Forced Labour Requirements Make an Impact on Canadian Companies

Canada’s Bill S-211 (Fighting Against Forced Labour and Child Labour in Supply Chains Act) went into effect in 2023, and as of May 31, 2024, compliant Companies submitted their first report about their efforts to identify and mitigate forced and child labour associated with their products and supply chains.

Bill S-211 aims to reduce forced and child labour in supply chains by promoting transparency and by mandating reporting requirements for entities or institutions that meet the following criteria: 

Any government institution or body that produces, purchases, or distributes goods in Canada or elsewhere must comply.

The scope includes businesses related to private entities that produce goods in Canada, import goods into Canada or control entities engaged in these activities.

The bill requires that affected entities must submit annual, publicly available reports which provide details about the steps taken in the previous year to identify and address risks of forced or child labour in their direct operations and prevent or mitigate these risks throughout their supply chains.

Bill S-211 does not dictate the actions that companies must take but reporting on their supply chains’ transparency, connections and collaborations with supply is necessary to perform the due diligence functions to be consistent with what is intended. These practices can include (but are not limited to):

1. Identifying Risks: The Act requires entities to identify and address forced and child labour risks; and mapping out your suppliers and subcontractors is the universal first step in pinpointing material risks;
2. Demonstrating Efforts: The core of compliance lies in reporting the measures taken to prevent or mitigate forced labour risks. By having a transparent supply chain, you can collect evidence of these efforts, such as audits conducted with suppliers or responsible sourcing policies implemented;
3. Focus on Prevention: Bill S-211 aims for proactive prevention, not just reactive responses to discovered issues. Transparency allows you to monitor your supply chain for any red flags, enabling early intervention and potentially avoiding forced labour altogether.
4. Accountability and Credibility: Transparency fosters accountability. By disclosing your supply chain and efforts to combat forced labour, you demonstrate a commitment to ethical sourcing. This can enhance your company’s reputation and consumer trust.

Transparency-One’s Senior Manager, Alex Bowles, discusses more on this topic with Canadian Occupational Safety here.

Looking to take a closer look at your supply chain for transparency and manage your network of suppliers? Partner with Transparency-One to let us help with your value chain needs.