Download the full submission here.
RIAA strongly endorses the objectives of the proposed Bill, including improving transparency, strengthening due diligence, and increasing accountability for identifying and addressing modern slavery risks across operations and supply chains. Modern slavery is not only an ethical concern but also a material business and investment risk. Companies connected to forced labour or exploitation face risks to long-term business sustainability, reputational harm and legal and regulatory scrutiny. In this context, unmanaged modern slavery risks can undermine business resilience, credibility, and access to capital.
RIAA's submission urges the Committee to support and progress the jointly sponsored Modern Slavery Bill. While our submission includes recommendations to strengthen the Bill’s clarity, workability, and implementation, we emphasise the importance of maintaining momentum on this reform and advancing the Bill through the legislative process.
Clear and effective modern slavery legislation supports institutional investors to better assess and manage these risks by improving the quality, consistency, and usefulness of information. Appropriate legislation also creates a level playing field by establishing common expectations for all businesses, supporting more consistent standards across the market.
The recommendations set out in this submission are intended to support effective implementation of the Bill in practice. They focus on promoting clarity, consistency, and a risk-based, proportionate approach, while enabling high-quality reporting and meaningful action to address modern slavery risks. We also include recommendations for the focus of the proposed statutory review under the proposed Bill, to be no later than 3 years from commencement.
RIAA’s response has been informed by the input of RIAA members. We are grateful for the strong engagement from our membership and thank those RIAA members who contributed to the development of this submission. We welcome ongoing engagement as the Bill progresses, including in the development of supporting guidance and regulations once it is enacted.
RIAA comments: Changes to the proposed Bill
Embed a clear and consistent risk-based approach throughout the framework
RIAA recommends:
- Clearer indication that assessment, prevention, mitigation, remediation, and reporting should be undertaken using a risk-based approach.
- Reinforce the importance of prioritising the most severe and most likely risks, consistent with the Bill’s due diligence framework.
- Use regulations and guidance to support a more consistent understanding of proportionate and risk-focused reporting expectations in practice.
Refine training requirements to support proportional, risk-based implementation
RIAA recommends:
- Clarify and refine section 9(2)(g)(ii) for the training requirements to be applied on a risk-based basis, consistent with our recommendations for the broader due diligence framework.
- Confirm through guidance that training provided by suppliers, or training targeted at supplier management and higher-risk exposures, can be sufficient where appropriate.
Support efficient and proportionate reporting, and minimise duplication
RIAA recommends:
- Enable consolidated or group-level reporting, where appropriate, to reduce duplication while maintaining transparency.
- Consider mechanisms for mutual recognition where equivalent reporting regimes exist, starting with Australia, to minimise unnecessary duplication across jurisdictions.
- Ensure prescribed forms and guidance to support flexibility in how information is presented, while maintaining comparability and decision-usefulness for users
Support a flexible and future-proof framework
RIAA recommends that the Committee:
- Ensure the reporting thresholds and related implementation settings are calibrated to the New Zealand context and remain capable of refinement over time.
- Support early implementation with practical guidance that promotes consistency, proportionality, and a clearer understanding of reporting expectations in practice.
- Use future statutory review processes to assess whether the framework is operating as intended and remains workable, proportionate, and fit for purpose as the regime develops: see also RIAA’s recommendations below.
RIAA comments: Committee report and implementation guidance
Support effective implementation with timely, practical, and sector-relevant guidance
RIAA recommends that the Committee, in its report:
- emphasises the importance of timely, practical, and ongoing implementation guidance as a central feature of successful implementation;
- ensures that this guidance supports both preparers and users of modern slavery statements, including investors;
- support the development of sector-specific guidance, including guidance relevant to investors and other entity types with distinct reporting contexts; and
- as a matter of priority, guidance be developed which helps reporting entities:
- to meet their core obligations, and is available sufficiently in advance of commencement; and
- to identify and respond to higher-risk sectors and exposures in a practical and consistent way.
RIAA comments: First statutory review under the proposed Bill
RIAA supports the inclusion of a statutory review no later than 3 years from commencement. It is an important mechanism to assess effectiveness, provide the ability to evaluate alignment with global developments and address any potential unintended consequences.
Strengthen the law by embedding mandatory due diligence
RIAA recommends that the Committee, in its report, refers to the first statutory review and:
- recognises that mandatory due diligence is an important element of an effective modern slavery regime, complementing disclosure requirements rather than replacing them;
- ensures the Bill more clearly situates due diligence within the overall framework, including its relationship to reporting, risk management, remediation, guidance, and enforcement;
- maintains strong compliance and enforcement settings, reflecting lessons learned from Australia that guidance and disclosure alone are not sufficient to drive meaningful change; and
- continues to draw on lessons from comparable jurisdictions, particularly Australia, while designing a New Zealand framework that is proportionate, workable, and aligned with emerging international practice.
Consider establishing an independent Anti-Slavery Commissioner
RIAA recommends that the Committee, in its report, refers to the first statutory review and:
- recognises the potential to establish an independent Anti-Slavery Commissioner to address modern slavery and support the effectiveness of New Zealand combatting modern slavery risk.
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