Travel Sellers Below Australia's $100m Reporting Line Join Anti-Slavery Push

Australian travel companies earning well under the $100 million reporting threshold are signing up to the ATIA Modern Slavery Collaboration — a compliance and supply-chain risk program they don't legally have to join.

The numbers tell the story. Only businesses with annual consolidated revenue above $100 million must report on modern slavery risks in their international supply chains under Australian law. Yet ATIA (the Australian Travel Industry Association, the country's peak travel trade body) says a growing share of members below that line are engaging anyway.

The programme builds on an industry-first consortium established by Intrepid Travel and Flight Centre in July 2023. It now sits under Project A30, ATIA's broader member support commitment.

What do members actually get?

The Collaboration offers four practical components:

• Compliance support for larger members facing mandatory reporting
• Shared learning between large and small operators
• Curated toolkits plus regulatory updates from Australia, New Zealand, the United States and Europe
• A members' forum run under clear competition law guidelines — the legal guardrail that lets rivals discuss risk without breaching antitrust rules

At its most recent meeting this month, members heard from Gary Shaw, a former New Zealand Police detective who investigated human trafficking undercover across 12 countries. Shaw spoke on risks specific to travel, tourism and adjacent sectors, and fielded questions on continuous improvement and collaboration.

Who else has presented?

The speaker roster reads like a supply-chain audit shortlist: the Blue Dragon Children's Foundation in Vietnam, the International Centre for Missing and Exploited Children (ICMEC) Australia, the Australian Red Cross Support for Trafficked People Program, Accor director of sustainability David Young, and University of Tasmania researchers.

The Office of the Australian Anti-Slavery Commissioner has also taken notice. Its guide, Maximising Impact: A guide to business collaboration resources, features the Collaboration as an example of collective action helping travel businesses share knowledge, assess supply-chain risks and strengthen prevention and reporting.

Why are sub-threshold sellers bothering?

ATIA director of public policy and advocacy Ingrid Fraser framed it as commercial reality, not charity. Travel businesses were taking on the issue because they wanted to lead and travellers expected it, she said.

"Larger entities have to report. Many others do not, but they are taking steps anyway. They deserve credit, and they should not have to work it out alone in complex international supply networks," Fraser said.

"We work directly with members and subject matter experts on the practical side: how you identify risk, assess it and act when you find it. Our pathways work whether you are lodging a statement or starting from scratch."

Project manager Robin Mellon said the value came from experts like Shaw, who has "worked these cases on the ground," and from members trading what actually works.

"That builds capability across the industry," Mellon said. "Travel is confronting one of the largest challenges it has faced, and the openness that participating members bring to the table is invaluable. They talk candidly about what is working and where they need help, and that honesty lifts every business in the room."

For travel sellers, the calculation is straightforward: buyer expectations on human rights are arriving faster than legislation. Voluntary engagement now is cheaper than retrofitting compliance later.

Expect the Collaboration's membership to keep widening as corporate clients and regulators push the same question down the supply chain.