Getting a Cleaning Accountability Framework certification is one of the hardest things to do in property’s anti slavery work. It’s complex, involving multiple stakeholders in a building – not an owner or contractor – and it involves private meetings with cleaners. But someone’s gotta do it.
Cbus Property recently became the first property investor and developer in Australia to have all of its 11 office buildings and shopping centres certified by the Cleaning Accountability Framework.
More than 500 cleaners will be affected by the certification, covering more than 700,000 square metres of space.
It’s not an easy certification for companies to obtain. According to Miriam Thompson, the co-chief executive of CAF, the process requires intensive, almost forensic work with a number of stakeholders.
First, it’s the building that gets certified, not the company, Thompson says ln a wide ranging interview with The Fifth Estate.
This tends to involve working with a minimu of three different companies – the owner, the building manager, the cleaning company. Sometimes you’ll need to add in a joint venture owner or tenant who might have nominated the building for certification, as Commonwealth Bank of Australia and Westpac have done.
The certification process includes an assessment of the procurement practices, she says.
So, “checking that the contract price is sufficient to pay workers, checking there’s a proper oversight mechanism at the building manager level with regards to conditions and licences and running meetings with cleaners, with no management present.
“If you’re looking at just a few signed payment slips you won’t find all the underpayment or bullying and harassment or injuries as you find when you talk to workers themselves.
“You’re dealing with humans rather than energy bills or wastewater systems. It’s quite an involved process.”
But despite the big hurdles, there are other companies and corporates prepared to enter the certification. Among them are ISPT, Mirvac, Charter Hall and even the Fair Work Ombudsman.
Why the growing interest?
Thompson says the big interest in certification around the employment of cleaners stems from the Modern Slavery Act, which requires that since 2019, companies with a consolidated revenue of more than $100 million must undertake mandatory reporting obligations.
With ESG reporting agendas also on the rise, the need to become transparent is moving companies at the top end of town to seek out CAF certification.
In 2014, when the CAF was established, working as a cleaner meant a work life likely marked by toxicity, few rights and low wages thanks to lowball contracts that did not meet fair employment standards.
“We came about because the industry had gotten so bad, Thompson tells The Fifth Estate.
“Five years ago, cleaners routinely told us that even though they were permanent employees, they were not allowed to take paid sick leave.”
“Given that 70 to 90 per cent of revenue [in cleaning businesses] is labour, if you are trying to save money by cutting contracts, it’s coming directly out of the cleaners wages,” she says.
The framework for the CAF was founded as a not for profit by AustralianSuper and the United Workers Union, which collectively realised that all stakeholders needed to be involved.
Property owners were key targets for the framework because of their primary role in the cleaning supply chain.
“You can outsource services, but you can’t outsource responsibility – investors are requiring property owners to show what they are going to do to prevent that risk – and CAF provides a very clear solution for them to demonstrate that they are doing something to address that risk,” Thompson says.
The procurement and certification process
Thompson says a key achievement of the organisation is to shine a light on the role of procurers.
“We manage to get building owners who procure cleaning services to interrogate their own procurement practices and ensure they’re not placing unreasonable demands on their suppliers.”
The framework focuses on engaging with cleaners and looking for a human connection with “quite a vulnerable workforce”.
“It’s not as simple as calling them up, ‘hey, give us an honest appraisal of your working conditions’, Thompson says.
“If you are talking about CBD locations, 99 per cent of them are international students and quite vulnerable to exploitation. It also makes them reluctant to speak up because if they do, they’ll lose their jobs or get given unfavourable shifts and poor treatment by their managers.”
Progress so far
So far CAF has certified more than 58 commercial and retail buildings and precincts, including 11 owned by Cbus Property. It’s a process that, since 2019 when it started. involved more than 4615 interactions with on site cleaners and the investigation of 772 compliance issues.
“Once the building is certified, we’re not saying that every issue has been fixed, and everyone can just sort of walk away and not do anything about it anymore.
“It’s the cleaning industry – underpayment is rife, unsustainable workloads are rife, there are a lot of unsafe working conditions, higher than almost any industry such as construction and mining. It’s a really problematic industry.”
However, what is safe to say is that certified buildings have a more transparent and accountable process in uncovering issues and remediating those issues along with ongoing compliance mechanisms, says Thompson.
“A CAF workplace is a better quality workplace than a non-CAF workplace.”

Industry trends
Thompson said the good news was that the industry – at least from what she could see – was improving. The “standards have really been raised five years into mandatory reporting.”
While companies working with the framework were initially nervous about disclosing any findings, all members Thompson had spoken to now disclose at varying levels.
“It’s really good to see how that’s changed. There’s a lot more courage and confidence to actually lay out some of the issues that have been identified and addressed.”
Human resource departments in cleaning are now beginning to invest in their own internal compliance mechanisms “because clients are asking them to open their books”.
“When we started out, we were routinely working with 30 minutes of unpaid work each shift – but now it’s closer to around 10 minutes of unpaid overtime.”
The greenwash element
However, some companies are so keen to align themselves with the level of integrity a CAF certification brings that they wrongly claim to have certification or that they are “working with” the organisation on the basis of having attended a webinar. Some are “household names” listed on the Australian Stock Exchange.
Adding to this frustration is that the Modern Slavery Act has little by way of a compliance safety net and relies on “civil society” to check performance
Thompson hopes that amendments proposed for the act, including the appointment of a national anti slavery commissioner, will offer improvement.
Portfolio certifications are next
The next phase of the organisation’s growth will be around portfolio certifications.
“We’ve done a pilot with ISPT and launching that to market in September, which will allow us to scale up significantly.”
Part of this included pre-qualifying contractors through a “deep assessment” process that includes worker engagement, including paid time meetings with cleaners and unions to “go beyond the garden variety underpayment to more serious things.” Thompson’s background in academia and policy research seems ready made for the rigorous work she’s leading now and she agrees it’s quite “forensic”.
In the past four years, the team has grown quickly from its start up days to a total of 11 staff, split between Melbourne and Sydney. Thompson suspects it will keep growing but a little more slowly now.
A brake on growth is the tough market conditions that the commercial property sector now faces.
However, last week, Thompson met with the Australian Council of Superannuation Investors, who, she says, showed interest, so the growth rate might be a little faster than expected.
