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What You Need To Know About

Canada Modern Slavery Act

What is it?

The Canadian government recently enacted the Modern Slavery Act, which aims to combat forced labor and human trafficking in global supply chains.

The Act requires companies with at least $330 million in annual gross revenue to report on measures taken to address the risk of forced labor in their operations and supply chains. The reporting requirements are aligned with international standards, and companies must provide information on their policies, due diligence, and remediation efforts.

Failure to comply with the reporting requirements can result in fines and reputational damage. The Act is part of a global trend towards increased regulatory scrutiny of supply chain practices and underscores the importance of companies proactively addressing human rights risks in their operations.

Who does it apply to?

Any company that is listed on stock exchange in Canada; or has a place of business in Canada, does business in Canada or has assets in Canada and (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.

  • Any company that has at least $20 million in assets
  • Any company that has generated at least $40 million in revenue
  • Any company that employs an average of at least 250 employees
What are the penalties for non compliance?

The Act grants significant investigative authority to individuals appointed by the minister, and the minister has wide discretion to demand any measures deemed necessary to ensure compliance from an entity.

Failure to comply with the Act, including failing to prepare or publish a report, refusing to assist or obstructing an investigation, or disobeying a corrective order, constitutes an offense punishable by summary conviction and a fine of over $250,000.

Providing knowingly false or misleading information to the minister or designated personnel also constitutes an offense, punishable by summary conviction and a fine of up to $250,000. Furthermore, any director, officer, agent, or employee who directed, authorized, assented to, acquiesced in, or participated in the offense is liable for the punishment provided for the offense, regardless of whether or not the entity was prosecuted or convicted.

What are the requirements?

The Act requires that on or before May 31 of each year, government institutions and entities report to the Minister of Public Safety and Emergency Preparedness on the steps taken during the previous financial year to prevent and reduce the risk that forced labor or child labour is used (i) in the case of government institutions, at any step of the production of goods produced, purchased or distributed by the government institution; and (ii) in the case of entities, at any step of the production of goods in Canada or elsewhere by the entity or of goods imported into Canada by the entity.

The report must also include information about the government institution’s or entity’s:


Structure, activities and supply chains

FRDM risk maps your supply chain and monitors risk at all levels, including risky commodities like cobalt, cotton and palm oil.

Policies and due diligence processes in relation to forced/child labor

FRDM helps assess your company’s policies and procedures as well as federating the policies and procedures of all suppliers.


Activities and supply chains that carry a risk of forced or child labor

Reporting must include information about a company's risk analysis of the entire supply chain and the steps it has taken to assess and manage that risk. FRDM’s risk algorithm is trusted by businesses and governments to determine risk and prioritize oversight. All mitigation activities are logged on FRDM with ability to report out.

Measures taken to remediate forced or child labour

Once risk is determined FRDM offers multiple mitigation tools to address risk.


Measures taken to remediate the loss of income

incurred by the most vulnerable families that results from any measure taken to eliminate the use of forced or child labour from its activities and supply chains. If an infraction is found, FRDM can assist in any remediation efforts. 5% of your subscription fee is donated to charities working to reduce forced and child labor.

Training provided to employees

on forced and child labour; and process for assessing its effectiveness in ensuring that forced and child labour are not being used in its activities and supply chains.FRDM has some of the world’s best training material about forced labor. FRDM owns and controls, the world’s largest awareness app on forced labor which has informed over 35 million people worldwide.


The minister must maintain an electronic registry of all submitted reports, and the registry must be made available to the public on the Department of Public Safety and Emergency Preparedness website. The minister also has the discretion to impose specifications on the form and manner in which reports are to be provided.

FRDM is a leader in supply chain risk management and modern slavery mitigation. We serve Fortune 500 clients. Our technology has been covered by CNN, Vogue, New York Times, Fast Company, Wall Street Journal and others.

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