Submission on the Modern Slavery Bill

Cooperative Business NZ made this submission to the Education and Workforce Select Committee on the Modern Slavery Bill.

The submission focused on how the proposed reporting regime may apply to co-operatives and mutuals, particularly member-owned structures operating through buying groups, shared-service models, and independently operated member networks.

The submission supports the intent of improving transparency regarding modern slavery risks within operations and supply chains. However, it raises concerns that aspects of the Bill may create unintended consequences for co-operatives and mutuals if the regime does not adequately recognise the distinct nature of member-owned business structures.

Submission at a glance

• Submitted by: Cooperative Business NZ 

• Date: May 2026 

• Submitted to: Education and Workforce Select Committee 

• Policy area: Modern slavery reporting and supply chain due diligence

• Format: written submission (PDF) 

CBNZ position

The submission supports the overall intent of the Bill and the importance of addressing modern slavery risks within operations and supply chains.

However, it outlines the view that co-operatives and mutuals often operate through member-owned structures that differ fundamentally from conventional corporate groups. In many co-operative models, independently owned member businesses participate in shared procurement, branding, reporting, or support arrangements without being controlled in the same manner as investor-owned corporate entities.

The submission argues that without clearer recognition of these distinctions, the Bill risks unintentionally capturing comparatively small support offices, creating disproportionate compliance obligations, and imposing reporting responsibilities on entities without direct control over member operations or supply chain activities.

Key issues addressed

• Application of the $100 million consolidated revenue threshold to co-operative and member-owned structures

• Use of accounting concepts of “control” within buying groups and shared-service co-operative models

• Risks of reporting obligations being imposed on comparatively small support offices operating within large member networks

• The importance of proportionate and practical supply chain reporting expectations where member businesses operate independently

• Alignment of reporting obligations with existing financial reporting cycles and group reporting arrangements

• The need for guidance regarding reporting obligations for activities outside an entity’s direct control

• Recognition of co-operative and mutual ownership structures within the operation of the regime

Read more submissions