Supplier Due Diligence & Responsible Sourcing
New Zealand modern slavery developments
A current-status briefing for businesses monitoring New Zealand modern slavery and supply-chain reform.
This is a Bill, not current law.
The Modern Slavery Reporting Bill 242-1 is a member's Bill before the New Zealand Parliament. Its requirements may change and should not be described as enacted obligations.
The Bill proposes a high consolidated-revenue threshold.
As introduced, the Bill would generally apply to specified New Zealand entities and overseas companies carrying on business in New Zealand where consolidated revenue for each of the two preceding accounting periods exceeds NZ$100 million. The controlling entity of a relevant group may also be within scope.
- Map the actual legal entity, group structure and controlling relationships.
- Test consolidated revenue using the relevant accounting position rather than group reputation or local sales alone.
- Confirm whether and how an overseas company carries on business in New Zealand.
The proposed statement is centred on risk, incidents and action.
The Bill proposes annual public reporting within six months after the reporting period. The statement would address modern slavery risks and incidents, steps taken, complaints and remediation. It also proposes offences, pecuniary penalties and potential director responsibility.
Strengthen controls that are useful regardless of timing.
- Map high-risk suppliers, sites, labour arrangements, products and materials.
- Define governance, escalation and board oversight for risks to people.
- Use proportionate due diligence rather than relying only on supplier declarations.
- Track corrective action, worker voice, complaints and remediation outcomes.
- Keep evidence of effectiveness and clearly distinguish confirmed facts from unresolved gaps.
Questions to ask
Focus on the decision and the evidence.
- 01
Which entity, group and operations are potentially relevant?
- 02
What is confirmed law, proposed reform or policy direction?
- 03
Which risk, supplier and remediation controls are useful regardless of timing?
Primary sources
Check the controlling material.
Recommended training
Watchdog PRO Certificate: Responsible Sourcing Professional
Build a responsible-sourcing system that separates current obligations from proposed reform and supports defensible reporting.
- Map and prioritise responsible-sourcing risk
- Assess supplier evidence and audit limitations
- Apply worker-centred corrective action and remedy
Practical support
Apply the guidance to your facts.
Identify the exact product, claim, customer journey, supplier, legal entity or process involved. Preserve the information that supports the current position, record unresolved facts, assign an owner and confirm the point at which specialist review is required.
Tell us how this issue affects your organisation and receive a tailored recommendation for the most useful next step.
Important information
Check the current position.
This resource is general information, not legal advice. Laws, official guidance and proposals can change. Do not rely on a title or summary alone to decide whether a requirement applies to a particular entity, product or activity.