This article originally appeared on the Gowling WLG website.
With the May 31 deadline for filing a report less than a month away, Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act ("S-211") is now a "front burner" item for many Canadian businesses.
Reporting responsibilities
S-211 requires in-scope businesses and organizations that are required to report under this law ("Reporting Entity") to prepare and file with the federal Minister of Public Safety, a report ("S-211 Report") on or before May 31 of each calendar year.
The S-211 Report must set out the steps the Reporting Entity has taken during its previous financial year to prevent and to reduce the risk that forced labour or child labour is used at any step in the production of goods in Canada or elsewhere by the Reporting Entity, or at any step in the production of goods imported into Canada by the Reporting Entity. Seven other mandatory disclosure items must also be included.
In addition, the S-211 Report must also include the following information in respect of the Reporting Entity and any Entities that it controls:
- 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 Reporting Entity assesses its effectiveness in ensuring that forced labour and child labour are not being used in its business and supply chains.
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