According to human rights group Walk Free, the 2021 Global Estimates indicate there are 49.6 million people living in situations of modern slavery on any given day: forced labour accounting for 27.6 million. The demand for transparency, fair working conditions and supply chain maintenance within large-scale organisations has never been higher.
In New Zealand, new modern slavery legislation was proposed in July to improve transparency and accountability standards. The law would create a public register on modern slavery, with companies required to report exploitation risks in their operations and supply chains, along with how they’re addressing those risks.
It’s likely the New Zealand law will be modelled on Australia’s Modern Slavery Act, under which a similar regime was introduced in 2019, while also incorporating lessons from that law’s implementation. For example, a recent review found that a lack of clear guidance on reporting was causing frustration for Australian businesses. As a result, companies should expect more detailed guidance to be included in the New Zealand law.
Another place the two nations’ legislation will differ is in the size of the companies affected. While the Australian regime has an AU $100m revenue threshold, in New Zealand the suggested threshold is just NZ $20m. The aim, said New Zealand’s Deputy Prime Minister Carmel
Sepuloni, is to “strike an appropriate balance, by encouraging those most able to influence their more extensive supply chains, and not overburdening small businesses”.
While the public register may be a while away, it’s a good idea for businesses – especially those with large or complex supply chains – to start preparing for compliance now. A large company with extensive overseas operations may already be issuing modern slavery disclosures, on which its NZ reporting can be based. Bunzl, for example, publishes an annual Modern Slavery and Human Trafficking Statement covering all aspects of its multinational operations. Other companies, however, will need to create a reporting regime from scratch. To avoid being caught flat-footed by the new law, they can start getting ready by mapping their supply chain and identifying at-risk suppliers by implementing initiatives such as supplier surveys.
Businesses can also introduce contractual requirements that see suppliers complying with relevant modern slavery laws, as well as bringing in staff training on modern slavery risk and mitigation. The key is to not put off taking positive steps until legally obliged to do so. The sooner that all businesses address the problem, the sooner the scourge of modern slavery can be eradicated.
