Human Rights Services

Bold commitments require meaningful action.

With the enactment of S-211, the Fighting Against Forced Labour and Child Labour in Supply Chains Act, Canada is taking steps to address modern slavery here and everywhere.

When this law comes into effect on January 1, 2024, it will impose annual reporting obligations on any corporation, trust, partnership or other unincorporated organization whose activities include producing, selling or distributing goods in Canada or elsewhere, importing goods into Canada, or controlling an entity engaged in these activities.

The law will apply to entities listed on stock exchanges in Canada. It will also apply to organizations that have a place of business in Canada, do business in Canada, or have assets in Canada and meet two of the following three criteria for at least one of its two most recent financial years:

• $20 million or more in assets
  
  
• $40 million or more in revenue
  
  
• 250 or more employees

What does that mean for you?

Organizations from coast to coast must determine what their reporting requirements will be in this new environment. Getting there starts by assessing whether your organization falls into one of two key categories:

Private sector organizations that are:

• Listed on the Toronto Stock Exchange
  
  
• Connected to Canada and meet specific conditions around assets, revenues and number of employees
  
  
• Prescribed by regulations

Public sector organizations that are:

• Federal government institutions, ministries and departments, including Crown corporations

Once you’ve determined the implications for your organization, it’s time to prepare for a new world of reporting responsibilities. You’ll need to file reports electronically with the Minister of Emergency Preparedness by May 31, 2024, publish reports prominently on your organization’s website and provide shareholders with a copy alongside financial statements.

Failure to comply could be costly, including:

• Fines of up to $250,000
  
  
• Liability for directors, officers and individuals who knowingly make false or misleading statements and attest to the report

How can you prepare now?

To build out an effective reporting process, start by:

• Assessing your business and your supply chains for forced labour and child labour risks
  
  
• Reviewing your own and your suppliers’ policies and procedures to address forced labour risks in the supply chain
  
  
• Updating supplier due diligence and remedying identified instances of child or forced labour
  
  
• Increasing communication and transparency with suppliers
  
  
• Carrying out employee training to maintain good governance over the long term

At EY, we can help you navigate this landscape while building flexibility and adaptability into the process — so you’re ready for what comes next. How?