After several stalled efforts in recent years (see previous Bennett Jones blog posts on Bill C-423 and Bill S-216), Parliament is poised to pass a supply chain transparency law aimed at preventing and reducing the risk of forced labour and child labour in supply chains. Private members Bill S-211, "An Act to enact the Fighting Against Forced Labour and Child Labour in Supply Chains Act and to amend the Customs Tariff", is expected to pass third reading in the House of Commons shortly and will have immediate implications for Canadian business and importers.
Bill S-211 proposes to introduce a public reporting regime that will require many government institutions and private sector entities to submit a public annual report explaining the steps they have taken in the previous fiscal year to prevent and reduce the risk that forced labour and child labour is used at any step of the production of goods in Canada or elsewhere by the entity or of goods imported into Canada by the entity. Private sector entity reports would be filed with the Minister of Public Safety and Emergency Preparedness on or before May 31 of each year. This means that if the Bill passes and receives Royal Assent in 2023, the first reports due in May 2024 must address steps government institutions and companies are taking this fiscal year to address these risks.
The passage of Bill S-211 would create a further compliance imperative in the form of public and stakeholder scrutiny of the forced labour track...
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