The GRS (Guidance on Reasonable Steps to Manage Modern Slavery Risks) is a risk management framework developed by the Office of the NSW Anti-Slavery Commissioner to help organisations identify, assess and address modern slavery risks in their operations and supply chains.
What Is the GRS?
The GRS is part of a broader framework designed to support entities — especially those legally required under New South Wales (NSW) law — to take “reasonable steps” to prevent modern slavery in their activities and procurement practices. It offers clear guidance, tools, and expectations to embed due diligence into organisational systems.
At the core, the GRS encourages organisations to operate responsibly and transparently, ensuring their goods and services are not produced through modern slavery.
Main Points of the GRS
1. Focus on Modern Slavery Risk Management
The GRS emphasises the development of a Modern Slavery Risk Management Plan — a documented approach to put a modern slavery policy into action. This plan helps organisations systematically manage and mitigate risks that could cause or contribute to modern slavery.
2. Salient Risks — What Matters Most
Organisations should prioritise risks based on their impact on people, not just business concerns. Salient risks are assessed by: Scale (severity of harm); Scope (number of people affected) and Irremediability (difficulty of fixing harms).
3. Seven “Reasonable Steps”
The GRS outlines a series of steps organisations should take to build effective modern slavery risk systems, including:
• Commit — Adopt a modern slavery policy.
• Plan — Map and assess risks.
• Source — Embed safeguards into procurement.
• Manage — Monitor and improve supplier performance.
• Remedy — Address harms and provide grievance options.
• Report — Share progress internally and externally.
• Improve — Continuously enhance practices.
4. Integration with Operations and Reporting
The guidance links risk planning and actions to existing organisational structures, ensuring that risk management is part of routine governance, procurement, and reporting cycles.
Who Is the GRS For?
The GRS is designed primarily for covered entities under NSW law — especially government agencies and organisations with modern slavery due diligence or reporting obligations. More than 400 public bodies in NSW are affected.
However, the guidance is also useful for any organisation (public or private) wanting to align with best practices in modern slavery risk management and responsible supply chain governance.
Why It Matters?
Modern slavery remains a serious human rights abuse — including forced labour, debt bondage, and human trafficking. The GRS provides a practical, structured way for organisations to prevent, identify, and respond to these risks within their operations and supply chains.
By following its steps and developing a robust risk management plan, organisations can protect vulnerable workers, improve ethical standards, meet legal obligations, and build trust with stakeholders.
If you’re interested in learning more or need support aligning your organisation with the GRS, our team is ready to assist!
