What every APPA member needs to know about modern slavery — and how to respond when a client asks
By Dr Stephen Morse, CEO, Unchained Solutions
Between the factory floor and the branded merchandise your client hands out at a trade show sits a supply chain. Somewhere in that chain — in China, Southeast Asia, or Australia — there may be a worker who is underpaid, unable to speak up safely, or forced to pay money just to get the job.
That is what the modern slavery conversation is about — and why procurement teams in enterprise and government are asking more questions about supplier practices.
For APPA members, this is no longer just an ethical issue. It is a supplier credibility issue. This article explains why it matters, what has changed, and five practical steps any business can take now — without a large compliance budget.
The World Has Changed
Trade pressure and what it does to workers
The promotional products industry sources heavily from China. Tariff turbulence in 2025–26 disrupted factory capacity, intensified price competition, and increased pressure across supply chains. When margins tighten, that pressure often lands on workers.
The risk is not abstract. A 2026 report by the Migrant Justice Institute found that two-thirds of migrant workers surveyed in Australia were paid less than they were legally owed, and more than a third were working under ABN arrangements, which is above the general workforce. This means that migrants on work visa are more likely to experience wage theft and job insecurity. The deeper the underpayment, the more likely workers were to experience indicators linked to forced labour.
"Wage theft can escalate into forced labour when workers are trapped by debt, threats, or fear. The line between underpayment and modern slavery is not a wall — it is a gradient."
Two Australian examples show how quickly the risk can become real.
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CASE STUDY Winit (AU) Trade Pty Ltd — Western Sydney |
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Shi Yuen Wong was a Hong Kong national on a working holiday visa, picking and packing in a Western Sydney warehouse. "This was the first time I'd been overseas, this was my first job," he said through an interpreter. "I basically didn't know what things were like in Australia. I never knew overtime rates applied." The Fair Work Ombudsman found that Winit (AU) Trade Pty Ltd — a Hong Kong-owned logistics supplier providing warehousing for products sold on retail platforms — had systematically underpaid its migrant workforce. The outcome: $368,684 in back-pay secured for 30 workers, and $558,190 in penalties imposed against the employer and its director. The lesson for the promotional products industry is not that logistics suppliers are uniquely risky. It is that the workers closest to your product — those packing, storing, and labelling it — are often the least visible, and the most exposed. |
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CASE STUDY Teys Australia — Migrant Workers and Recruitment Fees |
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Teys Australia, a major meat processor employing large numbers of migrant workers, discovered that 14 workers had paid recruitment fees to get their jobs — a practice that violates both ethical sourcing standards and Australian law. Rather than quietly closing the matter, Teys responded by delegating formal accountability to HR, establishing internal reporting channels across sites, conducting worker interviews, and overseeing direct reimbursement. Monthly updates went to executive leadership. The lesson: it is not only about preventing harm. It is about having the internal infrastructure to detect it, act on it, and demonstrate accountability when it occurs. Most businesses do not have that infrastructure yet. Building it is the work. |
In April 2026, China's State Council issued two new decrees that matter to anyone trying to understand or verify supply chain risk.
In plain language: some types of supply chain investigation and information-gathering inside China have become more legally sensitive. That makes traditional audit-heavy approaches harder to rely on.
For APPA members, the message is not to panic. It is to focus on what you can control: your direct suppliers, the questions you ask, the commitments you request, and the internal systems you build to respond credibly.
That makes supplier questionnaires, ethical sourcing commitments, and internal policies more important — not less.
Australia's Modern Slavery Act 2018 currently requires entities with annual revenue above $100 million to report on modern slavery risks in their supply chains. Most individual APPA members fall below that threshold. But their enterprise and government clients almost certainly do not — and those clients are passing the obligation downstream, into their supplier relationships.
Reform discussions in Australia are increasingly focused on moving beyond disclosure toward mandatory due diligence, with stronger oversight and potential penalties. The direction is clear: reporting is only the starting point.
Procurement teams are not just asking whether you have a policy. They are asking whether your business can show a credible process.
Five Practical Tips for APPA Members
These tips are for businesses of all sizes, including those sourcing through agents or small manufacturers. The goal is not perfection. It is a credible, practical response.
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Start with what you can see Map your direct suppliers, where they are based, and what products they provide. If you source through agents or intermediaries, be honest about the limits of your visibility. Start this week: list your top suppliers and note what you do — and do not — know about where goods are made. |
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Ask better supplier questions Keep it simple. Ask whether workers' pay recruitment fees, whether wages are paid in full and on time, whether workers can leave freely, and whether there is a safe way to raise concerns. Start this week: send four core labour questions to one key supplier or agent. |
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Build simple internal systems You do not need a major audit budget to get started. A short ethical sourcing policy, a supplier code of conduct, and basic staff awareness training go a long way. Start this week: draft a one-page ethical sourcing statement and decide who in your business owns the issue. |
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Understand what client questionnaires really mean Most clients are not expecting perfection. They want to know whether you have considered the risk, spoken with suppliers, and built a process you can explain. Start this week: prepare a short response that covers your policy, supplier engagement, staff awareness, and what you would do if a concern is found. |
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Measure something small Track a few simple indicators, such as how many suppliers have responded to your questions, signed your code, or been reviewed in the last year. Start this week: choose one metric and record a baseline. |
The Bottom Line
The promotional products industry sits at the intersection of global manufacturing, procurement scrutiny, and growing regulatory expectation.
The good news is that a credible response does not require a perfect supply chain or a large compliance team. It requires honesty, better supplier conversations, and a few practical systems that show your business is taking the issue seriously.
In many cases, relationship-based due diligence — visiting suppliers, asking direct questions, and documenting what you learn — will be more useful than a checkbox audit you do not fully understand.
"Procurement teams aren't just asking what your products are made from. They're asking who made them, and under what conditions."
The question is no longer whether clients will ask. It is whether your business is ready to answer clearly and credibly.
ABOUT THE AUTHOR
Dr Stephen Morse is the CEO and founder of Unchained Solutions Pty Ltd, a B-Corp and Social Traders accredited consultancy specialising in governance, human rights risk management, and modern slavery. He chairs the Ethics Committee of the Australasian Supply Chain Institute and holds a Doctorate in Human Trafficking Intervention. Unchained's SME Modern Slavery Toolkit and ESG Strategy Course offer practical starting points for APPA members looking to build their approach.
SELECT SOURCES
Key sources include the Australian Attorney-General's Department guidance on the Modern Slavery Act, the Australian Anti-Slavery Commissioner's 2026 reform recommendations, the Fair Work Ombudsman's Winit case material, the Migrant Justice Institute's Off the Books report, and public reporting by Teys Australia and Nestlé.
