate or volunteer with frontline organisations advancing worker rights
  • Keep the conversation going—raise awareness, listen to survivor voices, and advocate for justice

To hear more about how Informed 365 can support you to identify and mitigate modern slavery risk in your supply chain, while streamlining your annual reporting and Modern Slavery Statement process, book a demo here.

Further Resources

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Taking action against chocolate slavery

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Chocolate Slavery: How Organisations and Consumers Can Help End Cocoa Slavery and Support Anti-Slavery Chocolate

Chocolate is one of the world’s most beloved treats, but behind the sweetness lies a harsh and deeply troubling reality: chocolate slavery and the ongoing exploitation of children and vulnerable workers in the cocoa supply chain. While awareness is growing and progress has been made, the fight against cocoa slavery continues with both organisations and consumers having a vital role to play.

A Bitter History of Cocoa Slavery

For decades, the cocoa industry has been plagued by systemic issues, particularly in West Africa, where around 70% of the world’s cocoa is grown. Children as young as five have been reported working long hours on cocoa farms under hazardous conditions. Many are trafficked or forced into labour, often unpaid, due to poverty, lack of access to education, and exploitative supply chains. This is the harsh reality of cocoa slavery.

In 2021, we explored these issues in our blog, “Modern Slavery and Child Labour in the Cocoa Industry”, which outlined how chocolate slavery persists in global supply chains. Since then, there have been important developments, but there is still much work to be done.

Regulatory Momentum Against Chocolate Slavery

Around the world, governments are introducing and strengthening legislation to address human rights abuses in supply chains, including those linked to cocoa slavery. These regulations not only demand transparency but also accountability and proactive risk mitigation from companies.

In Australia, the Modern Slavery Act 2018 requires large entities (over $100 million in annual revenue) to report annually on the risks of modern slavery in their operations and supply chains, as well as actions taken to address those risks. The Act has raised awareness and driven stronger reporting among companies with exposure to anti-slavery chocolate commitments.

In the European Union, the upcoming Corporate Sustainability Due Diligence Directive (CSDDD) will go even further. It will require certain companies to identify, prevent, and remedy adverse human rights and environmental impacts – not just in their own operations, but across their entire value chain. This will apply to many global chocolate producers and retailers sourcing cocoa from high-risk regions.

Other relevant regulations include:

  • UK Modern Slavery Act (2015) – Requires companies to publish a Modern Slavery Statement.
  • German Supply Chain Due Diligence Act (LkSG) – Enforces due diligence for companies with over 1,000 employees, including in foreign operations.
  • U.S. Tariff Act (1930, Section 307) – Prohibits import of goods produced with forced labour, which has already led to actions against cocoa suppliers.

Together, these frameworks are increasing pressure on companies to move from voluntary efforts to mandatory compliance in eliminating cocoa slavery and supporting anti-slavery chocolate production.

The Chocolate Scorecard: A Powerful Anti-Slavery Tool

One of the most valuable tools for tracking progress and holding companies accountable is the Chocolate Scorecard, an initiative by Be Slavery Free. The 6th edition has just been released, evaluating over 60 chocolate companies on their performance across six key categories:

  • 1. Traceability & Transparency
  • 2. Living Income for Farmers
  • 3. Child Labour (including efforts to end cocoa slavery)
  • 4. Deforestation & Climate
  • 5. Agroforestry
  • 6. Chemical Management

The Scorecard highlights both leading companies and those failing to meet ethical standards. It also showcases “Good Egg” award winners – companies recognised for their commitment to anti-slavery chocolate practices and more sustainable cocoa farming.

Whether you’re a business sourcing chocolate or a consumer buying your favourite brand, the Chocolate Scorecard is an invaluable resource for identifying companies working to eliminate chocolate slavery and support human rights.

What Organisations Can Do to Combat Cocoa Slavery

Organisations using cocoa in their supply chains have a responsibility to address and eliminate cocoa slavery. Here’s how:

  • Conduct Human Rights Due Diligence (HRDD): Proactively assess and address human rights risks in your supply chain.
  • Use the Chocolate Scorecard to assess suppliers and align procurement with your ESG goals.
  • Engage suppliers on traceability, certifications, and progress against industry benchmarks.
  • Support multi-stakeholder initiatives such as the International Cocoa Initiative (ICI) to promote long-term change.
  • Track and report progress using platforms like Informed 365 to maintain transparency and accountability.

Organisations leading the fight against Chocolate Slavery

Tony’s Chocolonely

Tony’s Chocolonely is dedicated to producing 100% slave-free chocolate. The company collaborates directly with farmer cooperatives to maintain a fully traceable supply chain, ensuring transparency and ethical sourcing practices. By paying farmers a living income and committing to long-term purchasing agreements, Tony’s Chocolonely addresses the root causes of child labor and exploitation in the cocoa industry. Read more about their operations here.

Olam International

Olam Cocoa, a subsidiary of Olam International, has partnered with the Fair Labor Association to digitally register nearly 7,000 cocoa farmers and their households in Cameroon. This initiative includes implementing rigorous traceability and reporting systems, educating communities about child labor, and establishing Child Labor Monitoring and Remediation Systems (CLMRS). Olam Cocoa plans to expand this program to cover approximately 223,000 farmers across West Africa.

International Cocoa Initiative (ICI)

The International Cocoa Initiative is a Geneva-based nonprofit organisation funded by major chocolate manufacturers. ICI focuses on addressing child labor in cocoa production in West Africa by collaborating with communities, farmers, unions, the cocoa and chocolate industry, civil society, and national governments. Their efforts aim to improve the lives of children involved in cocoa farming through awareness programs, education, and the implementation of child protection policies.

These organisations exemplify the multifaceted approach needed to eradicate child labor and promote ethical practices in the cocoa supply chain.

How Consumers Can Choose Anti-Slavery Chocolate

Every chocolate purchase is a choice and consumers have more influence than they realise. To support the fight against chocolate slavery, consumers can:

  • Check the Chocolate Scorecard before buying chocolate and support high-ranking brands.
  • Look for ethical certifications like Fairtrade, Rainforest Alliance, or direct trade models.
  • Share information about cocoa slavery and ethical chocolate with your community.
  • Advocate for change by supporting policies and groups that promote human rights in global supply chains.

Useful Resources for Awareness and Action

Here are some essential tools and resources to help organisations and consumers take meaningful action:

The Road Ahead: Ending Chocolate Slavery Together

While the 6th edition of the Chocolate Scorecard shows signs of improvement, it also reveals that many companies still need to do more to eradicate cocoa slavery from their supply chains. Change is happening – but it needs to happen faster.

Whether you’re an organisation or a consumer, your choices matter. By demanding anti-slavery chocolate, supporting transparent companies, and pushing for accountability, we can help create an ethical chocolate industry. 

Ready to Take Action?

Informed 365’s ESG and modern slavery reporting platform makes it easy to gain transparency across your supply chain, monitor risk, and report with confidence.

Book a demo today to see how Informed 365 can support your anti-slavery goals and help you build a more ethical and sustainable business.

Revisit our original blog on this topic here: Modern Slavery and Child Labour in the Cocoa Industry

Informed 365 and Orka Advisory ESG Strategy Partnership

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Informed 365 and Orka Advisory Announce Strategic Partnership to Drive ESG Innovation and Regulatory Readiness

Informed 365, a leading ESG data and risk management SaaS provider, and Orka Advisory, a purpose-driven advisory firm specialising in ESG strategy development and implementation, sustainability reporting and disclosures, stakeholder engagement and materiality assessments, ESG training and capacity building, are excited to announce a strategic partnership. This collaboration brings together cutting-edge technology and deep industry expertise to help organisations accelerate their ESG journeys and respond confidently to the evolving sustainability and compliance landscape.

The partnership integrates Informed 365’s dynamic SaaS platform with Orka Advisory’s pragmatic, impact-led approach to ESG advisory, enabling clients to access real-time insights, enhance decision-making, and embed ESG performance into core business strategy.

“This partnership aligns with our shared vision of supporting organisations to move beyond compliance and towards meaningful, measurable ESG impact,” said Nicholas Bernhardt, CEO of Informed 365. “Orka Advisory’s on-the-ground expertise in sustainability strategy and stakeholder engagement complements our platform perfectly.”

Dr Kaushik Sridhar, Founder of Orka Advisory, added: “At Orka, we believe that good ESG strategy is as much about people and purpose as it is about data. By teaming up with Informed 365, we can offer our clients a robust, end-to-end ESG solution that combines technology, insight, and experience. This collaboration will help organisations not only meet regulatory expectations but lead the way in sustainability.”

With increasing pressure from regulators, investors, and stakeholders, the need for integrated ESG solutions has never been greater. Together, Informed 365 and Orka Advisory will help organisations navigate disclosures, mitigate risks, and drive long-term sustainable value across their operations and supply chains.

To learn more about this partnership, get in touch with us here.