Canada's Forced Labour & Child Labour Act: Reporting Due May 31

Do you know what you need to do?

Canada’s forced labour and child labour act comes into effect on January 1, 2024, and the responsibility to file a report on your supply chain is due on May 31st, 2024. The act is designed to remove or severely limit products of slave or child labour from the Canadian market.

What does this all mean for you?

Certain importers, exporters, and businesses that meet the criteria set out in the Fighting Against Forced Labour and Child Labour in Supply Chains Act?(the?Act) must satisfy the reporting requirements.

What businesses are subject to the Act? Those who are:

• “Producing, selling or distributing goods in Canada or elsewhere
• Importing into Canada goods produced outside Canada, or

• Controlling an entity engaged in either of the above activities”

The Act defines an entity as:

• ‘Is listed on a stock exchange in Canada
• Has a place of business in Canada, does business in Canada or has assets in Canada and, based on its consolidated financial statements for the last two financial years, has met at least two of the following three conditions:Had at least $20-million Canadian in assetsGenerated at least $40-million Canadian in revenueEmployed an average of at least 250 employees, or
• Is prescribed by regulations (no “other’ regulations have been made public)”

Reporting is similar to a PIP or CTPAT trade chain review but, rather than a view to security it is pointed at ethical labour practice within the supply chain. Each deemed entity will be required to file a report to the Canadian government. The report should contain certain detail such as:

• Their general structure, activities, and supply chains
• Their internal policies in relation to forced and child labour. As well as procedures to relating to identifying and mitigating the use of business partners who may utilize forced and child labour
• The parts of its business and supply chains carry a risk of forced or child labour being used in the various geographies where it may be prevalent.
• Steps it has taken to assess, manage, and/or mitigate that risk
• Internal training provided to employees on forced and child labour
• Any measures taken to remediate any forced or child labour
• Internal measures to assess the value of the loss of income to the victims of forced and child labour
• Internal reports or KPIs to determine the effectiveness of the entity’s policies regarding forced and child labour

Please note the list above is an example of the types of information that could be provided within an entity’s report.

Read the full article to learn more about Canada's Forced Labour and Child Labour Act

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