What is New Zealand's proposed Modern Slavery Bill and how did it progress through Parliament?

New Zealand's proposed Modern Slavery Bill has bipartisan support and passed its first reading in Parliament. It was co-sponsored by Greg Fleming MP (ACT Party) and Camilla Belich MP (Labour), creating a cross-party partnership that enabled the legislation to bypass the standard members' ballot under Standing Order 280. The bipartisan approach and Prime Ministerial support have accelerated the Bill's progress significantly. The proposed regime is broadly aligned with Australia's Modern Slavery Act framework but introduces more prescriptive reporting obligations and potential penalties for non-compliance.

How does the NZ Modern Slavery Bill compare with Australia's existing framework?

The NZ Modern Slavery Bill is broadly aligned with Australia's existing Modern Slavery Act framework but goes further in several areas. It introduces more prescriptive reporting obligations specifying what must be included in modern slavery statements in more detail than Australia currently requires. It adds potential personal liability for directors and those involved in preparing statements that are misleading, or where a statement is not filed or made available. It also introduces a dual reporting obligation that sits with both the New Zealand entity and its ultimate parent company in relation to the entire group, regardless of where that parent is domiciled. Australia's Act in its current form does not impose equivalent personal liability or equivalent parent-company group reporting obligations.

What is the revenue threshold for reporting under the NZ Modern Slavery Bill and who does it apply to?

The obligation to report applies to New Zealand entities (and their ultimate parent companies) carrying on business in New Zealand with consolidated revenue of NZD 100 million or more. In other major currency equivalents, the threshold is approximately USD 56 million, GBP 42 million, EUR 50 million, or AUD 80 million. The obligation applies not only to New Zealand-based entities, it will also be particularly relevant for all banks and insurers operating in New Zealand via a branch mechanism, organisations doing business with large businesses in New Zealand, and investors in New Zealand. The dual obligation means that where an NZ entity meets the threshold, the reporting obligation also falls on its global ultimate parent, wherever that parent is domiciled.

What personal liability provisions does the NZ Modern Slavery Bill introduce for directors?

The NZ Modern Slavery Bill introduces personal liability for directors and those involved in preparing modern slavery statements that are misleading, or where a statement is not filed or made available as required. This goes beyond the reporting obligations in Australia's existing Modern Slavery Act, which does not currently impose personal liability on individual directors or statement preparers. For global boards with New Zealand-connected entities, this provision means that NZ modern slavery compliance cannot be treated solely as a corporate reporting exercise, it creates individual accountability for those overseeing and preparing disclosures.

What practical steps should organisations take now to prepare for the NZ Modern Slavery Bill?

Organisations should: determine whether any entities in their group carry on business in New Zealand and whether consolidated group revenue meets or is likely to meet the NZD 100 million threshold; identify who the global ultimate parent entity is for NZ reporting purposes, as the dual obligation means that parent will also be in scope; assess whether existing modern slavery reporting programmes (including Australian MSA statements) would satisfy the NZ Bill's more prescriptive content requirements, or whether gap-filling is needed; review director and governance accountability frameworks to understand who would be personally liable for misleading statements or non-filing; and begin building or strengthening supply chain risk assessment and due diligence processes that can generate the evidence a more prescriptive regime will require, rather than waiting for enactment.

Home » Resources » Between Two Powers: What US-China Tensions Mean for Your Third-Party Due Diligence

Between Two Powers: What US-China Tensions Mean for Your Third-Party Due Diligence

Amanda Ong
October 14, 2026

Between Two Powers: What US-China Tensions Mean for Your Third-Party Due Diligence
Wednesday, 12 November 2026 | 9:00 AM SGT / 12:00 PM AEDT
In conversation with Robinson White

Escalating tensions between the US and China are creating increasingly complex compliance challenges for organisations with China-linked operations, suppliers and business partners. US sanctions and China’s counter-sanctions framework can create conflicting legal obligations, while restrictions on access to information and in-country investigations can make effective third-party due diligence more difficult.
How should organisations navigate these competing requirements, identify emerging risks and make defensible decisions when the regulatory landscape continues to change?
Join Tim Robinson and Michael White of Robinson White for a practical discussion drawing on their experience managing large-scale third-party risk programmes at BHP, Orica and Woodside. They will explore how geopolitical developments are changing third-party risk exposure and what compliance teams can do to strengthen their due diligence, monitoring and response processes.

Webinar Highlights
Understanding the impact of US-China tensions on third-party risk: How US sanctions, China’s Anti-Foreign Sanctions Law and related countermeasures can create competing compliance pressures for multinational organisations.
Adapting due diligence to an increasingly complex environment: How to identify exposure through ownership structures, state-linked entities and strategically sensitive sectors, and navigate the challenges of verifying information and conducting investigations in China.
Building a defensible approach to ongoing monitoring and risk management: How to identify changes in sanctions and regulatory restrictions, reassess third-party exposure, escalate potential conflicts and document decisions.

Who Should Join
This session is designed for compliance, legal, risk and procurement professionals in resources, extractives and other sectors with significant China exposure, particularly those responsible for third-party due diligence, sanctions compliance and supply chain risk management.

Speakers

Tim Robinson | Principal, Robinson White
Tim spent over a decade leading compliance and third-party risk functions at BHP and Orica, where he managed large-scale programmes across complex, multinational operations. He now advises organisations on third-party risk management, compliance programme design, and regulatory response.
Michael White | Principal, Robinson White
Michael held senior compliance and risk roles at BHP and Woodside, with direct responsibility for third-party due diligence across supply chains with significant China and Asia-Pacific exposure. He advises clients on practical risk management in high-stakes regulatory environments.
Ian Gallagher | Senior Business Development Manager, Ethixbase360
Martin Money | Managing Director, APAC, Ethixbase360

compliance, Ethixbase360, riskmanagement, supply chain, Third Party Risk Management

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Between Two Powers: What US-China Tensions Mean for Your Third-Party Due Diligence

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