In a supermarket aisle in Auckland today, you can find two bags of sugar sitting side-by-side. One brand provides a detailed, audited trail of its labor practices because it is governed by Australian law. The other remains a “black box” because New Zealand law currently gives consumers no way to know how the workers who produced it were treated.
The Ethical Transparency Alliance (ETA) has officially submitted our recommendations on the Modern Slavery Bill (242-1) to the Education and Workforce Select Committee. While we strongly support this bipartisan leadership, our message is clear: New Zealand must design this law for 2027, not 2015.
The “Tick-Box” Trap
For too long, international modern slavery registers have become “document graveyards”—repositories of unstructured PDF files that are difficult to search, compare, or analyze at scale. Australia’s own statutory review found that these long-form documents often resemble a “tick-box” exercise with limited evidence of meaningful change for victims.
We are advocating for a digital-first approach. The single most important amendment the Committee can make is to require modern slavery statements to be submitted in a structured, machine-readable format.
Why Structure Matters
A register full of PDFs is of limited practical value. By mandating structured data, New Zealand can empower:
- Researchers and Journalists: To instantly compare corporate responses across entire industries using automated analysis.
- Civil Society: To search the register by specific risk types, commodities, or geographies rather than downloading thousands of individual documents.
- Consumers: To eventually see this data directly at the point of sale.
The 2027 Convergence
Our advocacy for this Bill is directly linked to our technical work with GS1 global barcode standards. We are currently in the midst of “GS1 Sunrise 2027″— a global transition where traditional 1D barcodes are being replaced by 2D barcodes (QR codes) capable of carrying rich, structured data.
The ETA has formally proposed a dedicated “Ethics” LinkType for the GS1 Digital Link vocabulary. If the Modern Slavery Act requires structured digital reporting, it creates a direct pathway for that information to be linked to the product itself.
Imagine scanning a product in 2027 and seeing not just the price, but a verified, machine-readable signal of the brand’s commitment to labor rights and slave-free supply chains.
Our Key Recommendations
In our submission, we called for five critical changes to the Bill:
- Mandatory Machine-Readable Formats: Moving beyond PDFs to structured data schemas.
- Lowering the Threshold: Phasing the revenue threshold down from $100M to $50M to capture more high-risk supply chains.
- A Mandatory Commissioner: Establishing an independent Anti-Slavery Commissioner to drive reporting quality.
- Stronger Victim Protections: Including safe-harbor and immigration protections for those who report exploitation.
- Product-Level Transparency: Ensuring reporting eventually feeds into global digital product transparency systems.
The Bottom Line
New Zealand is one of the last developed nations to enact modern slavery reporting. We have a unique opportunity to learn from the mistakes of others and build a system that is not just a repository of promises, but a tool for genuine accountability.
It is time to make the human story behind every product visible.
Read our full submission to the Select Committee here.