Regulatory compliance: forced and child labor in the workplace

Who is in scope?

What reporting is required?​

Entities and government institutions covered by the Act are required to submit a report by 31 May each year. It would be made publicly available through the:

• Online questionnaire submitted to Public Safety Canada
• PDF report that should be in a prominent location on the entity’s or government institution's website

Information provided in the online questionnaire and PDF report must be consistent.

Scope of the report

The report should set out:

1. Overview of structure, activities and supply chain
2. Policies and due diligence processes
3. Steps to identify, assess and manage the risk of forced labour or child labour
4. Remediation measures
5. Trainings provided to employees
6. How it assesses effectiveness of measures to ensure forced labour and child labour are not used
7. Approval and attestation (for entities)

Penalties for non-compliance

Failure to comply can lead to summary conviction, fine of up to $250,000 and personal liability for directors, officers and agents. Key offences include:

• Failing to submit report annually
• Failing to make report publicly available on website
• Failure of federally incorporated companies to provide report to shareholders along with financial statements
• Knowingly providing false or misleading information / statements in the report

Getting ready

Preparing for the next reporting is not just about compliance – It’s an opportunity to strengthen your  supply chain and enhance transparency.  Seek to turn compliance into a competitive advantage.

Key actions to take include:

1. Review updated guidance from Public Safety Canada which clarified key aspects of the reporting process. Use this to better understand the reporting obligation and confirm what is applicable to the organisation.
2. Address any commitments in submitted reports to implement or improve processes to prevent and mitigate risks of forced and child labour.
3. Assess due diligence procedures. Identify gaps and remedial actions needed to enhance policies, processes and systems to better manage these risks across the supply chain.
4. Engage with suppliers to gather information on their policies, procedures and practices to manage these risks across their operations and sub-suppliers. Identify areas where additional support or collaboration is needed.
5. Provide trainings to staff on supply chain risks and responsible business practices. This would build awareness of potential high-risk areas and help improve the quality of risk assessments and stakeholder engagements.

How we can support you

Our team of sustainability experts provide guidance at every step. 

We can support with:

• Preparing / reviewing your PDF report and response to the online questionnaire
• Delivering trainings
• Mapping supply chain to identify high-risk areas
• Developing action plans to strength due diligence and risk management processes
• Producing and enhancing policies, supplier code of conduct and other key documents
• Defining target operating model and governance structures