How much do you know about the ethics and practices of the suppliers in your supply chain? Until recently, that question sat in the ESG and reputation column. In 2026 it moved into the cost and trade risk column, and that changes who needs to act on it and how quickly.
In July 2026 the US listed New Zealand among roughly 60 countries facing a new 12.5% tariff, up from 10%, for failing to stop the import of goods made with forced labour. That is a direct hit to export margins, and it is tied specifically to how well the country, and the businesses within it, can show they are keeping modern slavery out of their supply chains.
The higher rate took effect from 24 July 2026, up from New Zealand’s original 10%. The reason given was forced labour. Countries that committed to a forced labour import ban were kept at the lower 10% rate, and New Zealand was not among them. In practice that means clean, well-documented supply chains are no longer just good governance. They are now bound up with the price your goods land at in your largest market.
Why this matters to your business now
The point of this shift is simple. Supply chain due diligence is no longer just the right thing to do. It affects the price your goods land at in the US, which for most exporters is the difference between a competitive quote and a lost order. Being able to show your supply chain is free of forced labour is fast becoming a condition of trade, not a nice-to-have policy statement.
That is why this belongs on your finance and advisory agenda, not only your sustainability report. The checks below do double duty. They protect the people in your supply chain, and they build the evidence trail that keeps you on the right side of the tariff line and of the customers, auditors and partners who are asking the same questions.
What modern slavery means in supply chain terms
Modern slavery in a supply chain refers to severe labour exploitation where workers cannot refuse or leave their work due to threats, coercion or deception. It covers forced labour, debt bondage, human trafficking and child labour. It can sit with an immediate supplier, or several tiers down where you have far less visibility, which is exactly where the risk tends to hide.
Why demonstrable due diligence matters
With trade access now linked to forced labour standards, the businesses that come out ahead are the ones that can show a documented, active due diligence process rather than a one-off statement. The six checks below are a working model of that process, and each one produces the kind of record you would want to point to, whether the question comes from a customer, an auditor, a bank or a border.
Six ways to check for signs of modern slavery
- Document and map your supplier tiers. Map your supply chain and identify all immediate vendors and their sub-contractors. Focus on labour-intensive sectors such as cleaning, security or offshore apparel manufacturing, where the risk of exploitation is highest. This map is the foundation of any reasonable steps defence.
- Run risk assessments across your supply chain. Use key risk indicators to find your highest-risk areas: high-risk geographic regions, low-margin industries, or suppliers heavily reliant on vulnerable seasonal migrant labour. Record what you found and what you did about it.
- Build ethical checks into procurement. When taking on new suppliers, make modern slavery questionnaires a standard part of procurement. This forces new vendors to confirm compliance with labour laws and to state whether workers retain their own passports and are paid lawfully.
- Train the people who buy and approve. Educate the team members who buy goods or approve invoices on how to spot the signs. Red flags include suspiciously low quotes, unapproved sub-contracting, or a vendor that resists giving transparent detail about its business.
- Provide safe reporting channels. Put clear, confidential grievance mechanisms in place so supply chain workers can report forced labour or wage theft directly, without fear of reprisal.
- Collaborate with partners in your supply chain. Many businesses share suppliers and upstream providers. Compare notes with partners to surface issues you might miss on your own, and back up any concern with additional investigation so you are not acting on a false positive.
Where to start
If you export to the US, or supply businesses that do, the tariff change means this now sits on your bottom line. The businesses that will fare best are the ones that treat supply chain due diligence as an ongoing, documented process rather than an annual disclosure, and that can prove it when asked. Our business advisory team at DFK OGC can help you map your supply chain risk and factor the tariff impact into your planning. Reach out and let’s work through it together.