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Student exploitation and modern slavery on student placement

Overview 

Exploitation and modern slavery may occur on student placements, particularly in unpaid placements where initially agreed conditions shift to an employment relationship that becomes exploitative. 

Key points

  • Modern slavery sits on the extreme end of a continuum of exploitative practices, including deceptive recruitment, trafficking, debt bondage, forced labour and forced marriage.
  • A student may experience exploitation before it becomes extreme enough to be considered modern slavery.
  • Ensure when arranging a placement that the placement provider clearly understands the expected work and learning activities the student will complete, the number of hours/days and the time of day the student will be at their workplace, and the requirement of a placement being a learning experience.
  • Legislation relating to workplaces in Australia is administered by the Fair Work Ombudsman, specifically they help us identify what is a placement and when an experience might transition into an employee relationship.
  • We are responsible to monitor placement conditions and take action where variation may lead to exploitation or the placement transitioning into a work relationship.

Fair Work have identified the following indicators to help us identify where a placement has changed into a work relationship:

  • What was agreed to? The Student Placement Agreements (SPA) signed by the placement provider outlines the basic parameters of the placement that the Site agreed to. In addition to the SPA, the placement-specific communications issued to a Site prior to a student commencing a placement detail the specific activities the student is expected to undertake, the learning outcomes, the hours/days and time of day, and any other expectations related to each placement. These communications ensure a clear understanding of what is considered suitable for our students to undertake during placement. If the student is asked to perform activities outside of those agreed through the SPA and detailed in the placement-specific communications, then the situation may have transitioned to an employment relationship or be considered exploitative.
  • What was the reason for the arrangement? Placement activities organised and approved by the University are for the purpose of meeting learning and educational outcomes, usually associated with for-credit coursework. Other arrangements are possible, but require specific approval and monitoring, and are more likely to meet the definition of an employment relationship under the Fair Work Act. 
  • How much time was agreed to be a student placement? SPAs and / or placement-specific communications should clearly define the date range, days of the week, time of day and expected total hours for each placement. A placement that exceeds agreed parameters may be considered exploitative or to have transitioned to an employment relationship.
  • How important was the work to the business? Activities undertaken on placement should not place core-business responsibilities solely on a student for independent completion. Where this is to occur, the relationship has likely transitioned to meet requirements for employment or would be considered exploitative. 
  • What activities is the student undertaking? The more productive work a student undertakes, the more likely it is the student is should legally be considered an employee, with appropriate remuneration under the Fair Work Act. Where this occurs, the student needs to be compensated for productive work completed outside activities directly related to their learning outcomes.
  • Who's getting the benefit? While the Site may benefit from activities undertaken by a student, the primary beneficiary from the experience should be the student. We support this by ensuring placement providers understand that student activities should always align to learning outcomes. If this dynamic shifts, then the experience has likely either become exploitative or could be considered as not lawfully being a placement but should be an employment relationship.
  • Does the student have a contract directly with the Site? Where a student is asked to sign a contract directly with the Site organisation, this creates a legal relationship between the student and the Site organisation.  Our SPAs require a Site to inform the University if a contract is to be established between the student and Site.  Any contract a student is to sign with a Site organisation needs to be reviewed to determine the nature of the relationship and whether an employment relationship is being established.

For more information see the Fair Work Ombudsman page Work experience and internships.

Modern slavery is an umbrella term that describes situations where someone is being tricked, forced or controlled into exploitation and they cannot leave without consequences. These practices include deceptive recruitment, trafficking, debt bondage, forced labour and forced marriage. Modern slavery is on the extreme end of a continuum of exploitative practices. The continuum ranges from fair work, to exploitation and then to modern slavery at the extreme end.

Young people, including students, can be at a heightened risk of experiencing modern slavery both in Australia and overseas. Students could be at risk of exploitation during placement, especially international students and those who have fewer immediate support networks, lower English language proficiency, or are unaware of the workforce laws in Australia.

Some signs/indicators of modern slavery during placement

Student is forced / coerced / deceived into:

  • Undertaking activities reasonably considered outside appropriate placement experiences or unrelated to their learning goals (e.g., menial tasks not aligned to professional expectations);

  • Performing activities outside university-approved hours which may be excessive (e.g., attending placement for 12 hours / day);

  • Placement has transitioned into an employment arrangement.

Coercion may occur via many methods, some relevant to placement may include:

  • Student may be threatened with Placement failure;

  • Student may be threatened with having their visa revoked;

  • A student’s passport, identity documentation or mobile phones may be confiscated;

 

A student may feel trapped in a situation of exploitation due to threats, force, or other violence.

What do I do if I am concerned a placement is a form of Modern Slavery?

A student may experience mental health or physical health issues as a result of exploitation, which are indicators of potential modern slavery. If you are unsure, email the Modern Slavery Unit at [email protected]. For immediate student support, contact Student Wellbeing at [email protected]

Modern slavery is considered a critical incident by the University. Please follow the incident on placement process if you suspect a student has been exposed to modern slavery during placement.

To ensure students are safeguarded from modern slavery, please ensure that the  minimum due diligence requirements are met before a student starts their placement. These include:

  • Activities the student will be completing while on a placement will support a student to achieve the learning outcomes of the unit of study they will be enrolled in. This confirms that a placement is indeed for the purpose of learning.
  • The number of hours of the placement align with what has been approved for the unit of study (detailed in the Unit Outline in the Handbook) and that these hours are communicated to and agreed to by the Site.  Communication of the days a student will be on placement, time of the day they will be in the workplace, and any other expectations should also occur to ensure a Site is clear on when they can expect a student to be with them. 
  • A fully executed Student Placement Agreement (SPA) must be in place (which must include modern slavery clauses). Parties signing a SPA are confirming that they will not knowingly participate in or support modern slavery practices.
  • All students must be provided with the link to, and are encouraged to complete, the online Anti-Slavery Awareness Module before placement begins.
  • Consider sharing the University’s Modern Slavery Policy with the student placement provider to support a provider to understand our expectations.
  • Monitor and check-in with the student on placement (e.g. complete mid-placement check-in). Provide a safe space for the student to have open and transparent discussions with you about placement issues.

While on placement, students themselves may be at risk of exploitation but may also sometimes encounter people (e.g., staff or clients) who may be in situations of modern slavery. For example, if a student is completing a hospital placement where victim-survivors commonly present.

Students under duress, either from having directly experienced exploitation or having been exposed second or third hand, should be encouraged to share concerns with Student Wellbeing

If a student approaches you with concerns, the Modern Slavery Unit (MSU) can provide guidance in these situations. Email [email protected] or complete the online reporting form. Please note the Modern Slavery Unit will respond to you within 72 hours

Exploitation on Work integrated Learning Placement – Example One

Scenario

Sophie is a final-year veterinary science student completing a clinical placement at a large veterinary hospital. The placement is intended to provide supervised learning and practical experience.

Sophie is scheduled for multiple night shifts and weekend work, often exceeding 60 hours per week—far beyond the agreed placement requirements. Night shifts often involve working alone in high-pressure emergency situations without adequate supervision. Sophie is exhausted and makes mistakes, increasing risk to animal welfare and her own safety.

Despite performing duties equivalent to paid staff —such as assisting in surgeries and managing emergency cases— and working more than her placement hours, Sophie receives no remuneration. She is reminded that “students don’t get paid.”

When Sophie raises concerns about fatigue and wellbeing, the supervisor warns that negative feedback could affect her final grade and future employment prospects as she is “not a team player”. She is told this is “essential for real-world experience” and that refusing could jeopardize her assessment.

Sophie feels she cannot speak up due to fear of academic repercussions and lack of clarity about her workplace rights.

 

Exploitation on Work integrated Learning Placement – Example Two

Scenario

Jenny is a student currently completing her placement as part of her pre-registration course at the Sydney Nursing School. She is placed at a NSW public hospital in the women and maternal health ward. Several weeks into her placement, Jenny is assisting a patient who has presented with breathing difficulties, weight loss and untreated TB. Jenny observes that the patient speaks no English, appears anxious, withdrawn and flinches when Jenny checks her vitals. Jenny notices bruises and scars on her arms and hands.

Jenny and the patient are from a similar background and luckily, can speak the same dialect. She learns that the patient has had their personal movements restricted and documentation confiscated. The patient explains her back breaking work as a domestic help doing cleaning, cooking and taking children to and from school. She is receiving no pay, as she is paying off her ‘sponsoring and travel fees’ to the family she is working for. She informed Jenny she hasn’t had a day off for about 8 months since she arrived in Australia.

Jenny had previously completed the University’s Anti-Slavery Awareness training module for students. Jenny recognises the patient could be experiencing modern slavery. Jenny informs her supervisor and together they assist the client to access appropriate support. Thanks to the training she has undertaken, Jenny has assisted a potential victim of modern slavery.

In this situation, the patient is experiencing indicators of modern slavery including:

  • Health issues requiring hospital treatment which may have resulted from her exploitation;

  • Those from overseas or on temporary visas are at heightened risk of modern slavery due to language and cultural barriers and limited knowledge of Australian work rights;

  • Travel documents confiscated;

  • Unpaid wages;

  • Working excessive hours;

  • Paying off a debt, in the form of ‘sponsoring and travel fees’ as a way to keep the individual working for the family; and

    movements controlled and freedom restricted.

If you notice students themselves experiencing any of the above signs or indicators, you should follow the critical incident on placement process .

Resources

Content reviewed by the Inclusion and Disability team on November 2025.