Empowering Ethics, Securing Supply Chains: Transforming Business with Bill S-211
We can help make sure that you have a ethical supply chain that you are proud to show to the world.
Bill S-211, known as the Fighting Against Forced Labour and Child Labour in Supply Chains Act, enters in to force on January 1, 2024 and aims to address the issue of forced labor and child labor in supply chains. This act requires certain entities to publicly report on their efforts to prevent and reduce the risk of forced labor and child labor in their supply chains. It mandates transparency and accountability, compelling businesses to disclose information regarding their due diligence measures and the steps taken to ensure their products are free from such labor practices. The legislation seeks to raise awareness, promote responsible sourcing, and encourage companies to take proactive measures in combating forced labor and child labor within their supply networks.
Who Will Have Reporting Obligations?
Reporting entities include all Canadian federal government institutions and departments, Crown corporations and their wholly-owned subsidiaries, as well as any other private sector "entity" that is:
a. producing, selling or distributing goods in Canada or elsewhere;
b. importing into Canada goods produced outside Canada; or
c. controlling an entity engaged in any activity described in paragraph (a) or (b), with control defined broadly as any direct or indirect control or common control "in any manner".
An "entity" is defined as a corporation or a trust, partnership or other unincorporated organization that:
a. is listed on a stock exchange in Canada;
b. has a place of business in Canada, does business in Canada or has assets in Canada and that, based on its consolidated financial statements, meets at least two of the following conditions for at least one of its two most recent financial years:
i. it has at least C$20 million in assets,
ii. it has generated at least C$40 million in revenue, and
iii. it employs an average of at least 250 employees;
or
c. is otherwise prescribed by regulations, which have yet to be enacted.
The first report deadline will be May 31, 2024.
What Information Needs to Be In The Report?
The first report deadline will be May 31, 2024 and must include the following information in respect of each entity subject to the report:
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; and
how the entity assesses its effectiveness in ensuring that forced labour and child labour are not being used in its business and supply chains.
Adhering to these guidelines ensures companies actively assess, address, and disclose their efforts in combating forced labor and child labor within their supply chains, promoting accountability and transparency in their operations.
How Can We Help?
We are here to help make sure that your company is properly covered when it comes to Bill S-211. We do that by providing a comprehensive package that includes:
Risk Assessment and Gap Analysis: Evaluate existing supply chains to identify areas of non-compliance with Bill S-211.
Compliance Strategy Development: Create customized strategies to align supply chain practices with the requirements of the Act.
Policy and Procedure Development: Draft and implement policies addressing forced labor and child labor, ensuring they comply with S-211 regulations.
Supplier Audits and Monitoring: Conduct audits of suppliers to ensure adherence to compliance standards and establish ongoing monitoring systems.
Training and Education Programs: Develop training modules to educate stakeholders and employees on recognizing, preventing, and reporting instances of forced labor and child labor.
Due Diligence Support: Provide guidance on due diligence processes and assist in implementing measures to verify compliance across the supply chain.
Reporting and Documentation Assistance: Help in preparing the necessary reports and documentation required by Bill S-211.
Communication with the Minister: Liaise with government officials to ensure that the report covers all necessary information and satisfies requirements.
Supply Chain Transparency Solutions: Implement technologies or systems to enhance transparency within the supply chain, enabling better tracking and monitoring of labor practices.
Legal Compliance Advisory: Offer legal guidance and support in understanding and implementing the legal requirements outlined in Bill S-211.
Continuous Improvement Strategies: Assist in developing strategies for continuous improvement, ensuring ongoing compliance and ethical practices within the supply chain.
Crisis Management and Response Planning: Develop protocols and plans to address and mitigate any instances of non-compliance or labor-related crises within the supply chain.