On May 11, 2023, Canada passed An Act to enact Fighting Against Forced Labour and Child Labour in Supply Chains Act and to amend the Customs Tariff (the “Act”). As we reported previously, the Act will create supply chain transparency and reporting obligations for certain companies as part of Canada’s efforts to fight against forced labour and child labour in Canadian supply chains.

What Obligations Are Placed on Companies?

Covered companies will be required to report to the Minister of Public Safety and Emergency Preparedness (the “Minister”) on or before May 31 of each year. Group companies may provide a joint report.

The report must include the steps the company has taken during the previous financial year to prevent and reduce the risk that forced labour or child labour is used at any step of the production of goods in Canada or elsewhere by the company, or of goods imported into Canada by the company.

The report must also include information about the company’s:

1. Structure, activities and supply chains;
2. Policies and due diligence processes in relation to forced labour and child labour;
3. Parts of its business and supply chains that carry a risk of forced labour or child labour, and the steps it has taken to assess and manage that risk;
4. Measures taken to remediate any forced labour or child labour;
5. Measures taken to remediate the loss of income to the most vulnerable families that results from any measure taken to eliminate the use of forced labour or child labour in its...

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