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Annex One:
Relating to subcontracting practices and NAATI credential compliance within
interpreting and translation services procured by the Ministry of Education (Te
Tāhuhu o te Mātauranga).
SECTION A: SUBCONTRACTING ARRANGEMENTS
1. Whether the Ministry of Education's interpreting and translation providers are
permitted to subcontract assignments to third parties, including overseas-based
agencies or individual contractors located outside New Zealand.
2. Any conditions or restrictions in the Ministry of Education's contracts with
interpreting and translation providers regarding the use of subcontractors, including
any requirements that subcontractors be based in New Zealand or hold an
appropriate New Zealand work visa.
3. Whether the Ministry of Education requires providers to disclose the identity,
location, or credentials of individual interpreters or translators — including
subcontractors — who carry out assignments on the Ministry's behalf.
4. Whether the Ministry of Education has any knowledge of, or has sought
information about, assignments being routed to interpreters or translators located
outside New Zealand.
5. Any instances where the Ministry of Education became aware that an assignment
was conducted by a person located outside New Zealand or by an uncredentialled
subcontractor, and any action taken as a result.
SECTION B: NAATI CREDENTIAL COMPLIANCE
6. What mechanism, if any, the Ministry of Education uses to verify that individual
interpreters and translators carrying out assignments on its behalf — including those
engaged through subcontracting arrangements — hold a valid NAATI credential or
Working Towards NAATI (WTN) status.
7. Whether the Ministry of Education requires its interpreting and translation
providers to maintain and supply a current register of credential ed practitioners
working under Ministry contracts, and if so whether the Ministry has received and
reviewed such registers.
8. Any audits, spot checks, or compliance reviews conducted by the Ministry of
Education on its interpreting and translation providers since 1 July 2024 to verify
NAATI credential compliance, including the methodology and findings of any such
reviews.
9. Any instances since 1 July 2024 where a provider was found to have used an
interpreter or translator who did not hold the required NAATI credential or Working
Towards NAATI (WTN) status, and any consequences or remedial action taken.
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10. Any complaints received by the Ministry of Education since 1 July 2024 from
staff, students, families, or members of the public regarding the qualifications or
conduct of an interpreter or translator engaged through the Ministry's services.
SECTION C: INTERPRETER AND TRANSLATOR PAY VISIBILITY
11. Whether the Ministry of Education has any information about the rates or fees
paid by its providers to individual interpreters or translators for assignments
conducted on the Ministry's behalf.
12. Whether the Ministry of Education has ever sought, as part of contract
negotiations, tendering processes, or performance reviews, any information about
the pay or working conditions of interpreters or translators engaged through its
provider contracts.
13. Any internal policies, briefings, risk assessments, or correspondence within the
Ministry of Education regarding the fair remuneration or employment conditions of
interpreters and translators working under its contracts, including any concerns
raised about the margin between rates paid to providers and rates passed on to
practitioners.
14. Whether the Ministry of Education's tendering or procurement criteria for
interpreting and translation services include any consideration of whether providers
pay practitioners at or above a minimum rate, living wage, or industry standard.
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