The intersection of modern slavery and electronic waste is one of the most serious ethical issues in the technology lifecycle. From the mining of raw materials used in electronics to the informal recycling of discarded devices in developing countries, forced labour and exploitative working conditions are documented at multiple points in the e-waste supply chain. Australian organisations have specific legal obligations under the Modern Slavery Act 2018 (Cth) to identify and address these risks in their operations and supply chains.
Where Modern Slavery Risks Exist in E-Waste
Modern slavery risks in the electronics and e-waste supply chain occur at several stages. At the raw materials stage, minerals like cobalt, tantalum, tin, and tungsten, essential components in electronic devices, are sometimes sourced from mines that use child labour or forced labour, particularly in the Democratic Republic of Congo and parts of Southeast Asia. Cobalt mining, which supplies the lithium-ion batteries in laptops, phones, and tablets, has been extensively documented as a sector with significant forced labour and child labour risks.
At the manufacturing stage, electronics assembly in some regions involves labour practices that may constitute forced labour under international definitions, including debt bondage of migrant workers, excessive working hours, withheld wages, and restricted freedom of movement.
At the end-of-life stage, e-waste exported to countries with weak regulatory frameworks is often processed by informal workers, including children, who manually dismantle equipment and use dangerous methods like acid baths and open burning to extract valuable metals. These workers typically have no protective equipment, receive minimal pay, and face severe health consequences from exposure to heavy metals and toxic chemicals.
Australia’s Modern Slavery Act
The Modern Slavery Act 2018 (Cth) requires entities with annual consolidated revenue of $100 million or more to publish an annual Modern Slavery Statement. The statement must describe the entity’s structure, operations, and supply chains, the modern slavery risks in those operations and supply chains, and the actions taken to assess and address those risks, including due diligence and remediation processes.
Even if your organisation falls below the $100 million threshold, you may be a supplier to entities that are required to report. In that case, your customers may ask you to demonstrate that your own supply chains, including your IT procurement and e-waste disposal arrangements, are free from modern slavery risks.
E-Waste Export and the Basel Convention
Australia is a signatory to the Basel Convention, which regulates the transboundary movement of hazardous wastes, including e-waste. The convention aims to prevent wealthy countries from dumping hazardous waste in developing nations where processing conditions are often unsafe and exploitative.
Despite these regulations, significant volumes of e-waste still flow from developed to developing countries, sometimes disguised as “second-hand goods” or “donations.” Once in the receiving country, non-functional equipment is often processed by the informal sector under conditions that would constitute modern slavery by most definitions.
Choosing an ITAD provider that processes equipment within Australia, or that can demonstrate a transparent, auditable chain of custody for any exported materials, is one of the most effective ways to reduce your organisation’s connection to modern slavery through e-waste.
Due Diligence Steps for IT Procurement
Addressing modern slavery in your IT supply chain starts with procurement. When purchasing new IT equipment, consider asking suppliers about their due diligence on conflict minerals and responsible sourcing, requesting information about labour practices in their manufacturing facilities and those of their subcontractors, reviewing suppliers’ own Modern Slavery Statements (if they are reporting entities), and giving preference to manufacturers with credible responsible sourcing programmes and third-party audits.
Major equipment manufacturers have made varying degrees of progress on supply chain transparency. Some publish detailed supply chain reports and participate in industry initiatives like the Responsible Business Alliance (RBA). Others provide minimal visibility. Your procurement decisions send a market signal about the importance of these practices.
Due Diligence Steps for IT Disposition
When it comes to end-of-life IT equipment, modern slavery due diligence means understanding exactly what happens to your equipment after it is collected by your ITAD provider. Key questions to ask include where equipment is processed (domestically or exported), who performs the processing and under what working conditions, whether the provider holds certifications (like R2 or e-Stewards) that include social responsibility requirements, what happens to materials that are sent to downstream processors, and whether the provider conducts audits of its own supply chain.
Providers certified to the R2 standard, for example, are required to demonstrate responsible downstream management and conduct due diligence on their recycling partners. This is not a guarantee against modern slavery, but it represents a higher level of accountability than working with an uncertified provider.
Reporting on E-Waste in Modern Slavery Statements
If your organisation is a reporting entity under the Modern Slavery Act, your Modern Slavery Statement should address IT procurement and e-waste disposition as part of your supply chain risk assessment. A credible disclosure would describe the modern slavery risks you have identified in your IT supply chain, the steps you have taken to assess these risks (such as supplier questionnaires, audits, or certification requirements), the actions you have taken to mitigate the risks (such as procurement policies, ITAD provider selection criteria, or domestic processing requirements), and how you plan to improve your approach over time.
Simply stating that you “take modern slavery seriously” without describing specific actions and findings does not meet the spirit of the Act and is increasingly being called out by investors and advocacy groups as insufficient.
Connecting Procurement and Disposition
A holistic approach to modern slavery risk in IT considers the entire lifecycle, from the mine to the recycling facility. Procurement decisions about what you buy and from whom affect the upstream risks. Disposition decisions about how you dispose and through whom affect the downstream risks. Both need attention.
For organisations building or refining their approach to corporate sustainability and responsible e-waste management, modern slavery due diligence is an essential component alongside environmental and data security considerations. The reputational and legal consequences of being linked to modern slavery through your IT supply chain are significant and growing.
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