Commercial cleaning is consistently identified as one of Australia's highest-risk sectors for Modern Slavery. Wage underpayment, sham contracting, labour hire chains, and undocumented subcontractors are well-documented across the industry.
For Australian organisations required to report under the Modern Slavery Act 2018, this creates a specific procurement responsibility: knowing the cleaning contractors in your supply chain aren't a slavery risk isn't optional. It's a reporting obligation.
Australian entities with annual consolidated revenue of more than $100 million are required to lodge a Modern Slavery Statement each year with the Department of Home Affairs. Statements must:
The Act applies to over 3,000 Australian entities, and "supply chain" explicitly includes cleaning contractors, security companies, and other facilities management suppliers. For organisations below the $100M threshold, voluntary reporting is increasingly common as clients, investors, and regulators expect supply chain transparency regardless of legal obligation.
Many cleaning companies win contracts through competitive tender, then subcontract the actual cleaning work. That subcontractor may further subcontract. By the third or fourth layer, labour conditions become opaque and enforcement is essentially impossible.
Cleaning work attracts migrants, some of whom hold visa conditions that make them reluctant to report exploitation. Workers on student visas, temporary skilled visas, or irregular status are particularly vulnerable to wage theft and coercive control.
Some cleaning businesses pay workers in cash, below Award rates, with no payslips, tax, or superannuation. This is wage theft and a modern slavery risk.
Workers classified as independent contractors who have no genuine independence are legally employees. This classification is used to avoid Award rates, super, and leave entitlements.
The Fair Work Ombudsman has repeatedly prosecuted cleaning companies for these practices. They are not edge cases. They are industry patterns.
Direct employment is the highest-risk mitigation available. Each layer of subcontracting adds opacity. Look for a firm "all staff are directly employed" answer, not "primarily" or "mostly."
All cleaning workers in Australia should be covered by the Cleaning Services Award 2020 (or a registered Enterprise Agreement that provides equivalent or better conditions). Ask for the specific classification and pay rate applied to your site.
Seemingly basic, but non-compliance with super and payslip obligations is a leading indicator of broader exploitation. Ask to see a sample payslip (redacted for privacy).
This should be a standard due diligence question. Contractors with histories of FWO action represent unacceptable supply chain risk for Modern Slavery Act reporters.
Smaller operators may not yet have a formal statement but should be able to articulate their employment model and demonstrate compliance clearly.
Reputable contractors will be able to provide this. Evasive answers, vague responses, or inability to document employment practices are red flags.
Empower Clean was built around a single principle: transparent, fair employment with no room for exploitation.
Every Empower Clean team member is a direct employee. No subcontractors. No labour hire. No hidden layers. Every person cleaning your facility has a named contract, a payslip, and full Award entitlements.
All staff are paid under the Cleaning Services Award 2020 at the correct classification. Superannuation is paid in full and on time. Payslips are issued for every pay cycle.
Empower Clean specifically employs migrants and people facing systemic barriers to work. These are workers who, in other contexts, are most vulnerable to exploitation. Our model protects them with stable hours, transparent pay, and proper onboarding.
Empower Clean can provide a formal employment model statement for inclusion in your Modern Slavery documentation. We support our clients' compliance obligations, not just their cleaning requirements.
If your organisation is required to report under the Modern Slavery Act, or voluntarily reports, selecting Empower Clean removes a documented supply chain risk, provides clear evidence of supply chain due diligence, and contributes to your social procurement cleaning services story.
If your organisation is in Victoria and subject to the Social Procurement Framework, Empower Clean's social enterprise structure is built to support your obligations. Speak to us about how we can be documented in your procurement reporting.
Where this lands next depends on who is asking. Corporate sustainability teams building a defensible supplier chain will find the detail they need on corporate ESG cleaning services, while B-Corp-certified organisations qualifying a cleaning supplier against their own supply-chain standards should start with cleaning for B-Corp organisations.
Cleaning contracts are typically small relative to total procurement spend. But they represent a disproportionate Modern Slavery risk. Selecting a contractor that eliminates that risk is both the right thing to do and a demonstrably sound compliance decision.
The Act applies to entities with revenue over $100M, and those entities must assess and report on risks throughout their supply chain, including cleaning contractors.
There are currently no financial penalties for non-compliance, but the Home Affairs Minister can publicly name non-compliant entities. Reputational and commercial risk is significant, particularly for listed companies and government contractors.
Ask the six questions listed above. If your contractor cannot clearly answer whether all staff are directly employed, what Award applies, or whether they've had FWO compliance actions, that's a risk you need to document.
Yes. Contact us and we will provide an employment model statement for your supply chain documentation.
Empower Clean is Melbourne's award-rate commercial cleaning social enterprise — built for procurement teams with modern slavery, ESG, and social procurement compliance obligations.
If your organisation is seeking a cleaning partner that aligns with ESG, sustainability, or social procurement objectives, we would welcome a conversation.
Partner with us to:
