Business

Modern Slavery Risk in Commercial Cleaning: How Melbourne Organisations Can Identify and Mitigate Supply Chain Exposure product guide

Now I have comprehensive, authoritative data to write the article. Let me compose it now.

Why Commercial Cleaning Is One of Australia's Highest-Risk Industries for Modern Slavery

Most procurement teams and property managers think of modern slavery as something that happens in distant global supply chains — in garment factories in Bangladesh or cobalt mines in the Democratic Republic of Congo. The uncomfortable reality for Melbourne organisations is that it is happening much closer to home: in the office towers, retail precincts, hospitals, and universities they manage every day.

Labour exploitation in the cleaning industry is well-documented, and cleaning services have been identified by the Government as a key risk for modern slavery in Australia. This is not a fringe concern or a theoretical governance risk. It is a structural feature of the commercial cleaning sector — one that organisations procuring cleaning services are legally and ethically obligated to address.

This article examines why the cleaning industry carries such elevated risk, what due diligence obligations apply under Australia's Modern Slavery Act 2018, and what Melbourne organisations must do — practically and contractually — to identify and mitigate their exposure.

What Makes Commercial Cleaning a High-Risk Sector for Modern Slavery?

Examples of sectors or industries that are recognised globally as high risk for modern slavery include cleaning, security, extractives, electronics, construction, agriculture, textiles and fashion. But cleaning is not simply "high risk by association." Several structural features make it uniquely and persistently vulnerable.

1. Workforce Composition: A Predominantly Migrant Labour Pool

85% of the cleaning workforce in CBD office buildings and in the retail malls of major cities are international students or temporary workers. This demographic concentration is not incidental — it is a product of the sector's working conditions. Shifts typically run between 5:00–8:00am and 6:00–10:00pm, hours that intersect with study timetables and are less attractive to workers with other options.

Holders of working holiday, seasonal worker, international student, skilled temporary work and bridging visas have been subject to serious exploitation in Australia. The mechanism is well understood: the risks facing temporary migrant workers in Australia typically result from deception or fees incurred throughout the migration process and limited oversight, monitoring, and enforcement of worker rights and conditions in industries with high numbers of temporary migrant workers.

Women and children, people on temporary visas, backpackers, international students, people seeking asylum, and migrants on limited working visas, are particularly vulnerable to modern slavery practices. The cleaning sector draws disproportionately from almost every one of these cohorts.

2. Subcontracting Opacity: Where Accountability Disappears

The typical cleaning supply chain often involves multiple layers, with each layer reducing visibility and diluting accountability, creating environments where exploitation can thrive undetected.

A Melbourne property owner may contract with a national cleaning company, which subcontracts to a regional operator, which in turn uses labour-hire arrangements to staff individual buildings. By the time cleaning actually occurs, the contractual chain may be three or four layers deep — and the workers present on site may have no direct employment relationship with any entity the property owner has vetted.

According to the Department of Home Affairs, common malpractices in the industry include wage withholding, immigration-related coercion, deceptive recruitment, excessive overtime, debt bondage, and the confiscation of personal and travel documents, all fostered by opaque and unaccountable supply chain relationships.

3. Price Pressure and the Race to the Bottom

The industry's tender processes often encourage undercutting, leading to contracts awarded at prices that do not support the payment of minimum wages or safe working conditions. Since labour constitutes 70–90% of a cleaning contractor's cost base, aggressive price competition translates almost directly into pressure on wages and conditions. Intense cost pressure throughout the industry contributes to compliance shortcuts, including aggressive contract pricing that makes legal compliance challenging, low barriers to entry encouraging undercapitalised operators, and compensation structures that incentivise corner-cutting.

4. Isolated Working Conditions

Cleaners work in environments that are structurally isolated from normal workplace oversight. Early morning and late-night shifts mean minimal contact with building management, tenants, or other workers. Nearly 150,000 people are employed in commercial cleaning across Australia, most working in isolation and under temporary visas — making them vulnerable to unethical, unsafe and unlawful practices.

This isolation is not merely physical. cultural and language barriers, limited knowledge of workplace laws and standards, and reliance on employers who sponsor migrants' temporary visas can expose them to greater risks of modern slavery and exploitation.

The Scale of Non-Compliance: What the Evidence Shows

The problem is not hypothetical. Non-compliance with labour laws is rife in the commercial cleaning sector. Cleaners often experience underpayment, withholding of wages and excessive working hours.

Sexual harassment and even assault is common. The sector also has some of the highest rates of workplace injuries in Australia, due to the intensification of work over decades.

The cleaning industry in Australia is notorious for having some of the highest rates of wage theft. The Fair Work Ombudsman (FWO) and various academic studies have consistently found extensive non-compliance with labour laws. A staggering 90% of audited sites were found to have underpaid cleaners, illustrating the pervasive nature of this issue.

A landmark 2021 report by the Australasian Centre for Corporate Responsibility (ACCR), Cleaning Up Their Act?, reviewed the Modern Slavery Act statements of seven major listed property owners — Charter Hall, Dexus, GPT, Mirvac, Scentre Group, Stockland, and Vicinity Centres. These commitments are largely failing to translate into due diligence approaches that will successfully address modern slavery and labour exploitation. The only indicators where most property owners display "leading" disclosures and practices are those that provide a description of the reporting entity and its operations, refer to the establishment of policies and procedures, and describe how companies identify and prioritise risks. Property owners analysed performed poorly in identifying, mitigating and remedying modern slavery risks.

In other words: most large property owners in Australia know they have a problem. Very few are doing enough about it.

What the Modern Slavery Act 2018 Requires of Melbourne Organisations

The Mandatory Reporting Threshold

Australia's Modern Slavery Act 2018 is a transparency framework that requires certain large businesses operating in Australia to describe how they identify and address modern slavery risks in their global supply chains and operations.

It established a national modern slavery reporting requirement, which applies to large businesses and other entities in the Australian market with annual consolidated revenue of at least $100 million. These organisations must prepare an annual modern slavery statement. The statement explains how they are addressing modern slavery risks in their global operations and supply chains.

For Melbourne organisations above this threshold — including government agencies, large property groups, universities, and major corporates — a cleaning contract is not a peripheral procurement decision. It is a material modern slavery risk that must be identified, assessed, and reported on annually.

Smaller Organisations Are Not Off the Hook

Even organisations below the mandatory reporting threshold face equivalent obligations under common law duty of care principles and increasing stakeholder expectations. The Victorian Government's Social Procurement Framework (see our guide on Victoria's Social Procurement Framework Explained) and the City of Melbourne's ESG Procurement Framework (see our guide on City of Melbourne ESG Procurement Framework) impose supply chain obligations that effectively extend modern slavery due diligence requirements to smaller government buyers and their suppliers.

Proposed Reforms: From Disclosure to Action

The regulatory landscape is tightening. The Australian Anti-Slavery Commissioner's initial position paper, published in January 2026, signals that era of largely paperwork-based compliance is coming to an end. The proposed amendments to the Modern Slavery Act 2018 (Cth) represent the most significant shift in supply chain compliance obligations this country has seen.

The Commissioner's two core recommendations are clear: introduce a mandatory, risk-based due diligence obligation for all reporting entities, and create a mechanism to publicly declare certain products, services or industries as carrying a high risk of modern slavery. Together, these reforms would move Australia from a disclosure framework to an action framework.

Domestic risk areas including horticulture, agriculture, construction, meat processing, cleaning and food services are specifically called out. Businesses in or adjacent to these sectors cannot afford to wait for declarations before acting.

Practical Mitigation: What Melbourne Organisations Must Do

Step-by-Step: Modern Slavery Due Diligence for Cleaning Contracts

The following framework draws on guidance from the Department of Home Affairs, the Cleaning Accountability Framework, and the ACCR's best-practice principles.

1. Map Your Cleaning Supply Chain Document every tier of your cleaning supply chain — primary contractor, subcontractors, labour-hire firms, and any specialist service providers (e.g., window cleaning, carpet cleaning). Require your primary contractor to disclose all subcontracting arrangements in writing before contract commencement and to notify you of any changes.

2. Conduct Risk-Based Supplier Vetting

Certain sectors and industries have higher risks of modern slavery, such as those that tend to use foreign workers, unskilled, temporary or seasonal labour, or short-term contracts and outsourcing. Apply heightened scrutiny to any supplier using subcontracting, labour-hire, or a predominantly migrant workforce. Use the Australian Government's Modern Slavery Procurement Toolkit risk screening tool to assess individual supplier risk profiles. The Australian Government has produced a modern slavery procurement toolkit to assist procurement officers in identifying, assessing and addressing modern slavery risks in procurement activities. The toolkit contains a risk screening tool and other resources, including a suite of model modern slavery contract clauses for inclusion in Government procurement contracts.

3. Embed Modern Slavery Clauses in Contracts

The contract clauses have graduating obligations that agencies can select from depending on the modern slavery risk profile of the particular procurement. You can assess the risk profile using the Risk Screening Tool in the Toolkit. For higher risk contracts, the relevant contract clauses require suppliers and the relevant Government entity to take additional steps to ensure that any modern slavery risks are identified and adequately addressed.

At minimum, cleaning contracts should include:

  • A requirement to disclose all subcontracting arrangements
  • Obligations to comply with the Cleaning Services Award 2020 and Fair Work Act 2009
  • A right-to-audit clause permitting payroll and employment record inspection
  • Whistleblower protections for workers who report exploitation
  • Termination rights in the event of confirmed modern slavery findings

4. Engage the Cleaning Accountability Framework (CAF)

The process of CAF Building Certification addresses modern slavery risk by working with entities at the top of the supply chain because procurers of cleaning services have significant power to determine the working conditions of cleaners, despite not being in an employment relationship with them.

Through CAF Certification, stakeholders benefit by ensuring that they and entities in their supply chain aren't inadvertently supporting unlawful labour practices; minimising time spent assessing tenders and managing contracts; and accessing an anti-slavery mechanism which can be included in Modern Slavery Act statements.

CAF's approach is distinctive because it goes beyond desktop audits. The supply chain assessment includes an assessment of procurement practices, contract management practices, employment policies and procedures, and a sample check of payroll compliance. Concurrent to the desktop supply chain assessment, CAF undertakes a worker engagement assessment with cleaners at the building, including face-to-face meetings in paid time, a survey about cleaners' working conditions, and the nomination of a CAF Representative.

When critical issues — including modern slavery indicators — are identified, CAF will contact owners directly to report critical issues (e.g. modern slavery) or issues that suggest the practice is driven from the upper management level of the cleaning contractor as soon as they become aware of them. In such an event, CAF will not notify the cleaning contractor. This is to protect cleaners and prevent the cleaning contractor from hiding the issue and removing cleaners.

For Melbourne organisations managing multiple properties, in September 2024, AustralianSuper presented at the launch of CAF's Portfolio Certification, which has moved the CAF model from a building-by-building approach to a larger-scale certification. The certification is expected to increase CAF's ability to engage with cleaners on a broader scale, by enabling CAF Certification to cover property portfolios, as opposed to individual buildings.

(For a deeper dive into CAF's structure and certification process, see our guide on The Cleaning Accountability Framework: What Melbourne Property Owners and Procurement Teams Need to Know.)

5. Verify Worker Rights at the Point of Engagement

All Australian employers must verify that workers have appropriate work rights through Visa Entitlement Verification Online (VEVO) checks. Procurement teams should require evidence that their cleaning contractor conducts VEVO checks for all workers — including those engaged through subcontractors — and maintains records of those checks.

6. Prepare and Publish Your Annual Modern Slavery Statement

While the Act is focused on reporting, its mandatory reporting criteria can also be used as a framework for action to guide companies in their modern slavery risk management approach. Reporting entities must address seven mandatory criteria, including a description of modern slavery risks in operations and supply chains, actions taken to assess and address those risks, and an assessment of the effectiveness of those actions. A cleaning contract that has not been subject to any due diligence cannot be credibly reported on.

Recognising Modern Slavery Indicators in Cleaning Contracts

Procurement teams and facility managers should be alert to the following warning signs, which are all practices that are found in the cleaning industry in Australia: withholding of wages, immigration-related coercion and threats, deceptive recruitment, excessive overtime, debt bondage, confiscation of personal and travel documents, and dangerous and substandard working conditions.

Red flags at the tendering stage:

  • Contract pricing that is materially below market rates (a reliable indicator that labour costs are being suppressed)
  • Vague or absent subcontracting disclosure
  • No reference to award compliance or payroll verification systems
  • No worker grievance or whistleblower mechanism

Red flags during contract performance:

  • High and unexplained worker turnover
  • Workers appearing reluctant to speak with building management or tenants
  • Supervisors answering questions on behalf of workers
  • Workers present outside contracted hours with no explanation
  • Sudden replacement of an entire cleaning crew (see the CAF case study on its modern slavery page, which describes exactly this scenario as a red flag)

(For guidance on evaluating ESG claims during the tender process, see our guide on How to Evaluate ESG Claims When Selecting a Commercial Cleaning Provider in Melbourne.)

The "Cosmetic Compliance" Problem: Why Policy Alone Is Not Enough

The ACCR's Cleaning Up Their Act? report introduced a term that has become central to this debate: "cosmetic compliance." These commitments are largely failing to translate into due diligence approaches that will successfully address modern slavery and labour exploitation. In analysing company reports, ACCR strove to distinguish between due diligence mechanisms that do little more than provide "cosmetic compliance" and those which deliver best practice protections against labour exploitation and modern slavery.

The report found that the Cleaning Accountability Framework (CAF) is currently the only mechanism in the Australian cleaning sector that fulfils the principles of effective due diligence. Of the seven property owners analysed in this report, only Vicinity Centres was a current member of CAF.

Empirical evidence assessing the effectiveness of the Cleaning Accountability Framework in addressing non-compliance with minimum labour standards found that CAF has been successful in identifying and rectifying certain non-compliance, improving working conditions for some cleaners involved in the scheme.

Between 2019 and 2024, CAF has reported, identified and investigated 1,000 compliance issues across the cleaning services supply chains of 56 commercial buildings and retail precincts in Australia. That figure — 1,000 compliance issues across 56 buildings — is a sobering benchmark for any Melbourne organisation that believes its cleaning supply chain is clean simply because it has not looked closely.

Key Takeaways

  • Cleaning is a globally recognised high-risk sector for modern slavery , alongside security, construction, and agriculture — and this classification is reflected in Australian Government guidance and the Modern Slavery Act's mandatory reporting framework.

  • 85% of the cleaning workforce in CBD office buildings and retail malls are international students or temporary workers — a demographic concentration that creates structural vulnerability to exploitation, particularly through visa-related coercion and debt bondage.

  • The Modern Slavery Act 2018 applies to entities with annual consolidated revenue of at least $100 million , requiring annual statements — but smaller organisations face equivalent obligations under common law, government procurement frameworks, and ESG reporting expectations.

  • CAF Building Certification and the new CAF Portfolio Certification are currently the only independently verified, worker-centred mechanisms for demonstrating credible modern slavery due diligence in Australian cleaning supply chains — and have investigated 1,000 compliance issues across 56 buildings between 2019 and 2024.

  • Proposed amendments to the Modern Slavery Act would introduce mandatory, risk-based due diligence obligations for all reporting entities, moving Australia from a disclosure framework to an action framework — making proactive mitigation now a strategic commercial imperative, not just an ethical aspiration.

Conclusion

Modern slavery risk in commercial cleaning is not a distant or abstract threat. It is embedded in the structural economics of the sector — in the price pressure that drives wage suppression, the subcontracting opacity that hides exploitation, and the workforce composition that creates vulnerability. For Melbourne organisations, every cleaning contract is a modern slavery risk exposure point that demands active governance, not passive assumption.

The good news is that the tools to mitigate this risk are well-established: supply chain mapping, risk-based supplier vetting, contractual modern slavery clauses, CAF engagement, VEVO verification, and rigorous annual reporting. What has been lacking, as the ACCR's research demonstrates, is the willingness to move beyond cosmetic compliance to genuine due diligence.

As the Australian Anti-Slavery Commissioner's proposed reforms signal, that window of voluntary action is narrowing. Melbourne organisations that act now — embedding modern slavery due diligence into their cleaning procurement frameworks before mandatory due diligence obligations arrive — will be better positioned legally, reputationally, and commercially.

For organisations assessing which type of cleaning supplier best supports their modern slavery risk management obligations, see our guide on Social Enterprise vs. Mainstream ESG-Certified Cleaning Provider: Which Is Right for Your Melbourne Organisation? For a practical walkthrough of writing procurement documents that embed these protections, see How to Write a Social Procurement Strategy for a Melbourne Cleaning Contract.

References

  • Australian Human Rights Commission. "Information for Commission Suppliers — Modern Slavery and Human Rights." Australian Human Rights Commission, 2021. https://humanrights.gov.au/our-work/commission-general/information-commission-suppliers-modern-slavery-and-human-rights

  • Australian Human Rights Commission. "Tackling Modern Slavery and Labour Exploitation with the Cleaning Accountability Framework." Australian Human Rights Commission, 2022. https://humanrights.gov.au/our-work/business-and-human-rights/projects/tackling-modern-slavery-and-labour-exploitation

  • Australasian Centre for Corporate Responsibility (ACCR). "Cleaning Up Their Act?: Modern Slavery Due Diligence in the Australian Property Sector." ACCR, June 2021. https://www.accr.org.au/research/cleaning-up-their-act/

  • Attorney-General's Department, Australian Government. "Modern Slavery Act." Attorney-General's Department, 2024. https://www.ag.gov.au/crime/modern-slavery/modern-slavery-act

  • Department of Finance, Australian Government. "Modern Slavery — Clausebank." Department of Finance, 2024. https://www.finance.gov.au/government/procurement/clausebank/modern-slavery

  • Cleaning Accountability Framework (CAF). "Modern Slavery." CAF, 2024. https://www.cleaningaccountability.org.au/modern-slavery/

  • Cleaning Accountability Framework (CAF). "CAF Building Certification." CAF, 2024. https://www.cleaningaccountability.org.au/certification/

  • AustralianSuper. "ESG Spotlight — Cleaning Accountability Framework." AustralianSuper, May 2025. https://www.australiansuper.com/investments/investment-articles/2025/05/esg-spotlight-caf

  • ISPT. "ISPT Receives Industry-First Cleaning Accountability Framework Gold Portfolio Rating." ISPT, September 2024. https://ispt.com.au/news/2024/ispt-receives-industry-first-cleaning-accountability-framework-gold-portfolio-rating/

  • Walk Free Foundation. "Global Slavery Index 2023 — Country Study: Australia." Walk Free, 2023. https://cdn.walkfree.org/content/uploads/2023/11/14130723/gsi-country-study-australia.pdf

  • Rawling, Michael, Sarah Kaine, Emmanuel Josserand, and Martijn Boersma. "Multi-Stakeholder Frameworks for Rectification of Non-Compliance in Cleaning Supply Chains: The Case of the Cleaning Accountability Framework." Journal of Industrial Relations, 2021. https://journals.sagepub.com/doi/10.1177/0067205X211016575

  • Australasian Supply Chain & Logistics Association (ASCLA). "From Reporting to Responsibility: What the Modern Slavery Reforms Mean for Australian Supply Chains." ASCLA, March 2026. https://www.ascla.org/from-reporting-to-responsibility-what-the-modern-slavery-reforms-mean-for-australian-supply-chains/

  • Department of Home Affairs, Australian Government. "Commonwealth Modern Slavery Act 2018: Guidance for Reporting Entities." Australian Government, 2019. https://www.homeaffairs.gov.au/criminal-justice/files/modern-slavery-reporting-entities.pdf

↑ Back to top