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Navigating Canada’s New Anti-Forced Labour Supply Chain Law: A Guide for Businesses

Michael Glionna, PRESIDENT

By:

Michael Glionna

President

Canada has taken a critical step towards tackling forced labour and child labour within the supply chains by introducing new legislation known as “An Act to enact the Fighting Against Forced Labour and Child Labour in Supply Chains Act and to amend the Customs Tariff,” also referred to as Bill S211. This act aims to ensure that businesses take proactive measures towards establishing an ethical and responsible trade environment.

Overview of Bill S211

On May 11, 2023, the bill received Royal Assent and became effective from January 1, 2024. The new law requires certain organizations to submit annual reports detailing the measures they have taken to prevent forced or child labour in their business operations and supply chains. These reports, covering the previous fiscal year’s activities, are due on May 31 of each year.

Who Needs to Comply?

The act categorizes entities required to comply based on several criteria. These entities include corporations, trusts, partnerships, or other unincorporated organizations that:

  • Are listed on a Canadian stock exchange;
  • Have a business presence in Canada, conduct business in Canada, or possess assets in Canada and meet at least two of the following conditions for one of their two most recent financial years:
    • At least $20 million in assets;
    • At least $40 million in revenue;
    • An average of at least 250 employees.

Furthermore, the legislation applies to entities involved in:

  • Producing, selling, or distributing goods in Canada or elsewhere;
  • Importing goods into Canada that were produced outside the country;
  • Controlling an entity engaged in any of the activities mentioned above.

Reporting Requirements

The annual report must detail:

  • The entity’s structure, activities, and supply chains;
  • Policies and due diligence processes concerning forced and child labour;
  • Business and supply chain segments at risk of utilizing forced or child labour and the actions taken to manage these risks;
  • Measures implemented to remedy any instances of forced or child labour;
  • Actions taken to compensate for income loss among vulnerable families due to measures against forced or child labour;
  • Training provided to employees on identifying and preventing forced and child labour;
  • Methods used by the entity to evaluate its effectiveness in ensuring its business and supply chains are free from forced and child labour.

Accessibility of Reports

To ensure transparency, submitted reports will be accessible in two ways:

  • Through an electronic registry on Public Safety Canada’s website,
  • On a prominent location on the reporting entity’s or government institution’s website.

Further Information and Resources

If businesses want to understand the full implications of Bill S211 and ensure compliance, they can refer to the official resources provided by the Government of Canada’s Public Safety and read the text of Bill S211 itself. For personalized guidance, entities can contact Brian Rowe, Director of Customs Compliance & Regulatory Affairs.

This legislation is a significant step in Canada’s efforts to eliminate forced and child labour from global supply chains. It reflects a growing commitment to ethical business practices and the protection of human rights.

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