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New Zealand’s proposed Modern Slavery Bill is progressing quickly through Parliament and, if enacted, will introduce one of the most comprehensive modern slavery reporting regimes in the Asia Pacific region. While the legislation is specific to New Zealand, its implications extend well beyond its borders. Drawing on Australia’s experience while introducing several new reporting and accountability measures, the Bill reflects broader regulatory expectations around human rights due diligence and supply chain governance.
Ethixbase360 recently hosted a webinar, Understanding New Zealand’s Proposed Modern Slavery Bill: Local and Global Implications, featuring Greg Fleming, Member of Parliament and co-sponsor of the Bill, alongside Abigail McGregor (Partner) and Grace Do (Special Counsel) of Norton Rose Fulbright. Moderated by Ian Gallagher, Senior Business Development Manager at Ethixbase360, the discussion explored the proposed legislation, what distinguishes it from Australia’s framework, and the practical lessons organizations can apply as they prepare for evolving modern slavery reporting requirements.
Below are five observations from the discussion.
1. The Bill has broad political support and is moving quickly
Modern slavery legislation often takes years to move from proposal to enactment. New Zealand’s Bill is moving considerably faster.
Greg Fleming explained that he co-sponsored the Bill with Labour MP Camilla Belich, creating an unusual cross-party partnership that enabled the legislation to bypass the normal members’ ballot under Standing Order 280.
“When I first took this idea to caucus, I was almost laughed out of the room for the idea of thinking that we could work across the aisle like this.”
That cooperation, together with support from the Prime Minister, has accelerated the Bill’s progress. At the time of the webinar, Fleming expected the legislation to receive Royal Assent before Parliament rises for the September election. He also noted that lawmakers are considering a transition period of between 12 and 24 months before reporting obligations commence, giving organizations time to prepare.
2. New Zealand has built on Australia’s experience rather than simply replicating it
Rather than adopting Australia’s Modern Slavery Act as it exists today, New Zealand has used Australia’s experience to shape a more prescriptive framework.
“Our intention, right from the get go with this Bill, has been to align with where we believe Australia is going,” Fleming explained.
As Grace Do outlined, the Bill introduces several reporting requirements that do not currently exist in Australia, including disclosure of modern slavery incidents, the number of complaints received, details of training provided to employees and supply chain workers, remediation efforts linked to specific incidents and complaints, and of “known or anticipated risks” of modern slavery. Companies would also be required to publish their statements on their own websites, in addition to submitting them to a government-maintained register. On the question of parent company obligations, the Bill takes a notably broad approach – any entity that controls, directly or indirectly, an entity meeting the primary reporting criteria is itself a reporting entity.
For organisations already reporting under Australia’s Modern Slavery Act, much of the underlying compliance infrastructure such as supply chain mapping, due diligence methodologies, governance frameworks, and effectiveness measures provides a useful foundation. However, the new incident disclosure and complaints reporting requirements will likely necessitate additional internal complaint-handling pathways, clearer investigation protocols, and new processes to identify when an issue becomes a reportable “incident.”
3. Don’t let perfection delay progress
Abigail McGregor’s advice to organizations preparing for compliance was straightforward.
“There’s no absolute right way to do things… just start somewhere rather than feel a little paralysed.”
Drawing on Australia’s experience, McGregor encouraged organizations to view modern slavery compliance as an ongoing programme rather than a once a year reporting exercise. The first step is understanding where the greatest risks exist across operations and supply chains. From there, organizations can progressively strengthen governance, supplier engagement, policies, due diligence, and reporting.
She also cautioned against applying the same level of scrutiny to every supplier.
“You’re not expected to deal with every single supplier and do a deep dive in relation to every single risk.”
Instead, organizations should focus resources where the risk to people is greatest, consider how they can have the greatest impact, engage suppliers early in the contracting process, and prioritize remediation over disengagement wherever possible. As McGregor noted, working with suppliers to improve conditions often delivers better outcomes than simply ending the relationship.
4. The proposed framework shifts the focus from disclosure to accountability
Although the Bill remains a reporting regime, it introduces stronger governance and accountability measures than Australia’s current legislation.
That is reflected most clearly in the proposed director liability provisions. Asked whether those measures were intended to address criticism that Australia’s legislation lacked meaningful enforcement, Fleming’s response was unequivocal.
“Yep, that’s exactly why. One hundred percent.”
McGregor explained that directors are not expected to oversee every aspect of due diligence, but they are expected to ensure appropriate governance is in place and that reasonable steps have been taken.
“They’re not meant to be in the weeds on everything, but they need to ask the questions when they’re put on notice in relation to risk.”
Fleming also emphasized that enforcement is intended to reinforce, not replace, good governance.
“Law, by its very nature, can’t bring about culture change. What it can do is provide the backstop for non compliance.”
The Bill also includes several mechanisms designed to strengthen oversight, including a Registrar of Modern Slavery Statements, annual ministerial reporting to Parliament, oversight by the Human Rights Commission, and regular statutory reviews. Together, these measures reinforce that compliance is expected to improve over time rather than end with the publication of an annual statement.
5. Strong governance starts with acknowledging risk
Abigail McGregor challenged a common assumption about modern slavery reporting: that organizations should avoid disclosing risks wherever possible.
“If I see a modern slavery statement that says ‘we do not have any modern slavery risk’, I know this entity has absolutely no engagement with this topic because everyone has some slavery risk.”
Her point was that identifying risks or incidents should not be viewed as evidence of failure. On the contrary, it demonstrates that an organization understands its operations and supply chains and has processes in place to assess, investigate, and respond when issues arise. Increasingly, organizations are likely to be judged less by whether risks exist than by how transparently they identify, assess, manage, and remediate them.
That same principle extends to supplier relationships. Drawing on the UN Guiding Principles on Business and Human Rights, McGregor emphasized that the objective should be to improve outcomes for affected workers, not simply to remove suppliers from the supply chain.
“The goal is to work together to improve the situation… rather than just cut off a supplier because there are problems.”
Rather than automatically terminating a supplier when concerns are identified, organizations should first consider whether they have the leverage to work collaboratively with that supplier to strengthen labour practices and address the underlying issues.
Looking ahead
Although New Zealand’s proposed Modern Slavery Bill is still progressing through Parliament, it reflects a broader shift in regulatory expectations. Modern slavery reporting is becoming less about publishing a statement and more about demonstrating effective governance, risk based due diligence, and meaningful action across the supply chain.
For organizations already reporting under Australia’s Modern Slavery Act, many of the required foundations are already in place. For those beginning this work, the proposed implementation period provides an opportunity to build those capabilities before reporting becomes mandatory. Regardless of the final form of the legislation, organizations that invest now in stronger governance, supplier visibility, and risk based due diligence will be better positioned not only for New Zealand’s proposed framework, but for the continued evolution of human rights and supply chain regulation more broadly.
Watch the full webinar
To hear Greg Fleming MP, Abigail McGregor, and Grace Do explore New Zealand’s proposed Modern Slavery Bill in greater detail, including practical guidance for boards, legal teams, procurement leaders, and compliance professionals, watch the on demand webinar, Understanding New Zealand’s Proposed Modern Slavery Bill: Local and Global Implications.