Bill S-211 – Forced Labour in Canadian Supply Chains

Forced labour can be found in every country and every sector. The risk occurs primarily through the global supply chains of businesses. Entities and government institutions doing business in Canada have a responsibility to ensure that exploitative practices are addressed and eradicated from their supply chains.  

Public Safety Canada recently released information to assist supply chain parties fulfill their reporting obligations under Bill S-211.

The Supply Chains Act comes into force on January 1, 2024, at which time certain entities and government institutions will be required to submit an annual report to the Minister of Public Safety by May 31st of each year. Reports must detail the steps taken during the previous financial year to prevent and reduce the risk that forced labour or child labour is used by them or in their supply chains.

“Entities” include 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 any of these activities. Additionally, the entity must either be listed on a stock exchange in Canada or 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
  • An average of 250 or more employees

“Government institution” is defined in the Act as:

  • any department or ministry of state of the Government of Canada, or any body or office, listed in Schedule I, and
  • any parent Crown corporation, and any wholly-owned subsidiary of such a corporation, within the meaning of section 83 of the Financial Administration Act (FAA).

Further details about the reporting process and guidance for reporting entities are available at: Forced Labour in Canadian Supply Chains (publicsafety.gc.ca)

Public Safety Canada will hold an information session on the reporting process on January 11, 2024. You can register using the links below:

 English Session: https://canada.webex.com/weblink/register/re06877e3ba8251d24fd83cda08cb2563

Séance en français: https://canada.webex.com/weblink/register/rce7ea55e5809bb25d8012265ad75756b