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Understanding Canada's new Supply Chains Act: #2 Navigating Compliance

In our previous discussion about Canada's new Fighting Against Forced Labour and Child Labour in Supply Chains Act (previously Bill S-211), we explored the broader context of the legislation and who is required to file a report. Now, let's dive into the specifics of what affected organizations need to report and how they can navigate compliance effectively.


What Must the Report Include?

Under the Act, organizations must document their efforts during the previous financial year to prevent and reduce the risk of forced labour or child labour within their business and supply chain activities. This encompasses addressing such issues not only within Canada’s borders but also elsewhere.


The comprehensive report must cover the following aspects for each entity subject to it:


  • Structure, Activities, and Supply Chains: An in-depth overview of the organization's structure, activities, and supply chains.

  • Policies and Due Diligence Processes: Documentation of the organization's policies and due diligence processes concerning forced labour and child labour.

  • Risk Assessment and Management: Identification of the parts of its business and supply chains susceptible to forced labour or child labour, along with the steps taken to assess and manage that risk.

  • Remediation Measures: Description of any measures taken to address identified forced labour or child labour, including efforts to mitigate the loss of income to vulnerable families resulting from such measures.

  • Employee Training: Details about the training provided to employees on forced labour and child labour.

  • Effectiveness Assessment: Insight into how the organization evaluates its effectiveness in ensuring forced labour and child labour are not present in its business and supply chains.


These are the steps that entities must follow:


  1. Prepare a Report: Organizations must develop a comprehensive document that meets all the Act's requirements. This entails thorough internal consultation and gathering of necessary information, with the guidance provided serving as a valuable resource. The pdf report cannot be larger than 100mb and a 10 page maximum is recommended.

  2. Approval and Attestation: After completing the report, it must be approved by the organization's governing body (i.e. board of directors). A representative of the governing body needs to sign a statement confirming their approval, which must be included in the final version of the report submitted to the government.

  3. Complete Online Questionnaire: Entities must complete the online questionnaire here. This questionnaire consists of a series of questions addressing each requirement under the Act. Ensuring consistency between the questionnaire and the report is essential.

  4. Upload Completed Report: Entities are required to upload their attested report in PDF format. A copy of the report will be made publicly available on the Public Safety Canada website (a searchable online catalogue is currently in development).

  5. Publish Report to Entity’s Website: Entities must publish their submitted report prominently on their website.


Navigating this process diligently is essential for organizations to fulfill their obligations under the Act effectively and contribute to broader efforts combatting forced labour and child labour in supply chains.

Public Availability

Organizations subject to the Act must make these reports publicly available, including on their website. Entities incorporated under federal statutes like the Canada Business Corporations Act must also provide the annual report to shareholders. Eventually, a centralized publicly accessible electronic registry will available on the Public Safety Canada website for members of the public to review the submitted reports.


Stay tuned for our next blog post, where we take a step back and look at developing an effective supply chain due diligence program.




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