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Fighting Against Forced Labour and Child Labour in Canadian Supply Chains Act

February 23, 2024

On January 1, 2024, Canada’s new anti-forced labour legislation, the Fighting Against Forced Labour and Child Labour in Supply Chains Act (The Act) came into effect. Certain entities and government institutions must submit an annual report to the Minister of Public Safety by May 31 of each year and make the reports available to the public.

The Act includes penalties of up to $250,000 for companies and officers that fail to comply with the reporting requirements or where the reports include false or misleading information. As such, it is important that you take action to ensure that you meet your reporting obligations in advance of the May 31 deadline.

Definitions

The Act defines an entity as a corporation or a trust, partnership, or other unincorporated organization that either:

  1. is listed on a stock exchange in Canada; or,
  2. 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:
    1. it has at least $20 million in assets,
    2. it has generated at least $40 million in revenue; and,
    3. it employs an average of at least 250 employees.

Applicability

The reporting requirements apply to entities:

  1. producing, selling or distributing goods in Canada or elsewhere;
  2. importing into Canada goods produced outside Canada; or,
  3. controlling an entity engaged in any activity described in paragraph (1) or (2).

If you feel your entity may meet the above criteria, we recommend that you seek appropriate legal counsel to determine your reporting requirements and be in compliance with The Act.