Modern Slavery, Subcontracting and Commercial Cleaning

In 2020, ACCR launched a program of work that looked at material risks associated with various forms of indirect employment: labour hire, contracting and subcontracting. The commercial cleaning sector was identified as a sector where subcontracting is rife, and the risks associated with indirect employment are high.

The sector involves complex and multilayered labour hire and subcontracting relationships. Historically, building owners have used their market power to exert significant downward pressure on wages and conditions. These are significant factors that make the sector one of the Australian sectors at highest risk for modern slavery.

ACCR is engaging building owners on the policies and processes that they have in place to manage compliance in their cleaning supply chains.

Worker-driven social responsibility

ACCR’s engagement on cleaning supply chains is part of a broader program of work that has focused on the inadequacy of social audits in ensuring compliance in supply chains.

Drawing on decades of research, we argue that worker-driven social responsibility (WSR) initiatives offer a more robust form of human rights due diligence than social audits. WSR initiatives actively involve workers and their representatives in compliance measures, and have been shown to be effective in addressing labour risks. These initiatives support workers to raise workplace issues early, helping businesses to resolve them “before they escalate into more lengthy and complex disputes that may come at a high cost”.

ACCR is calling on building owners to adopt a cross-sector approach to managing supply chain risk that actively involves workers and their representatives, alongside suppliers, property owners and statutory agencies.

The Cleaning Accountability Framework (CAF) is an example of a positive multi stakeholder approach. It involves: lead/host companies (e.g. property owners), investors and asset managers; cleaning companies; employee representatives, industry associations, and the Fair Work Ombudsman. CAF advocates for responsible contracting practices. Participants involved in this scheme, including investors, have described how it assists in ensuring that labour practices in the cleaning industry are ethical, fair, and high-quality.

Company engagement

ACCR is engaging the following companies on their cleaning supply chains, and on cleaning service procurement more broadly: Scentre Group (SCG), Dexus (DXS), Mirvac (MGR), Lendlease (LLC), GPT Group (GPT), Stockland (SGP), Vicinity Centres (VCX), Charter Hall Group (CHC).

Key Documents