Modern Slavery Bill Overlooks the Coercive Harm Happening on New Zealand Shores
This submission was made to the Modern Slavery Bill Select Committee on Justice, New Zealand, on behalf of the Cult-Informed Professional Network on 28-5-26, by Liz Gregory with Dennis Parker.
Introduction
My name is Liz Gregory, and I, in connection with Dennis Parker, am making this submission on behalf of the Cult-Informed Professional Network (CIP Network), a group focused on increasing understanding of cultic harm and strengthening professional capability in responding to coercive and high-control environments across New Zealand and Australia.
The CIP Network is a growing multidisciplinary network of 50+ individuals and professionals across New Zealand and Australia who work independently and collaboratively to reduce the impacts and influence of cults and coercive groups. Many members have lived experience in these contexts. The CIP Network focuses on increasing awareness and understanding of cultic harm while building professional capability across health, psychology, social services, education, law, and policy-making. The network supports workforce development, collaboration, public education, research, survivor support pathways, and informed policy responses relating to coercive control and cult-related harm. This submission reflects a range of personal views and experiences from within the CIP Network.
Our perspectives are informed by many years of direct frontline involvement supporting individuals and families leaving high-control religious communities, including through work connected with the Gloriavale Leavers Support Trust and alongside professionals within the Cult-Informed Professional Network. Through this work, we have gained significant insight into the long-term effects coercive systems can have on autonomy, education, labour expectations, financial independence, access to information, psychological wellbeing, and a person’s practical ability to leave an environment safely.
This has included supporting people experiencing dynamics commonly associated with slavery and exploitation frameworks, including coercive control, dependency, economic restriction, restricted autonomy, excessive labour expectations, social isolation, and significant barriers to leaving. These are not always well captured by traditional understandings of slavery or exploitation within New Zealand law and policy.
We therefore have a strong interest in legislation relating to slavery, servitude, forced labour, exploitation, and coercive control.
We are supportive of the intent behind the Modern Slavery Bill and welcome efforts to strengthen New Zealand’s response to this issue. However, we believe the current framework risks overlooking forms of coercive control and exploitation that can occur within closed, high-control, or cultic environments, particularly where compliance is achieved through psychological, social, spiritual, relational, or culturally enforced mechanisms.
Existing New Zealand Context
While Gloriavale is referenced throughout this submission because of the extent of public documentation, court findings, and our direct frontline experience, it is important to note that it is not the only high-control group in New Zealand where slave-like practices may occur. The CIP Network is aware of other closed or high-control environments operating within New Zealand where similar dynamics of coercive labour, restricted autonomy, financial dependence, and barriers to exit are present.
Gloriavale is simply the most visible example. The framework created by this Bill needs to be capable of recognising patterns of harm wherever they occur.
New Zealand has already seen significant judicial findings relating to exploitative labour practices within communal religious environments. In both the Courage and Pilgrim Employment Court decisions, the Court made serious findings regarding child labour, employment status, and systemic labour practices within Gloriavale. Parts of those rulings alluded to conditions resembling servitude and slave-like conditions, particularly in relation to the lack of genuine freedom, the expectation of lifelong labour, and the degree of control exercised over members from childhood onward.
There are also continuing public concerns and active Police investigations relating to allegations of slavery, servitude, and forced labour within Gloriavale. Sadly, four years on, that investigation appears to have stalled.
Even with court findings, years of media attention, and ongoing public concern, many people affected by these environments still feel there is little realistic pathway to accountability or change. That is part of the reason this Bill matters.
Concerns Regarding the Narrow Scope of the Bill
While the Bill is a welcome step toward recognising modern slavery in New Zealand, its focus appears relatively narrow.
At present, the Bill is largely a corporate transparency mechanism rather than a direct anti-slavery enforcement tool. It relies heavily on large businesses identifying and reporting risks within their supply chains. That may improve transparency in some sectors, particularly internationally, but situations like Gloriavale do not sit neatly inside a conventional corporate supply-chain model.
The primary mechanism proposed is a reporting regime applying only to entities with more than $100 million in annual revenue. As currently drafted, it is difficult to see how this legislation would meaningfully impact slavery or servitude occurring in many domestic coercive environments.
Modern slavery does not occur only within international trafficking networks or overseas manufacturing chains. It can also arise within closed domestic environments where labour, finances, education, movement, relationships, and access to outside support are tightly controlled over many years through psychological, cultural, religious, economic, and relational pressures.
In some cases, people may technically appear free to leave, while in reality facing overwhelming barriers to autonomy due to fear of shunning, family separation, dependency, loss of community, spiritual consequences, or simply a lack of education and preparation for life outside.
For many survivors, those barriers are invisible to outsiders but overwhelming in practice.
Gaps in the Current Framework
The Bill appears primarily designed around commercial supply-chain exploitation and conventional employment relationships. As a result, uniquely New Zealand forms of coercive exploitation occurring within closed communal systems may remain poorly recognised and insufficiently addressed.
The difficult reality is that many of the legal tools that should already apply to Gloriavale-type situations technically exist. Employment law exists. The Crimes Act exists. Human rights protections exist. Yet the real-world experience has shown how slow, fragmented, and difficult these cases can be to address, particularly when victims are deeply conditioned not to speak out or may not recognise themselves as victims at all.
A modern slavery framework focused mainly on corporate reporting does not solve that enforcement problem.
Prosecutions relating to slavery and servitude remain rare, the legal threshold for proving such offences is high, and responsibility is spread across multiple agencies including Police, MBIE, MSD, Oranga Tamariki, Education, and employment authorities. In practice, coercive environments can end up falling between all of them, with no single agency having the mandate, expertise, or confidence to act decisively.
New Zealand is not alone in grappling with these limitations. The United Kingdom’s Modern Slavery Act 2015 was pioneering, but experience over the last decade has shown that reporting-only regimes have limited impact without stronger enforcement mechanisms behind them. Australia, Canada, Germany, and Norway have all taken steps forward, but their approaches have also focused primarily on corporate supply chains rather than coercive domestic communities.
New Zealand has an opportunity to build on those lessons instead of simply repeating the same narrow framework.
Children Raised Within Closed Systems
We are particularly concerned that the experiences of children raised within coercive communal environments are not sufficiently recognised within this Bill.
In some settings, children grow up within systems involving extensive labour expectations, restricted educational opportunities, financial dependency, limited exposure to mainstream society, and strong pressure discouraging dissent or exit.
Particular consideration should be given to children raised within isolated or coercive environments where labour expectations, educational deprivation, and dependency structures impair the development of genuine autonomy and informed consent.
These children cannot reasonably be expected to identify themselves as victims of modern slavery when that is the only life they have ever known. The exploitation they experience is often intergenerational, normalised over decades, and reinforced by community, theology, family structure, and social isolation.
Suggested Areas for Strengthening the Bill
We believe the Bill could be significantly strengthened in several key areas.
1. Explicitly recognise and define coercive control
The Bill should expressly recognise that slavery and servitude may arise through psychological, cultural, religious, relational, or economic coercion, even where overt physical restraint is absent.
Relevant indicators should include psychological and spiritual coercion, social isolation, manufactured dependency, fear of shunning or family separation, information control, and practical barriers to exit.
Many entrenched forms of domestic exploitation do not rely on physical force. They operate through environments where people have been conditioned from childhood to accept their circumstances as normal, righteous, or inevitable.
Without clearer recognition of these dynamics, assessments of servitude and forced labour will continue to miss the lived reality of many survivors.
Consideration should therefore be given to more clearly defining coercive control within the legislation or associated guidance material. This would assist Police and other agencies to better identify exploitative environments, particularly within high-control or closed community settings where compliance is achieved through dependency and coercion rather than overt force alone and will give confidence for appropriate intervention where harm is occurring.
2. Broaden the scope beyond very large entities
The current $100 million threshold is extremely high in a New Zealand context and means the vast majority of businesses purchasing goods or services from exploitative domestic operations will face no obligations whatsoever.
A tiered approach - for example, a reporting obligation at $10 million revenue and a fuller due diligence requirement at $50 million - would bring far more relevant businesses within scope without imposing disproportionate burdens on genuinely small operators. The Gloriavale situation is instructive. Many of the businesses purchasing products connected to those labour systems were regional operators that would sit well below the proposed threshold. Most faced no legal obligation to consider the conditions under which those products were produced until public pressure forced the issue.
Consideration should also be given to allowing entities or sectors to be brought within scope based on elevated risk indicators rather than revenue alone.
3. Establish specialist oversight and coordination
Consideration should be given to establishing an independent Anti-Slavery Commissioner with expertise in coercive control and cultic harm, and with the ability to coordinate responses where vulnerability is known or suspected.
Cases involving coercive communal environments routinely fall between agencies because no single body has the expertise or mandate to coordinate responses involving labour, education, welfare, coercive control, trauma, and psychological dependency all at once.
The Gloriavale situation remained unresolved for years despite extensive public documentation and court findings, largely because responsibility remained fragmented.
A reporting regime alone will not fix that.
4. Invest in survivor support and workforce capability
Many survivors leaving coercive environments face significant practical, psychological, educational, and economic barriers long after they physically leave.
The Bill should encourage stronger investment in specialist exit support, trauma-informed services, housing pathways, education catch-up, financial mentoring, and long-term reintegration support.
We regularly encounter former members who have never independently managed finances, signed tenancy agreements, accessed healthcare systems on their own, or navigated mainstream employment expectations.
Equally important is workforce development. Police, labour inspectors, social workers, teachers, healthcare providers, immigration officials, and prosecutors regularly encounter people experiencing coercive control or hidden exploitation but often lack the training to recognise it.
Training relating to coercive control, cult dynamics, trauma responses, and barriers to exit should form part of the broader framework created around this legislation.
The frontline knowledge held by organisations like the CIP Network, the GLST and Olive Leaf Network should also be recognised and resourced as part of New Zealand’s modern slavery response, rather than relying primarily on charitable goodwill and overstretched volunteer networks.
Conclusion
We ask the select committee to consider honestly whether this Bill, as currently drafted, would have made any meaningful difference to the people we support. We do not believe it would.
That is not an argument against the Bill. It is an argument for making it stronger.
Ultimately, modern slavery legislation in New Zealand should not focus solely on overseas supply chains and large commercial operations. It should also recognise that serious exploitation can occur domestically, including within environments that outwardly appear lawful, communal, cultural, or religious, but where individuals may experience profound restrictions on freedom, autonomy, informed consent, and the practical ability to leave.
The people we support did not find their way to freedom through a corporate reporting regime. They found it through relationships, trusted professionals, frontline organisations, and often through years of painful legal processes.
This Bill has an opportunity to build a framework that reaches people sooner. We urge the committee to take that opportunity.
We would like to be heard in the oral submissions.
Comments