Canada’s new Modern Slavery Act is an extension of good social procurement practices

Jul 31st, 2023

Canada’s Federal Government is introducing measures to tackle modern slavery and other forms of forced labour in global supply chains.

Bill S-211, An Act to enact the Fighting Against Forced Labour and Child Labour in Supply Chains Act and to amend the Customs Tariff, referred to as Canada’s “Modern Slavery Act” (the Act), is expected to come into effect on January 1, 2024.

In 2018, The House of Commons Subcommittee on International Human Rights (SDIR) released a report on child labour in supply chains. It was recommended that the Canadian government review other jurisdictions supply chain legislation when developing policy and initiatives aimed at addressing any form of child labour in supply chains. The Act is one of many efforts to address forced and child labour in supply chains and differs from previous government actions to combat modern slavery because it likely captures entities not previously considered.

At Buy Social Canada we view the new Modern Slavery Act as an extension of what a good social procurement policy or program should be delivering. Social procurement is about using your existing purchasing to capture best value and help shape inclusive, vibrant and healthy communities.

Who the act applies to


A corporation or a trust, partnership or other unincorporated organization that:

  • (a) is listed on a stock exchange in Canada;
  • (b) 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:
    • (i) it has at least $20 million in assets,
    • (ii) it has generated at least $40 million in revenue, and
    • (iii) it employs an average of at least 250 employees; or
  • (c) is prescribed by regulations. (entité)

Government institutions

  • (a) any department or ministry of state of the Government of Canada, or any body or office, listed in Schedule I, and
  • (b) any parent Crown corporation, and any wholly-owned subsidiary of such a corporation, within the meaning of section 83 of the Financial Administration Act; (institution fédérale)

What will the report need to include?

The Act requires that certain entities and government institutions report on:

  • The steps the entity or government institutions has taken during their previous financial year to prevent and reduce the risk of forced and child labour at any step of the production of goods in Canada or elsewhere or of goods imported into Canada.
  • Its structure, activities, and supply chains.
  • Its policies and 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 entity assesses its effectiveness in ensuring that forced labour and child labour are not being used in its business and supply chains.

The report must be submitted to the Minister before or by May 31, where it will be made publicly available. The report must also be made publicly available in a prominent place on the organization’s website.

Where does my organization begin?

Buy Social Canada encourages all organizations to learn about their supply chain, where risks could exist, and ways to prevent and minimize risks of forced labour or child labour. As social procurement experts, we acknowledge that the journey to end modern slavery will take time, resources, and long-term commitments. It won’t simply mean cutting ties with guilty suppliers, it will mean developing the policy frameworks and tools to ensure the issue is addressed and real change happens.

Stay tuned to learn more about how your social procurement program can help shape stronger supply chains that are free of forced and child labour. The Buy Social Canada team will be working to prepare reporting criteria and processes to share with our partners and clients.

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