IoD seeks clearer modern slavery obligations

The Institute of Directors (IoD) supports the intent of the Modern Slavery Bill and its goal of improving transparency, strengthening modern slavery risk management and increasing visibility of risks across operations and supply chains. The IoD recognises modern slavery as an important governance issue that can affect organisational reputation, stakeholder trust, supply-chain resilience and long-term sustainability. 

While supporting greater transparency and stronger expectations around identifying and addressing modern slavery risks, the IoD considers the Bill should more clearly distinguish between governance oversight and operational management responsibilities. The IoD advocates for an entity-focused regime that places primary responsibility for compliance on the reporting entity, with boards responsible for governance oversight. 

The IoD raises concerns about the breadth of the proposed due diligence provisions and director liability settings, noting that the Bill creates uncertainty around governance oversight responsibilities, implementation expectations and proportionate reporting requirements. It also raises concerns about the cumulative effect of the proposed liability, public register and procurement settings, and the risk these may encourage defensive governance and compliance-focused behaviour. 

The IoD supports a staged and proportionate implementation approach, supported by practical guidance and greater clarity around reasonable steps and due diligence expectations. It also recommends aligning reporting periods with entities’ existing reporting cycles, recognising joint and overseas statements where appropriate, and maintaining stronger alignment with Australian reporting settings and broader New Zealand reporting regimes. 

Overall, the IoD supports the intent of the Bill but advocates for a proportionate, practical and governance-focused regime that strengthens transparency and modern slavery risk management while supporting effective governance, meaningful capability development and responsible reporting practices.

Read the submission