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With the enforcement of the Fighting Against Forced Labour and Child Labour in Supply Chains Act (Bill S-211) on January 1, 2024, companies face new challenges and responsibilities. Recently, the Minister of Public Safety and Emergency Preparedness released updated guidance to assist organizations in navigating the intricacies of compliance.
Bill S-211 aims to fulfill Canada’s commitment to fight forced and child labor by mandating reporting. It promotes ethical business by increasing transparency and penalizing non-compliance.
Is your business prepared for Bill S-211?
The law impacts companies and partnerships in manufacturing, selling, or importing goods globally or in Canada. Entities listed on Canadian exchanges, with Canadian operations or assets, and meeting financial thresholds are subject to this legislation.
Separate Entity Determinations for Parent and Subsidiary Companies
One crucial aspect highlighted in the updated guidance is the requirement for parent and subsidiary companies to make separate entity determinations. This ensures a comprehensive evaluation of each entity’s compliance status based on its individual financial standing.
Clarification on Reporting Triggers
The updated guidance introduces clarity regarding reporting triggers by removing references to “distributing” and “selling.” This change prompts entities to reassess their reporting strategies and adjust compliance efforts accordingly.
Format and Length of Reports
Entities have more flexibility with clearer guidelines on report format and length. Although the 10-page recommendation is now advisory, the 100MB size limit stays, enabling more detailed reports without unnecessary limits.
Filing Deadlines and Obligations
Entities must file their first reports by May 31, 2024, and annually after, following strict deadlines. This requirement applies not only to corporations but also to federal government institutions, underscoring the Act’s broad reach.
In preparation for compliance, organizations are urged to revisit previous guidance, familiarize themselves with updated requirements, and utilize available resources. By proactively addressing the Act’s mandates, companies can play a vital role in combating forced labor and child labor in global supply chains.
Is your business ready for Bill S-211?
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