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Modern Slavery
New Zealand
Director Liability
Supply Chain Due Diligence
Australia Comparison
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Named contributors
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Key observations
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Approved source
Executive Summary
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. Ethixbase360 hosted a webinar featuring Greg Fleming MP, co-sponsor of the Bill, alongside Abigail McGregor and Grace Do of Norton Rose Fulbright.
The panel's central finding: the Bill has unusual cross-party support and is moving faster than modern slavery legislation typically does, building on Australia's experience while introducing new requirements — incident disclosure, complaints reporting, and a broad parent-entity reporting obligation. The framework shifts emphasis from disclosure toward accountability, most notably through proposed director liability provisions.
Key Facts
TRANSITION PERIOD
12–24 months being considered before reporting obligations commence
LEGISLATIVE MECHANISM
Bypassed the normal members' ballot under Standing Order 280
EXPECTED TIMING
Royal Assent expected before Parliament rose for the September election
CROSS-PARTY SPONSORSHIP
Co-sponsored by Greg Fleming and Labour MP Camilla Belich
Key Observations
01
The Bill has broad political support and is moving quickly
"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."
— Greg Fleming, MP, co-sponsor of the Bill
02
New Zealand has built on Australia's experience rather than simply replicating it
"Our intention, right from the get go with this Bill, has been to align with where we believe Australia is going."
— Greg Fleming, MP, co-sponsor of the Bill
03
Don't let perfection delay progress
"There's no absolute right way to do things… just start somewhere rather than feel a little paralysed."
— Abigail McGregor, Partner, Norton Rose Fulbright
"You're not expected to deal with every single supplier and do a deep dive in relation to every single risk."
— Abigail McGregor, Partner, Norton Rose Fulbright
04
The proposed framework shifts the focus from disclosure to accountability
"Law, by its very nature, can't bring about culture change. What it can do is provide the backstop for non compliance."
— Greg Fleming, MP, co-sponsor of the Bill
"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."
— Abigail McGregor, Partner, Norton Rose Fulbright
05
Strong governance starts with acknowledging risk
"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."
— Abigail McGregor, Partner, Norton Rose Fulbright
"The goal is to work together to improve the situation… rather than just cut off a supplier because there are problems."
— Abigail McGregor, Partner, Norton Rose Fulbright
Key Concepts
- NZ Modern Slavery Bill
- New Zealand's proposed reporting regime, introducing more prescriptive requirements than Australia's Modern Slavery Act while drawing on its experience.
- Director liability provisions
- Proposed accountability measures under which directors must ensure appropriate governance is in place and ask the right questions when put on notice of risk.
- Parent/controlling-entity obligation
- Any entity that controls, directly or indirectly, an entity meeting the primary reporting criteria is itself a reporting entity.
- Incident disclosure requirement
- A new NZ-specific requirement to disclose modern slavery incidents, complaints received, and remediation efforts linked to specific incidents.
- Registrar of Modern Slavery Statements
- A proposed oversight mechanism, alongside annual ministerial reporting to Parliament and Human Rights Commission oversight.
Frequently Asked Questions
How does New Zealand's proposed Bill differ from Australia's Modern Slavery Act?
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The Bill introduces several requirements that don't currently exist in Australia, including disclosure of modern slavery incidents, the number of complaints received, training details, remediation efforts linked to specific incidents, and disclosure of known or anticipated risks. Companies would also publish statements on their own websites in addition to a government-maintained register.
Who counts as a "reporting entity" under the Bill's parent company obligations?
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The Bill takes a broad approach: any entity that controls, directly or indirectly, an entity meeting the primary reporting criteria is itself a reporting entity.
What accountability measures does the Bill introduce for directors?
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The Bill includes director liability provisions. Directors aren't expected to oversee every aspect of due diligence, but are expected to ensure appropriate governance is in place and to ask the right questions when put on notice of risk.
When is New Zealand's Modern Slavery Bill expected to take effect?
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Royal Assent was expected before Parliament rose for the September election, with lawmakers considering a transition period of 12–24 months before reporting obligations commence.
Should organizations disengage from suppliers with identified modern slavery risks?
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According to Abigail McGregor of Norton Rose Fulbright, the goal is to work together to improve the situation rather than automatically cut off a supplier because problems exist — prioritizing remediation over disengagement wherever possible.
Key Takeaways & Actions
- ✓Start with the areas of greatest risk rather than waiting for a perfect approach.
- ✓Build on existing Australian Modern Slavery Act compliance infrastructure where it already exists.
- ✓Establish clear internal complaint-handling and incident-investigation pathways ahead of new disclosure requirements.
- ✓Prioritize supplier remediation and collaboration over automatic disengagement.
- ✓Ensure directors ask the right governance questions rather than manage due diligence directly.
Citation-Ready Snippets
↗ Cite this finding
"Law, by its very nature, can't bring about culture change. What it can do is provide the backstop for non compliance." — Greg Fleming, MP, co-sponsor of New Zealand's proposed Modern Slavery Bill.
Source: ethixbase360.com/five-observations-from-our-webinar-on-new-zealands-proposed-modern-slavery-bill/
↗ Cite this finding
A modern slavery statement claiming "no risk" signals no real engagement with the topic — everyone has some slavery risk, per Abigail McGregor, Partner, Norton Rose Fulbright.
Source: ethixbase360.com/five-observations-from-our-webinar-on-new-zealands-proposed-modern-slavery-bill/
↗ Cite this finding
Under New Zealand's proposed Modern Slavery Bill, any entity that controls, directly or indirectly, an entity meeting the primary reporting criteria is itself a reporting entity.
Source: ethixbase360.com/five-observations-from-our-webinar-on-new-zealands-proposed-modern-slavery-bill/
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