New Zealand companies with annual revenue above $100 million would be required to publish annual statements on modern slavery risks and supply-chain incidents under a proposed Modern Slavery Bill.
The legislation, co-sponsored by National’s Greg Fleming and Labour’s Camilla Belich, introduces civil and criminal penalties for non-compliance and potential personal liability for directors and senior managers.
Entities covered by the bill would need to map their supply chains, identify modern slavery risks, and disclose findings in annual modern slavery statements lodged on a public register. The statements must be in a prescribed form and signed by an authorised person.
Information required includes the company’s identity, structure, operations, controlled entities, remedial actions undertaken, employee and supplier training, and the number of complaints received.
While the proposed rules are less demanding than the 2022 proposals for mandatory due diligence, the focus on transparency and accountability represents a shift toward formalised disclosure.
Entities failing to comply, or submitting false or misleading statements, could face criminal fines up to $200,000 and civil penalties of up to $600,000. The bill also introduces personal liability for directors and managers if breaches occur under their authority, or if they knew, or could reasonably be expected to have known, and failed to act.
“This will likely be a point of focus in submissions and appears contrary to the trend of other recent reforms… where personal liability provisions have been wound back,” a source noted.
The bill will use Standing Order 288, allowing automatic introduction without the usual ballot process. Sponsors aim to introduce the bill on 10 February, with a goal of enactment later in the year, ahead of the November election. No transition period has been signalled, prompting immediate action by affected companies.
The Act Party has voiced opposition, citing concerns that compliance costs could outweigh the law’s effectiveness.
Boards are advised to assign governance ownership for modern slavery risk, approve reporting plans, and ensure management can deliver the required disclosures.
Firms already reporting under Australian or UK frameworks may adapt existing statements to meet New Zealand requirements. Procurement and risk teams should accelerate supply-chain mapping, prioritising high-risk sectors and geographies. Engagement in the consultation and select committee process is expected, particularly regarding personal liability and enforcement measures.