The Context
Xi Jinping personally escalated China’s anti-corruption campaign in January 2026, demanding “tough scrutiny” for the next five-year plan. The climate is not theoretical. From January to November 2025, over half a million low-level officials were disciplined. Sixty-five senior ‘tigers’ were snared. The official line is clear: corruption is a “stumbling block” and the situation remains “grave and complex.” The specific target? Collusion between officials and business. For any New Zealand company with operations, partners, or aspirations in China, this isn’t a political sidebar. It’s a live operational risk. Your local manager’s ‘relationship-building’ dinner could now be a disciplinary file.
The Risk
Your personal liability isn’t about Chinese law. It’s about New Zealand governance. The crisis isn’t a fine from Beijing; it’s the brand erosion and director disqualification that follows. If your subsidiary is implicated in a corruption probe, the reputational contagion is instant. The ‘Court of Public Opinion’ in NZ will judge your oversight. This may indicate a failure of your duty of care under the Companies Act 1993. Were you diligent? Did you ensure adequate controls in a high-risk jurisdiction? A scandal can trigger a catastrophic loss of stakeholder trust, evaporating market value far faster than any regulatory penalty. Your personal reputation, built over decades, becomes synonymous with the headline.
The Control
Treat this campaign as a material business risk, not a geopolitical footnote. Immediately mandate a top-to-bottom review of all China-facing operations with a singular focus: eliminating any ambiguity around gifts, entertainment, and third-party intermediaries. Insist on transparency that would survive front-page scrutiny in Wellington. This is about psychosocial safety for your employees there, too—they are navigating a climate of fear. Your governance must be their shield.
The Challenge
These are the critical questions you should be raising at the board table:
| Can we guarantee, with evidence, that none of our commercial relationships in China could be construed by authorities as “collusion between officials and businessmen”? | |
| What is our immediate crisis communications plan for our staff, customers, and the NZ market if our China operations are publicly named in a CCDI investigation? | |
| Have we stress-tested our whistleblower protocols to ensure an employee in Shanghai feels as safe reporting a concern as one in Christchurch? |