Aotearoa New Zealand is currently one of the few OECD countries without modern slavery legislation. As much as $8 billion worth of goods tainted by modern slavery are imported into the country each year. This includes products from construction and retail sectors, as well as everyday items from platforms like Temu and Amazon.
New Zealand businesses are not immune to modern slavery risks, and must be equipped and supported to address the issue. Not only is it the right thing to do, but essential for businesses wanting to export, secure finance and insurance, and achieve tendering advantages in procurement.
Recently, Eco Choice Aotearoa hosted two events on the topic of modern slavery in collaboration with our partners at Edge Impact.
Our morning session brought together political representatives, legal advisors, and industry experts to help unpack the legislative landscape, assess emerging trade and compliance risks, and provide practical guidance to business leaders. Later that evening, we shifted focus with a wider audience to explore how businesses could adopt proactive leadership and build a strong business case for identifying, managing and preventing modern slavery risks in their supply chains.
Over two value-packed panel conversations, we gathered expert voices from across sectors to ask: how do we identify and mitigate risks, respond effectively, and ensure human rights and wellbeing are upheld?
1. Recognise the complex and interrelated nature of modern slavery, environmental harm, and climate change.
Modern slavery, environmental degradation, and climate risk are interconnected symptoms of the same extractive systems. Our responses must be integrated, not siloed.
You cannot credibly claim sustainability if you don’t understand your supply chain, your people, and the full extent of your impact.
There is a growing call to move from burden-shifting to shared responsibility — to work alongside suppliers rather than discard them. The goal is not to expose and punish, but to prevent harm, protect people, and support lasting change.
2. Understand your risk before you chase the chain.
Traceability is important, but only if you know what you’re looking for. Before diving into supply chain mapping, Gemma Livingston, Special Counsel at DLA Piper says, “businesses should begin by identifying their most salient risk areas”.
These risks aren’t always offshore; they can exist locally too. By focusing due diligence efforts where they matter most, your company can take a more targeted and credible approach that also aligns with global best practice. This way, you’ll be able to effectively allocate resources and avoid unnecessary supply chain mapping that may not actually reflect where the greatest vulnerabilities lie.
Gemma suggests that a robust modern slavery risk assessment should consider intersecting risk indicators, which typically fall into four categories:
- Geographic risk: Regions with weak governance, conflict, or systemic poverty that create conditions conducive to exploitation.
- Industry risk: Sectors such as agriculture, construction, hospitality, and cleaning, which often rely on low-paid, low-skilled labour.
- Business model risk: Practices that obscure accountability, including outsourcing, subcontracting, and the use of temporary or migrant workers.
- Vulnerable populations: Groups such as migrants, women, and marginalised communities who are disproportionately at risk of exploitation.
3. Ditch the 90-question SAQ for targeted feedback.
The traditional supplier self-assessment questionnaire (SAQ) is often too lengthy, vague and doesn’t focus on the right questions. As a result, suppliers see this as a literal box ticking exercise and are less likely to provide accurate information or disclose potential risks.
Instead, build a rapport with your supplier and ask fewer, more targeted questions tied to actual risk.
“For example, if you’re sourcing from high-risk labour categories, ask about recruitment practices or oversight of subcontracting – not a general ESG checklist,” explains Nicholas Dexter MBA, GAICD, Principal Consultant at Edge Impact.
“But it’s not just about asking better questions – you also need a clear interpretation framework. That means knowing how to triage responses, spot red flags, and engage your supplier in improvement plans accordingly.”
If you must use SAQs:
- Keep them short and focused
- Align them to real categories and real risks
- Explain why you’re asking – both to your own procurement team and to your suppliers (get your comms team to help here!)
- Be clear on how you’ll follow up, then follow through on that commitment
“And if you don’t have the energy or capacity to use the data meaningfully – don’t waste your suppliers’ time,” says Nick.
4. Don’t let reporting take away from the actual work.
While clear, robust reporting is a valuable part of addressing modern slavery risk, particularly when it comes to meeting legislative requirements, it should never become the sole focus.
Reporting exists to provide transparency around the real work: identifying, addressing and, mitigating risk, and remedying harm. But if you’re spending more time and resources preparing statements than you are on putting in the work, it’s time to rebalance your efforts.
Rebecca Kingi, ESG Initiatives Lead at ANZ recommends that companies look to the United Nations Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct to help guide their efforts to identify and manage modern slavery risk.
“These principles are often reflected in modern slavery legislative reporting criteria so it can set companies up for success with both modern slavery risk management and reporting.”
5. Strengthen workplace practices to prevent exploitation
Modern slavery often begins with poor or exploitative working conditions that can worsen over time. Issues like poor recruitment processes, lack of written contracts, or unsafe working conditions may seem small at first but can compound into serious exploitation if left unchecked.
As outlined in the Plan of Action by Ministry of Business, Innovation and Employment, upholding worker rights is a moral and practical safeguard that prevents exploitation from taking root in the first place.
Businesses have a responsibility to act at every stage:
- Prevent: Understand your risk areas. Build strong relationships with suppliers and labour hire companies. Prioritise ethical recruitment and employment contracts.
- Identify: Use independent, worker-informed audits and grievance mechanisms to surface issues early.
- Respond: Communicate clear expectations around rights, protections, and behaviours, and follow through with meaningful oversight and support.
6. Collaborate across sectors to drive systemic change
No organisation can tackle modern slavery on its own. This is a systemic issue that transcends borders, industries, and supply chains. To create real, lasting change, we need cross-sector collaboration.
Businesses can lead by aligning expectations across buyers and suppliers, sharing insights rather than guarding them, and creating safe, trusted channels for workers to speak up.
It also requires a culture of transparency, not just in public reporting, but in how your business operates. When organisations are honest about their risks, gaps, and progress, it opens the door to shared learning and stronger, more resilient systems. Progress isn’t driven by isolated effort, but through our shared responsibility.
Legislative Momentum Is Building
Both National and Labour have introduced bills to implement modern slavery legislation in New Zealand. These bills aim to make human rights due diligence and transparency around modern slavery risks a legal requirement for businesses.
This bipartisan support signals strong political will to regulate business conduct around human rights. Businesses that begin preparing now by mapping risks, building supplier engagement, and embedding due diligence will be far better positioned to meet future compliance expectations and public scrutiny.
Eco Choice Aotearoa’s consultancy services offer tailored sustainability advice and practical solutions to help organisations lead with integrity and impact. We support clients across key areas including waste minimisation, circular economy, emissions reduction, sustainable procurement, green building, responsible trade, and modern slavery prevention. Whether you’re starting your sustainability journey or aiming to lead your sector, our expert team can help you turn ambition into action. https://ecochoiceaotearoa.org.nz/
Resources
Here are some helpful resources that were mentioned during the event:
- Eco Choice Aotearoa’s Sustainable Procurement Toolkit
- Ethical and sustainable work practices | Employment New Zealand
- Home – Anti Slavery Australia
- Remediating Modern Slavery in Property and Construction A Practical Guide for Effective Human Right – Property Council Australia
- Due diligence and reporting | Communities and Justice NSW Government
- Responsible Contracting Project
- Responsible Sourcing Tool » Is Forced Labor Hidden in Your Global Supply Chain?
- www.chocolatescorecard.com
- Business integration of Human Rights Due Diligence in Australia: Modern Slavery and Beyond – UN Global Compact Network Australia
A massive thank you to: Our partners at Edge Impact, all of our panellists for your valuable insights, Alberts NZ and ANZ for hosting us at your wonderful spaces, Alex Kim from Content Boxfor the beautiful images.
Follow Eco Choice Aotearoa on Humanitix to find out when our next event is happening.
