The Australian property and construction sector is under growing pressure to confront one of the most uncomfortable issues in global supply chains: modern slavery.

A new guide released by the Property Council of Australia and ERM, Indicators of Vulnerability to Modern Slavery in Property and Construction (August 2025), aims to give builders, developers, and suppliers a practical framework for spotting red flags and addressing risks that often sit well out of sight.

For an industry employing over 1.3 million people and sourcing materials from around the globe, the implications are significant.

Why This Matters

Modern slavery isn’t an abstract problem happening “somewhere else.” It’s tied into the very materials and services that flow into Australian building projects, from bricks and tiles to cleaning, security, and labour hire.

Australia’s Modern Slavery Act (2018) already requires large companies to report on risks in their supply chains. But for many in construction, knowing where to start has been a stumbling block.

This guide goes a step further, highlighting the industries, products, and practices most vulnerable to exploitation. It’s not about ticking boxes for compliance; it’s about recognising where harm can occur and taking steps to prevent it.

The Vulnerability Lens

The Property Council–ERM guide introduces the idea of “indicators of vulnerability” patterns and practices that increase the risk of modern slavery.

These include:

• High-risk products and materials: bricks, tiles, steel, timber, stone, and solar panels, many of which have documented links to forced labour globally.
• Labour hire and subcontracting: particularly in cleaning, security, and site services, where short-term, low-visibility work can mask exploitation.
• Geographic sourcing: materials imported from countries with weak labour protections or known forced labour issues.
• Workforce characteristics: vulnerable worker groups such as temporary migrants, students, or people with limited English skills.

For builders, the message is clear: if your projects touch these areas and almost all do, you need to be alert.

A Builder’s Responsibility

The guide recognises the unique structure of construction: complex, multi-layered supply chains where builders may have visibility of Tier 1 suppliers, but little oversight of subcontractors several levels down.

That’s where risk multiplies.

The Property Council warns that reputational damage is no longer the only threat. Investors, regulators, and clients increasingly expect clear evidence that companies are taking action, not just writing policies.

For mid-sized builders and subcontractors many of whom fall below the reporting threshold of the Modern Slavery Act this may feel like a big-business problem. But the guide stresses that smaller companies are just as exposed, particularly where they rely on imported products or outsourced labour.

Practical Tools, Not Just Principles

Importantly, the Indicators of Vulnerability guide isn’t just theory. It offers a suite of tools builders can apply immediately:

• Sector-specific examples: from quarrying and brickmaking to site cleaning and labour hire.
• Red flag checklists: warning signs for contracts, procurement, and site practices.
• Due diligence steps: practical advice on engaging suppliers, asking the right questions, and embedding checks into project delivery.
• Case studies: showing where risks have materialised and how companies responded.

For project managers under pressure to deliver on time and on budget, this makes the resource more accessible. It acknowledges the commercial realities while pushing for higher standards.

What It Means for the Industry

The release comes at a pivotal time.

• Global spotlight: International scrutiny is intensifying, particularly on construction materials like stone, tiles, and solar panels linked to forced labour in Asia and the Middle East.
• Client expectations: Institutional investors, government procurement programs, and major developers are embedding modern slavery requirements into contracts.
• Reputation at stake: Builders who ignore these issues risk being left out of tenders or facing public backlash.

As ERM notes, the property and construction sector has both “a high exposure to risk and a high capacity for impact.” In other words, what builders choose to do next will set the tone for the wider industry.

Taking the First Step

For many, the hardest part is knowing where to begin. The guide suggests a staged approach:

1. Identify risks — use the indicators framework to map vulnerable products, services, and suppliers.
2. Engage suppliers — ask questions, seek transparency, and provide support where needed.
3. Act on findings — don’t wait for perfect visibility. Address red flags where you see them.
4. Report and review — build modern slavery risk into regular project reporting.

The message is not perfection, but progress.

Voices From the Sector

Property Council Chief Executive Mike Zorbas said the guide was about equipping the industry to take “real, practical steps.”

“We know the risks are present in our supply chains,” Zorbas said. “This guide helps members move beyond policy statements to action that reduces vulnerability and protects workers.”

ERM partner Kate Daniel added: “Indicators are about visibility. Once you know where the risks sit, you can have meaningful conversations with suppliers and change outcomes on the ground.”

A Call to Builders

For builders reading this, the key takeaway is simple: modern slavery risks are closer than you think. Whether you’re sourcing stone benchtops, contracting cleaners, or engaging labour hire, vulnerabilities exist.

The Property Council and ERM guide gives you a map. The next step is yours.

It’s not just about compliance with the Modern Slavery Act — it’s about leadership, reputation, and doing right by the people whose unseen labour underpins the industry.

As one industry leader put it: “You can’t pour a slab on exploitation. If it’s in your supply chain, it undermines everything you build.”

Author: TGB Editorial