Forced Labour Reporting · Canada
Canada’s annual report on forced labour and child labour, prepared section by section.
Fighting Against Forced Labour and Child Labour in Supply Chains Act (S-211)
The Act asks the entities it covers to report each year on the steps they took. The module works out whether the Act applies to you, takes you through each requirement with the Act’s words and Public Safety Canada’s guidance beside it, and produces the report as a PDF.
How people arrive here
Your first report is due
And the Act asks for a report that answers each of its requirements, which nobody in the business has written before.
You are near the size conditions
And you need to know whether the Act reaches you before the report is due.
A customer or lender asked for your report
And the one you publish has to stand up to being read closely.
What the Act asks
- Who must report
- An entity listed on a stock exchange in Canada, at any size, or one with a place of business, business or assets in Canada that meets at least two of three conditions in either of its two most recent financial years: CAD 20 million in assets, CAD 40 million in revenue, and an average of 250 employees. It must report if it produces, sells or distributes goods in Canada or elsewhere, imports goods into Canada, or controls an entity that does.
- When
- On or before May 31 each year, covering the previous financial year (section 11(1)).
- What the report contains
- The steps taken during the previous financial year to prevent and reduce the risk of forced labour or child labour, and, for each entity it covers: its structure, activities and supply chains; its policies and its due diligence processes in relation to forced labour and child labour; the parts of its business and supply chains that carry a risk of forced labour or child labour being used and the steps it has taken to assess and manage that risk; any measures taken to remediate any forced labour or child labour; any 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 activities and supply chains; the training provided to employees on forced labour and child labour; how the entity assesses its effectiveness in ensuring that forced labour and child labour are not being used in its business and supply chains.
- Format
- Public Safety Canada’s guidance: “The report must be submitted in PDF format and must not exceed 100MB in size.”
- Publishing
- Section 13(1): an entity must “on providing the Minister with a report under section 11 or a revised report under section 12, make the report available to the public, including by publishing it in a prominent place on its website”.
What the module covers for Canada
- Whether the Act applies
- The section 2 entity test and the section 9 activities, with the Act’s words and Public Safety Canada’s guidance quoted beside the result.
- Every requirement of section 11
- Structure and supply chains, policies and due diligence, risks, remediation, lost income, training and effectiveness, each with the Act’s words, a plain explanation and what readers look for.
- The steps taken during the year
- A summary drafted from your answers to the other sections, which you edit before it goes into the report.
- Approval and attestation
- The approval statement in the Act’s terms, and a signature block for each governing body that approved the report.
- Checks before export
- Missing answers, placeholders left in the attestation, and text that looks like personal information, all shown before the PDF is produced.
What it satisfies
Described, sourced and mapped to a module on the regulations page.
The module is $1,499/yr, includes the Canada report. About the module
Questions people ask first
Who has to report?
An entity listed on a stock exchange in Canada, at any size, or one with a place of business, business or assets in Canada that meets at least two of three conditions in either of its two most recent financial years: CAD 20 million in assets, CAD 40 million in revenue, and an average of 250 employees. It must report if it produces, sells or distributes goods in Canada or elsewhere, imports goods into Canada, or controls an entity that does. The free check works through it with your own figures.
When is the report due?
On or before May 31 each year, covering the entity’s previous financial year. That is section 11(1) of the Act.
What does the report contain?
The steps taken during the previous financial year to prevent and reduce the risk of forced labour or child labour, and, for each entity it covers: its structure, activities and supply chains; its policies and its due diligence processes in relation to forced labour and child labour; the parts of its business and supply chains that carry a risk of forced labour or child labour being used and the steps it has taken to assess and manage that risk; any measures taken to remediate any forced labour or child labour; any 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 activities and supply chains; the training provided to employees on forced labour and child labour; how the entity assesses its effectiveness in ensuring that forced labour and child labour are not being used in its business and supply chains. It ends with a statement of how the governing body approved it, and a signed attestation.
Does the module file the report for us?
No. The module produces the report as a PDF. Your organization still completes Public Safety Canada’s questionnaire, submits the report, and makes it public: section 13 of the Act says an entity must “on providing the Minister with a report under section 11 or a revised report under section 12, make the report available to the public, including by publishing it in a prominent place on its website”.
We only sell or distribute goods. Do we have to report?
Section 9(a) of the Act covers an entity producing, selling or distributing goods. Public Safety Canada’s current guidance says: “Entities solely involved in distributing and selling are not expected to report under the Act.” The check shows both, so you can see the Act’s words and the guidance’s position side by side.
Can one report cover several companies?
Yes, as a joint report. The guidance says: “Only submit a joint report if the information provided generally applies to all entities covered by the report.” The module lists each entity by its legal name and gives each governing body that approved the report its own signature block.
Is the result of the check legal advice?
No. It is a screening from the answers you give, with the Act and the guidance quoted so you can see what it rests on. Public Safety Canada’s guidance encourages an entity that is unsure whether the Act applies to seek advice from its legal counsel.
