On March 7, 2024, the Canadian government updated the governmental guidance concerning the new modern slavery reporting legislation, specifically targeting entities involved in producing, selling, or importing goods. This updated guidance is relevant to the Fighting Against Forced Labour and Child Labour in Supply Chains Act which came into force on January 1, 2024. Along with publishing the amended guidance, the government also released a resource for frequently asked questions. Among the updates in the guidance, is the clarification on which reporting entities are required to submit a detailed online questionnaire and report by May 31, 2024, about actions taken to mitigate forced labour and child labour in their supply chains for the previous fiscal year.
Key points from the update include:
Clarification on Reporting Obligations: The updated guidance narrows the focus on entities that produce or import goods, slightly moving away from those who only sell or distribute goods. Despite this, the Act remains unchanged.
Determining Reporting Entity Status: Entities can use financial and tax records to assess their obligations to report under the Act. Subsidiaries must independently assess their reporting requirements, irrespective of their inclusion in parent company reports.
Note: Given the nature of our sector’s activities, credit unions and Centrals are not expected to engage in activities the Act targets or comply with its reporting requirements.
If you would like to discuss this further, please reach out to Gavin Karaiskos.