Submissions

The Institute of Directors regularly submits on legislative, regulatory and policy changes relevant to directors and governance. Submissions are archived here for your browsing.

2019 submissions

Submission on the Productivity Commission’s draft report into local government funding and financing
We strongly endorse the Commission’s recommendations in the draft report to help build governance and financial capability. We support the Commission highlighting that the IoD has a ranges of resources and services that can assist elected members and we welcome the opportunity to help improve governance and financial capability in local government. We encourage elected members’ ongoing professional development including membership of the IoD. There is also an opportunity when appointing new members of audit and risk committees to include IoD Chartered Members.

Read the submission on the Productivity Commission’s draft report into local government funding and financing


Submission on Phase 2 of the Reserve Bank Act Review - Consultation 2
The IoD’s submission comments on the current director attestation regime. We support the ‘enhanced status quo’ option in the consultation document to improve the attestation regime, including increased supervisory engagement by the Reserve Bank. This should be done in a manner that encourages high quality directors to remain involved in the sector and which includes a process to audit or verify attestations by the Reserve Bank. The submission also addresses some aspects of the Reserve Bank’s governance arrangements and identifies opportunities to strengthen director professionalism with reference to IoD’s Chartered Membership pathway. 

Read the submission on Phase 2 of the Reserve Bank Act Review - Consultation 2


Submission on the Climate Change Response (Zero Carbon) Amendment Bill
The IoD generally supports the introduction of the Bill and the 2050 target and emissions budgets. We also support the establishment of a permanent Climate Change Commission, and we suggest that the Minister for Climate Change should be required to ensure that the board has sufficient governance capability to lead and oversee the Commission. We agree with the decision not to require mandatory climate-related disclosure in the Bill for organisations, and we support the introduction of other adaptation provisions to help address the impacts of climate change.

Read the submission on the Climate Change Response (Zero Carbon) Amendment Bill


Submission on the Credit Contracts Legislation Amendment Bill
We support the intent of the Bill and the need to protect vulnerable consumers from irresponsible lending practices and problem debt. However, we are very concerned about the adverse impact that the Bill will have on responsible lenders and directors, and potential unintended consequences for vulnerable consumers. As currently drafted, the Bill places a disproportionate burden on responsible lenders, excessive penalties and damages, and an unreasonable prohibition on indemnities and insurance. The potential adverse effects of amendments in the Bill include increased compliance costs and insurance premiums, boards becoming more risk averse, and the possibility of deterring directors from serving on boards of lenders.

Read the submission on the Credit Contracts Legislation Amendment Bill


Feedback on Capital Markets Review
The purpose of the review is to deliver a ten-year vision and growth agenda for the sector with more people and companies involved in capital markets to build opportunity and wealth for New Zealanders. The IoD welcomes the review and our feedback focuses on the following matters:

  • disclosure obligations for listed entities
  • short-termism
  • the balance of risk between investors, issuers, directors and other stakeholders involved in capital markets
  • Directors & Officers insurance and
  • facilitating access to talent.


Read the feedback on Capital Markets Review


Submission on conduct of financial institutions options paper
We support the Ministry of Business, Innovation and Employment reviewing options for improving culture and conduct in financial institutions in New Zealand.  However, we are concerned about the scope of the proposed duties on financial institutions and directors in the options paper. These need to be carefully considered and imposed only to the extent necessary. The IoD also strongly opposes the introduction of director personal liability where an entity breaches a duty as this is a disproportionate response to the issues identified. This proposal has the potential to seriously undermine the overall strength of corporate governance in New Zealand and may have adverse effects and unintended consequences, including deterring qualified and experienced directors from serving on boards of financial institutions.

Read the submission on conduct of financial institutions options paper


IoD submission on Extended External Reporting Assurance
Extended External Reporting (EER) using a range of frameworks (eg Integrated Reporting) is gaining significant global traction and increasing take-up in New Zealand. This take-up reflects the importance and value that more holistic reporting brings to organisations and to stakeholders. It also supports better governance and enhanced accountability. We support the development of IAASB guidance that will help enable more consistent and appropriate application of ISAE 3000 (Revised)  Assurance Engagements Other than Audits or Reviews of Historical Financial Information.

Read the submission on Extended External Reporting Assurance


Submission on the technological change and the future of work
The New Zealand Productivity Commission’s issues paper on technological change and the future of work raises a number of challenges that need to be considered and we strongly support the work being done by in this area. Boards play a critical role in leading and overseeing the transition into new ways of working to maintain long-term business sustainability. The future of work is one of IoD’s top 5 issues for directors in 2019 and was a key theme for our membership this year featuring at IoD events and in our publications.

Read the submission on the future of work


Submission on modernising the Charities Act
The IoD welcomes the discussion document on modernising the Charities Act and we view this as an opportunity to help raise the standards of governance in charities. We can see considerable benefit in introducing governance standards through a specific governance code for the charitable/not-for-profit sector that is fit for purpose and value adding. A key challenge will be to balance raising standards without burdening organisations and deterring people from getting involved in leadership. We also support the Department looking at options to strengthen who can be officers of charities, and we consider that there is merit in creating a new reporting tier with simpler reporting requirements for the smallest charities.

Read the submission on modernising the Charities Act


Submission on the report by the Tomorrow’s Schools Independent Taskforce
The Taskforce’s report recommends a number of significant changes to the New Zealand schooling system, including in relation to school boards. Many IoD members are (or have been) trustees on school boards and we conducted a survey of our members to seek their feedback on how the current governance model is working and the recommended changes. Their feedback helps inform our submission which highlights concerns with the report and governance-related recommendations. We have suggested measures the Government should consider in improving boards and addressing issues and challenges.

Read the submission on the report by the Tomorrow’s Schools Independent Taskforce 


Submission on the Reform of Vocational Education
The IoD supports the Government reviewing the Vocational Education system to ensure it is fit for purpose and can respond to the challenges of the future. However, we highlight in our submission concerns with the review and some governance-related proposed changes.  

Read the submission on the Reform of Vocational Education


Submission on Phase 2 of the Reserve Bank Act Review
The IoD’s submission on the review focuses on how the Reserve Bank should be governed. We support a shift away from the Reserve Bank single decision maker model to a governing board. It is essential that there is a balanced board of highly capable and professional directors with the right mix of knowledge, skills and experience. It is also critical that there is a transparent and robust board appointment (and reappointment) process based on high quality analysis.

Read the submission on the review

2018 submissions

Submission on the review of the Protected Disclosures Act 2000
The IoD welcomes the review of the Act to ensure it is fit-for-purpose and meets international best practice standards. We support the overall intent of the review, but we are very concerned that small and medium sized organisations will be disproportionately burdened by some of the proposals for reform.

Read the submission on the review


Submission on draft NZX Guidance Notes
NZX consulted on new and updated draft Guidance Notes to support the revised NZX Listing Rules. The IoD’s submission mainly focuses on the Guidance Note on continuous disclosure. We suggested some improvements in relation to guidance on constructive knowledge and also urged caution with respect to hindsight bias. We also commented on the new Guidance Note on governance. 

Read the submission to NZX on the draft Guidance Notes


Submission to the Tax Working Group on the proposal to introduce director personal liability for PAYE and GST debts of companies
The IoD strongly opposes the proposal to introduce director personal liability for PAYE and GST debts of companies in our submission. The prospect of director personal liability for company taxes is deeply troubling and may have far-reaching and unintended consequences outweighing any potential benefits.

Read the submission to the Tax Working Group


Submission on the reform of the State Sector Act 1988
Given that the State Sector Act is now 30 years old, the Government has initiated a review to ensure it is fit for purpose and meets the needs of a modern Public Service. The IoD’s submission focuses on governance related matters in the discussion document and, in particular, where Crown entity boards may be affected.

Read the submission on the reform of the State Sector Act 1988


How schedular payment rules apply to non-resident directors’ fees
Inland Revenue consulted on a draft interpretation statement on withholding tax on fees paid to non-resident directors. This is expected to be the last in a series of interpretation statements relating to directors’ fees. The IoD’s submission raises some areas where further guidance would be helpful.

Read the submission on how schedular payment rules apply to non-resident directors’ fees


Companies (Clarification of Dividend Rules in Companies) Amendment Bill
The IoD supports the Bill which will introduce a minor and technical amendment to the Companies Act 1993 to clarify that profits can be distributed differently across the same class of shares if this is set out in a company’s constitution.

Read the submission on clarification of dividend rules in companies


Submission on increasing the transparency of beneficial ownership of companies and limited partnerships
The IoD is supportive of measures in New Zealand to combat the misuse of corporate entities by criminals, and recognises the importance of law enforcement agencies being able to access beneficial ownership information of corporate entities. However, we consider a public beneficial ownership register is not a proportionate and appropriate response to MBIE’s concerns. 

Read the submission on increasing the transparency of beneficial ownership of companies and limited partnerships


Submission on publishing directors’ residential addresses
The IoD strongly advocates that company directors should be able to publish a service address rather than their residential address for the purposes of the Companies Act 1993. We set out our reasons for this in our submission and discuss related issues.

Read the submission on publishing directors’ residential addresses


Submission on the review of the ASX Corporate Governance Council’s Principles and Recommendations
The IoD welcomes the review and the updating of the Principles and Recommendations to ensure that they are current, effective for good corporate governance reporting, and aligned with best practice. We comment on specific updates in our submission.

Read the submission on the review of the Principles and Recommendations


Submission on the development of the Zero Carbon Bill
The proposed Bill will be a significant policy development for New Zealand and will have a substantial impact on the economy and business. The IoD generally supports the intent of the Government to establish a long-term approach to climate change. However, we emphasise in our submission that organisations need clarity and certainty around the approach and commitments to climate change.

Read the submission on the development of the Zero Carbon Bill


Submission on the exposure draft of the NZX Listing Rules
The IoD strongly opposes the proposal to extend the continuous disclosure rules in the NZX Listing Rules to include constructive knowledge of directors and officers. However, we support other proposed director-related changes in our submission including requirements around director independence.

Read the Submission on the exposure draft of the NZX Listing Rules


Submission on the Privacy Bill
The IoD welcomes the Privacy Bill which will replace the Privacy Act 1993. It is essential that the Bill is fit for purpose, flexible for the future, comparable with the privacy regimes of our key trading partners, and meets international best practice standards. We support introducing mandatory notification of privacy breaches for serious breaches in New Zealand.

Read the submission on the Privacy Bill


Future of tax
The IoD supports the Tax Working Group’s review of New Zealand’s tax system to ensure it is fit for purpose and sustainable going forward. New Zealand has a highly regarded tax system with many strengths. However, it can’t stand still in this time of rapid change and uncertainty. Now is an appropriate time to stand back and consider what is working well and what can be improved to future proof the tax system. Our submission comments on the review at a high level.

Read the submission on the Future of Tax


Submission on management banning orders under the Fair Trading Act 1986
The IoD supports MBIE’s intent to introduce a provision to ban directors/managers of entities that breach the Act (on one occasion) and then go on to set up other entities and are involved in similar offending by those new entities. However, in order to prevent any unintended consequences we suggest the Commerce Commission provide guidance clarifying who is intended to be subject to the new provision.

Read the submission on management banning orders under the Fair Trading Act 1986


State Sector and Crown Entities Reform Bill
The IoD is concerned about reforms in the Bill which give the State Services Commissioner increased powers and shift a level of control away from Crown entity boards to the Commissioner. This shift diminishes the Crown entity governance model, the fundamental role of the board to manage CEOs and hold them to account, and the board’s relationship with the Minister. It will also deter skilled and experienced directors from putting themselves forward to serve on Crown entity boards.

Read the submission on the State Sector and Crown Entities Reform Bill


Submission on the criminalisation of cartels
The Commerce (Criminalisation of Cartels) Amendment Bill introduces a criminal offence for cartel conduct. In our submission we oppose criminalisation because we believe the current civil regime prohibiting cartels is a sufficient deterrent, and introducing a criminal offence may be detrimental to business and New Zealand as a whole.

Read submission on the criminalisation of cartels


Submission on the Trusts Bill
The IoD welcomes the Trusts Bill which will replace the Trustee Act 1956. We generally support the Bill and its purpose to restate and reform New Zealand trust law. We particularly support the inclusion of mandatory and default trustee duties. Our submission discusses governance and specific trustee-related matters and issues with the Bill.
Read submission on the Trusts Bill

2017 submissions

Submission on the FMA corporate governance handbook
The FMA is revising its corporate governance handbook (which was last updated in 2014). The handbook has been refocused to apply to non-listed and public sector entities, moving away from listed issuers. Updates to the handbook reflect developments in corporate governance including non-financial reporting, and director and executive remuneration. Our submission focuses on some of the key revisions to the handbook and other matters the FMA may wish to include.
Read submission on the FMA corporate governance handbook

Submission on personalised digital advice
The IoD made a submission to the FMA on the proposed exemption to enable personalised digital advice (also known as robo-advice). The exemption is a temporary measure to allow financial advisor entities to provide personalised digital services to retail clients. As part of the application process for the exemption, entities will need to include good character declarations from their directors and senior managers. Our submission focuses on this aspect of the exemption process.
Read submission to the FMA on personalised digital advice

Submission on the NZX Listing Rules review
The NZX Listing Rules set out mandatory requirements for issuers listed on the NZX Main Board/Debt Board (and those wishing to list). This is the first major review of the Listing Rules since 2003 and will also impact NZX’s other markets. Our submission focuses mainly on the proposed market structure, and governance and board/director matters in relation to equity issuers.
Read submission to NZX Listing Rules

Service Performance Reporting
The IoD supports the introduction of a reporting standard to provide PBEs with a framework for service performance reporting. We support the proposed flexibility in how entities report service performance information and the extended implementation period. We also encourage the development of clear guidance and educational support for PBE entities.
Read submission to XRB on revised service performance standard

Submission on introducing director identification numbers and insolvency law reform
The IoD continues to support the introduction of director identification numbers and the suggested implementation process. We have also called for the Insolvency Working Group to give greater consideration to proposed insolvency reforms overseas and their relevance in the New Zealand context.
Read submission on introducing director identification numbers and insolvency law reform

Submission on Inland Revenue exposure draft
The IoD generally supports Inland Revenue’s draft interpretation statement on the application of schedular payment rules to directors’ fees. Our submission focuses on specific situations in which tax must be withheld (eg when fees are paid to employees, independent contractors and companies). We have suggested Inland Revenue consider:

  • whether, for payments of directors' fees to employees (eg executive directors), reliance on specification of directors duties in the employment agreement is appropriate (we suggest looking at the reality of the situation)
  • including coverage of the wihtholding tax treatment of payments to employees for directorship services in subsidiary companies
  • providing an upfront summary and/or simplified version to provide greater access for directors, payers and others.

Read submission on Inland Revenue exposure draft

Submission to the FMA on disclosing non-GAAP financial information
It is important that entities present financial information that is understandable and meaningful to investors and other stakeholders. This is fundamental to good governance and underpins trust and confidence in business. The IoD generally supports the updating of the FMA guidance on disclosing non-GAAP financial information to help entities that present this information ensure it is helpful and not misleading. 
Read submission to the FMA on disclosing non-GAAP financial information

Submission on the review of the Unit Titles Act 2010
The Unit Titles Act 2010 is being reviewed to ensure it is fit for purpose. We welcome the review and support reforms to strengthen body corporate governance. These include introducing body corporate committees conflicts of interest provisions and additional provisions on their duties and responsibilities. We also consider that the reform of the Act should include anti-proxy farming provisions. 
Read submission on the review of the Unit Titles Act 2010

2016 submissions

Submission on the exposure draft of the Trusts Bill
The IoD welcomes the draft Trusts Bill which will replace the Trustee Act 1956. We generally support the draft Bill and its purpose to restate and reform New Zealand trust law. We particularly support the inclusion of mandatory and default trustee duties. Our submission discusses governance and specific trustee-related matters and issues with the draft Bill.
Read submission

Submission on NZX Continuous Disclosure (Correcting Consensus Guidance)
Analysts and other third parties track the performance of NZX issuers and publish guidance that can have a significant effect on market expectations. Under proposed amendments to NZX’s Guidance Note on continuous disclosure, issuers would be expected to correct such guidance where they are sufficiently certain that a material deviation (between market expectations and actual financial performance) will arise.
We generally support this disclosure requirement, however we have expressed some concerns with the proposed commentary.
Read submission

Submission on the Regulatory Systems (Commercial Matters) Amendment Bill
The Bill will amend the Companies Act 1993, the Takeovers Act 1993 and other commercial legislation. Our submission focuses on specific governance and director-related amendments.
Read submission

Submission on the FMA's conduct guide
It’s the board’s role to foster high ethical standards and ‘set the tone’ for an effective culture in organisations. In our submission, we support the conduct guide as a resource to help providers understand FMA’s focus on, and expectations about, good conduct.
Read submission

Submission on NZX Corporate Governance Code
The IoD generally supports the proposed updated NZX Corporate Governance Code, including the new tiered approach and 'comply or explain' recommendations. Our comments in this submission focus on particular recommendations. We also provide brief comments to the specific questions in the NZX Consultation Paper.
Read submission

Submission on the review of corporate insolvency law
The review addresses the regulation of insolvency practitioners and voluntary liquidations. Our submission focuses on the New Zealand Companies Register and supports the proposal to introduce director identification numbers. We also discuss contact addresses for directors and submit that directors should be able to publish on the Register a service address that is not their residential address.
Read submission

Exposure Draft NZASB 2016-6 Service Performance Reporting
The IoD supports the introduction of a reporting standard to provide PBEs with a framework for service performance reporting. Financial information alone doesn’t tell the whole story and accurate, timely and meaningful non-financial information is essential for good governance. Introducing a new performance reporting regime will mean significant change for many PBEs and it is important that sufficient time and support is provided to enable an effective transition.
Read submission

Submission on Local Government Act 2002 Amendment Bill (No 2)
The Bill introduces significant local government reforms. We comment on specific governance and director matters related to new types of council-controlled organisations.
Read submission

Submission on the Te Ture Whenua Māori Bill

The reform of Te Ture Whenua Māori (and updating of the 1993 Act) will mean significant change for Māori land owners, including introducing a new governance framework in relation to developing and approving their own governance constitutions and appointment of kaitiaki (governors). Our submission focuses on the duties and responsibilities of kaitiaki and their immunity from personal liability.
Read submission

Submission on Exposure Draft of the Incorporated Societies Bill

The IoD supports the updating of the Incorporated Societies Act 1908 with a new, modern statute. However, we are concerned that small incorporated societies may be disproportionately burdened by compliance matters in the draft Bill. We encourage MBIE to consider whether the one-size-fits-all approach under the draft Bill is appropriate or whether there are alternative options that would better suit small societies.
Read submission

IoD submission to NZX on the review of Corporate Governance Reporting Requirements

The Institute of Directors endorses NZX’s review and the updating of the Corporate Governance Best Practice Code (the Code). It is important to develop a reporting regime that is current, effective for good corporate governance reporting, and aligned with best practice. It is also important that we reduce fragmentation, duplication and inconsistencies as much as possible in the various corporate governance reporting regimes in New Zealand. 
Read submission


 

2015 submissions

IoD submission to RBNZ on Regulatory Stocktake of the Prudential Requirements applying to Registered Banks (September 2015)

We believe that the Institute of Director’s (IoD) annual confirmation of good character for Chartered Members offers an opportunity for the Bank to help ensure ongoing suitability of bank directors after they have been appointed.
Read submission

IoD submission to XRB on Exposure Draft NZAuASB 2015-1, and reporting on Key Audit Matters (August 2015)

We supported a cautious and phased approach to the introduction of a significant change in auditor reporting on Key Audit Matters (KAM), including deferring consideration of wider application of KAM reporting until after the post-implementation review.
Read submission

IoD submission to XRB on Exposure Draft NZAuASB 2015-2, and directors’ responsibilities (August 2015)

The IoD agreed with the NZAuASB that, notwithstanding a recent amendment to the Companies Act, directors (i.e. those charged with governance) are ultimately responsible for ensuring the preparation of financial statements.
Read submission

IoD submission to Te Ture Whenua Māori Act 1993 Review Panel on draft Te Ture Whenua Māori Bill (August 2015)

The reform of Te Ture Whenua Māori (and updating of the 1993 Act) will mean significant change for Māori land owners, including in relation to developing and approving their own governance constitutions and appointment of kaitiaki (governors). The IoD’s submission focused on the duties and liabilities of kaitiaki.
Read submission

IoD submission to Inland Revenue on Draft Public Ruling: Goods and Services Tax - Directors' Fees (May 2015)

The IoD supported the updating of the Ruling on GST and Directors' fees to reflect changes to the GST Act, and encouraged the development of simple and user-friendly guidance on this matter.  Read submission
The new guidance is now available and an overview is available here.

IoD submission to NZX on its Review of penalties available within NZ Markets Disciplinary Tribunal Rules and Procedures: Discussion Document (May 2015)

The IoD considers legal compliance to be fundamental to governance best practice, and a way a board can add value by ensuring financial reports and processes with regulatory environments.
Read submission

2014 submissions

IoD submission to OECD Corporate Governance Committee: Organisation for Economic Co-operation and Development

The IoD supported the guidance to improve corporate governance and offers suggestions for changing aspects of the guidance.
Read submission


IoD submission to FMA on Corporate Governance Principles

The IoD supported the updating of the guidelines, and encourage enhancements to help reflect best practice in governance.
Read submission


IoD submission to FMA on consultation paper: Going Public – a Directors’ Guide

The IoD supported guidance to improve corporate governance and directors especially those considering an initial public offering or wanting to undertake a 'compliance listing'.
Read submission


IoD submission to NZX on Trading Halts and Continuous Disclosure

The IoD's comment on the draft disclosure was intended to provide clarity for end users such as directors.
Read submission


IoD submission on Long Association of Personnel with an Audit Client

The IoD recognised the importance of auditor rotation and supported a focus on the role of director's audit committees in maintaining audit quality. The impact of increasing a two year cooling off period to five years could compromise audit quality, and the IoD but supported maintaining the current stand down period in line with the Auditor-General's standards.
Read submission


IoD submission on the Health and Safety Reform Bill

The IoD supported the Bill and is committed to safer workplaces in New Zealand. We welcome the aim to reform the culture and responsibilities in the workplace from the ‘top down’ and support directors being appropriately held responsible for health and safety outcomes. In our view proportionality is an important principle, for example regulatory focus should concentrate on areas with significant health and safety problems. We also discuss aspects of the Bill, such as voluntary directors, that need clarification.
Read the IoD’s full submission here.

2012 - 2013 submissions

Position statement on earthquake-prone buildings

Members will be aware of the initiative between the IoD and the Ministry of Business, Innovation and Employment (MBIE) where we jointly issued the Good Governance Practices Guideline for Managing Health and Safety Risks.

MBIE and the newly established Worksafe New Zealand have been working to produce guidance on earthquake-prone buildings and the interaction of the Health and Safety in Employment Act with the Building Act.

WorkSafe released guidance for to aid building owners, employers and directors in this following Position Statement.

The IoD strongly recommends that members read the Position Statement and familiarise themselves with the content.


Exposure Draft: Health and Safety Reform Bill

Submission of the Institute of Directors


Earthquake prone buildings – director liability


Financial Markets Conduct Bill passed

(Source: Chapman Tripp)

The Financial Markets Conduct Bill has now been passed and represents a significant achievement for all involved – Minister Craig Foss, former Minister Simon Power, Select Committee members, officials, and those from the private sector who have committed significant time and resource to get legislation which is both workable and durable.

The new Act will be brought into force progressively from April next year. Much of the detail will be established through regulations, with consultation on drafts to begin in October. Read more.

Timing (Source: Bell Gully)
Parts of both Acts will come into force after the Acts receive Royal assent, mainly to allow for regulations required under the Acts to be progressed. The provisions relating to the new register of securities offers (which has been in place since 1 July this year) will be repealed at that time.

The key provisions of both Acts will not be brought into force until next year. The FMA has indicated that the implementation dates will be in two phases as outlined below:

Phase 1 on 1 April 2014

For the general fair dealing obligations in Part 2, key growth-focussed initiatives (e.g., the changes for employee share schemes) and to enable financial market participants to become licensed.

Phase 2 on 1 December 2014

For the new disclosure requirements, the go-live of the two new online registers (i.e., the register of managed investment schemes and the register of offers of financial products), licensing obligations and the remainder of the Acts.

Exposure Draft, Reporting on Audited Financial Statements: Proposed New and Revised International Standards on Auditing (ISAs)

The IAASB has published the proposed changes for public comment. This is important reading for directors and boards – especially audit committees. Read more

Workplace Health and Safety Reform

On 8 August 2013,  the Government released their response to the recommendations of the Independent Taskforce on Workplace Health and Safety (the taskforce) in a document titled ‘Working Safer – A blueprint for health and safety at work’. The extensive document details the largest reform of health and safety in New Zealand in over 20 years. Much of what has been included was anticipated by the presenters at the recent IoD Health and Safety Governance events. Read more

IoD submission on Civil Pecuniary Penalties Consultation Document

The IoD has long supported the need for a clear demarcation between civil and criminal liability. Civil pecuniary penalties in their current form do not provide this. It is important that individuals are able to understand the distinction and the consequences of a breach of duty. The IoD firmly believes that directors should be accountable for their actions. The IoD supports the review of the civil pecuniary penalty (CPP) regime and the general belief by the Law Commission that there is a place for CPP in today’s world.
Read the IoD's full submission

IoD submission on the Safer Workplaces Consultation Document

The IoD supports the purpose behind the work of the Taskforce: to improve the safety of New Zealand’s workplaces. We see workplace safety as a key component of responsible and effective businesses, and we are confident that a significant majority of New Zealand businesses and business leaders take their responsibilities in this area seriously, and discharge their obligations diligently.
Read the IoD's full submission

IoD submission on the Companies and Limited Partnerships Amendment Bill

The loD supports legislation that is likely to result in a more efficient market economy and functional and performing financial markets that investors can have confidence in. We therefore support the central purposes of the Companies and Limited Partnerships Amendment Bill (“the Bill”) which is to ensure that New Zealand remains a trusted place to do business. 
Read the IoD's full submission
View Companies and Limited Partnerships Amendment Bill report

IoD submission on the Financial Markets Conduct Bill

The loD supports any legislation that is likely to result in a more efficient market economy and functional and performing financial markets that investors can have confidence in. We therefore support the central purposes of the draft Financial Markets Conduct Bill (“the Bill”) which is to provide an enduring financial market conduct regulatory regime that encourages confident and informed participation and promotes innovation and effective competition. 
Read the IoD's submission
View Financial Markets Conduct Bill report

IoD submission on proposed amendments to the NZX Listing Rules 10.5.5 (Diversity)

The IoD firmly supports initiatives whose intent is to encourage listed companies to consider the benefits that “diversity” confers both within the board and throughout the rest of the company for the purpose of promoting performance improvement and increasing shareholder value.
Read the IoD's submission