{"id":5809,"date":"2026-05-21T16:07:30","date_gmt":"2026-05-21T16:07:30","guid":{"rendered":"https:\/\/affilia.legal\/?p=5809"},"modified":"2026-05-21T20:51:33","modified_gmt":"2026-05-21T20:51:33","slug":"beyond-compliance-tackling-child-and-forced-labour-in-global-supply-chains","status":"publish","type":"post","link":"https:\/\/affilia.legal\/en\/beyond-compliance-tackling-child-and-forced-labour-in-global-supply-chains\/","title":{"rendered":"Beyond Compliance: Tackling Child and Forced Labour in Global Supply Chains"},"content":{"rendered":"\n<p>Since 2024, May has become a race against the clock for many manufacturing and technology companies. Finalizing, approving, and filing their report on combating forced labour and child labour in supply chains is no longer optional \u2014 it is now a strategic imperative. Under the <em>Fighting Against Forced Labour and Child Labour in Supply Chains Act<\/em> (S.C. 2023, c. 9, formerly Bill S\u2011211), reporting entities must submit their report by May 31 each year to the Minister of Public Safety and Emergency Preparedness of Canada [1].<\/p>\n\n\n\n<h2 class=\"wp-block-heading\">Are you really subject to these reporting obligations? (Spoiler: more often than you\u2019d expect.)<\/h2>\n\n\n\n<p>In practice, many companies only realize they are subject to the law when it is almost too late. The<em> Act <\/em>notably targets private-sector entities that:<\/p>\n\n\n\n<ul class=\"wp-block-list\">\n<li>Have a place of business in Canada, conduct business in Canada or hold assets in Canada; and<\/li>\n\n\n\n<li>Meet at least two of the following three thresholds for at least one of their last two financial years:\n<ul class=\"wp-block-list\">\n<li>At least\u00a0$20,000,000\u00a0in assets<\/li>\n\n\n\n<li>At least\u00a0$40,000,000\u00a0in revenue<\/li>\n\n\n\n<li>An average of at least 250 employees<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n\n\n\n<p><\/p>\n\n\n\n<p>For many internationally oriented manufacturing and technology companies, the conclusion is clear: being in scope is the rule, not the exception. In 2025, the manufacturing sector alone accounted for nearly one quarter of reporting entities (24.9%), ahead of wholesale trade (11.8%), retail trade (8.9%), and transportation and warehousing (5.8%)\u00a0<a href=\"https:\/\/www.securitepublique.gc.ca\/cnt\/rsrcs\/pblctns\/2025-frcd-lbr-chld-lbr-spply-chns-ct-scnd-rprt\/index-en.aspx#a4\" target=\"_blank\" rel=\"noopener\">[2]<\/a>, which shows just how directly these obligations target complex supply chains.<\/p>\n\n\n\n<h2 class=\"wp-block-heading\">A Global Shift that Now Includes Canada<\/h2>\n\n\n\n<p>Canadian companies subject to the <em>Act<\/em> are not alone: they are part of a broader international wave that already affects their clients, partners, and competitors. Australia, the United Kingdom, the European Union, and California already impose, or are in the process of imposing, similar transparency or due diligence obligations regarding forced labour and child labour. In this context, thinking in terms of a \u201clocal market\u201d is no longer enough: a compliance failure in Canada can quickly become a global reputational risk, especially when international groups compare reports from one affiliate to another.<\/p>\n\n\n\n<p>It is precisely to promote transparency and encourage responsible business practices that Canada, Australia, and the United Kingdom have developed a common framework to help streamline reporting, even though each jurisdiction\u2019s requirements remain distinct <a href=\"https:\/\/www.securitepublique.gc.ca\/cnt\/cntrng-crm\/frcd-lbr-cndn-spply-chns\/ntrntnl-rprtng-frcd-lbr-chld-lbr-tmplt-en.aspx\" target=\"_blank\" rel=\"noopener\">[3]<\/a>. <\/p>\n\n\n\n<p>For an international company subject to rules in several jurisdictions, this creates an opportunity to organize its data and governance in a coherent way across those jurisdictions, rather than managing a patchwork of one-off, case\u2011by\u2011case requests.<\/p>\n\n\n\n<h2 class=\"wp-block-heading\">Transparency, Not an Admission of Failure<\/h2>\n\n\n\n<p>One frequent observation in practice is that many companies hesitate to \u201csay too much.\u201d They worry that acknowledging risks in their supply chains will be interpreted as an admission of wrongdoing. In reality, the <em>Act<\/em> is built on a logic of disclosure and transparency, not on an expectation of immediate, flawless results. An entity is not penalized for identifying areas of heightened risk; it is at greater risk if it claims to have none where risks clearly exist.<\/p>\n\n\n\n<p>Put differently, what regulators (and, at times, the market) are looking for is not perfection, but consistency: recognizing your risks, explaining how you map them, outlining the measures you have implemented, and what you plan to improve. It is this structured honesty that strengthens a company\u2019s credibility, not a narrative that is too polished to be believable.<\/p>\n\n\n\n<h2 class=\"wp-block-heading\">Turning a Compliance Obligation into a Strategic Advantage<\/h2>\n\n\n\n<p>For companies that engage seriously with the process, preparing the report quickly becomes much more than a box\u2011ticking regulatory exercise. The report itself is public, but all the work that goes into it (analyses, tools, programs) becomes valuable internal capital that supports both your risk management and your broader strategy.<\/p>\n\n\n\n<p>This preparation acts as a mapping tool for your supply chains, helping you better understand your blind spots and critical dependencies. It can also bring hidden issues to light: the places where forced or child labour risks are most plausible are often those where the flows are furthest removed from head office\u00a0<a href=\"https:\/\/www.international.gc.ca\/transparency-transparence\/study_forced_labour-etude_travail_force.aspx?lang=eng.\" target=\"_blank\" rel=\"noopener\">[4]<\/a>.<\/p>\n\n\n\n<p>For some reporting companies, this work ultimately becomes a key framework for managing reputational and litigation risk. Disasters such as the collapse of the Rana Plaza building in Bangladesh in 2013 have shown how a lack of on\u2011the\u2011ground insight can damage a brand, even from thousands of kilometres away\u00a0<a href=\"https:\/\/ici.radio-canada.ca\/nouvelle\/1972327\/rana-plaza-textile-vetement-effondrement-sang-ouvrier\" target=\"_blank\" rel=\"noopener\">[5]<\/a>. The measures you put in place to prepare your report help reduce that information gap and give you greater control over your risk profile.<\/p>\n\n\n\n<p>For this process to be truly effective, many reporting companies consider that it should be based on [6]:<\/p>\n\n\n\n<ul class=\"wp-block-list\">\n<li>Reliable, structured, and repeatable data collection<\/li>\n\n\n\n<li>A clear methodology for prioritizing risks (by country, type of input, sector, or supplier type)<\/li>\n\n\n\n<li>Tools and questionnaires tailored to the manufacturing and technology context, where the physical chain (components, raw materials, subcontracting) often overlaps with an intangible chain (services, cloud, data, R&amp;D)<\/li>\n<\/ul>\n\n\n\n<p><\/p>\n\n\n\n<p>It is precisely this work of structuring, rather than simply filling out a form, that generates real value.<\/p>\n\n\n\n<h2 class=\"wp-block-heading\"><strong>Plan, Prioritize, Progress<\/strong><\/h2>\n\n\n\n<p>Companies that are most successful in leveraging these new requirements tend to have one thing in common: they do not treat the report as a last\u2011minute sprint in April, but as a recurring, planned project. In practice, this can mean:<\/p>\n\n\n\n<ul class=\"wp-block-list\">\n<li>Starting early: setting up governance, clear roles, a timeline, and an internal approval process.<\/li>\n\n\n\n<li>Building year over year: not starting from scratch, but improving data quality, refining risk mapping, and documenting processes and decisions.<\/li>\n\n\n\n<li>Using the report as a management tool: setting concrete objectives for the following year (for example, covering a higher percentage of critical suppliers, rolling out a new contractual clause, or expanding the scope of audits).<\/li>\n<\/ul>\n\n\n\n<p><\/p>\n\n\n\n<p>Canadian guidance also supports a phased approach. This leaves room for gradual progress that reflects each organization\u2019s operational reality and capacity, rather than pushing companies into a one\u2011off \u201ccompliance showcase\u201d disconnected from how they actually operate.<\/p>\n\n\n\n<h2 class=\"wp-block-heading\"><strong>From Compliance to Competitiveness<\/strong><\/h2>\n\n\n\n<p>As transparency and due diligence regimes continue to proliferate around the world, efforts to combat forced labour and child labour are becoming a key factor in supplier selection. Buyers are looking for partners that are able to:<\/p>\n\n\n\n<ul class=\"wp-block-list\">\n<li>Produce clear, consistent, and credible reports.<\/li>\n\n\n\n<li>Demonstrate a genuine understanding of their supply chains.<\/li>\n\n\n\n<li>Show measurable progress, even if gradual, in reducing risks.<\/li>\n<\/ul>\n\n\n\n<p><\/p>\n\n\n\n<p>For a reporting manufacturing or technology company that exports or is part of international value chains, managing these obligations effectively therefore means:<\/p>\n\n\n\n<ul class=\"wp-block-list\">\n<li>Protecting its brands and limiting the risk of media or regulatory crises.<\/li>\n\n\n\n<li>Facilitating access to markets and tenders where ESG criteria are now decisive.<\/li>\n\n\n\n<li>Positioning itself as a reliable partner for global groups that are subject to similar requirements.<\/li>\n<\/ul>\n\n\n\n<h2 class=\"wp-block-heading\">How our Team can Help you Move Forward<\/h2>\n\n\n\n<p>In practice, many of the companies that come to us fall into one of the following situations:<\/p>\n\n\n\n<ul class=\"wp-block-list\">\n<li>They have just realized that they are subject to the law\u2026 and May 31 is fast approaching.<\/li>\n\n\n\n<li>They have produced a first \u201cminimal\u201d report and now want to raise the bar.<\/li>\n\n\n\n<li>They are already subject to foreign requirements (e.g., United Kingdom, EU, California) and need to harmonize their approach.<\/li>\n<\/ul>\n\n\n\n<p>Our typical support often includes:<\/p>\n\n\n\n<ul class=\"wp-block-list\">\n<li>Analysing whether you are in scope and determining the precise extent of your obligations.<\/li>\n\n\n\n<li>Designing the structure of the report: what to say, where to say it, and how to say it without understating your risks or over\u2011promising.<\/li>\n\n\n\n<li>Providing legal support and advice to establish or enhance a risk\u2011mapping approach tailored to your sector and inputs, in collaboration with your internal teams or specialised advisors.<\/li>\n\n\n\n<li>Assisting in defining a realistic multi\u2011year action plan from a legal and regulatory standpoint and, where needed, connecting you with trusted partners in our network for the operational and ESG components.<\/li>\n<\/ul>\n\n\n\n<p>If you believe your company may fall within the scope of these requirements, or if you would like to take a more professional and structured approach to reporting on efforts to combat forced and child labour in your supply chains, it is worth starting the conversation now rather than on the eve of the annual deadline. A member of our team can help you design your approach, manage your risk exposure, and turn this regulatory obligation into a genuine driver of value creation.<\/p>\n\n\n\n<p>________________________________________________________________________________________________________________________<\/p>\n\n\n\n<p>[1]\u00a0S. 2 (\u201cMinister\u201d) of the Act. See also s. 11(1) of the Act.<\/p>\n\n\n\n<p><a href=\"https:\/\/www.securitepublique.gc.ca\/cnt\/rsrcs\/pblctns\/2025-frcd-lbr-chld-lbr-spply-chns-ct-scnd-rprt\/index-en.aspx#a4\" target=\"_blank\" rel=\"noopener\">[2]<\/a>\u00a0https:\/\/www.securitepublique.gc.ca\/cnt\/rsrcs\/pblctns\/2025-frcd-lbr-chld-lbr-spply-chns-ct-scnd-rprt\/index-en.aspx#a4<\/p>\n\n\n\n<p><a href=\"https:\/\/www.securitepublique.gc.ca\/cnt\/cntrng-crm\/frcd-lbr-cndn-spply-chns\/ntrntnl-rprtng-frcd-lbr-chld-lbr-tmplt-en.aspx\" target=\"_blank\" rel=\"noopener\">[3]<\/a>\u00a0https:\/\/www.securitepublique.gc.ca\/cnt\/cntrng-crm\/frcd-lbr-cndn-spply-chns\/ntrntnl-rprtng-frcd-lbr-chld-lbr-tmplt-en.aspx<\/p>\n\n\n\n<p><a href=\"https:\/\/www.international.gc.ca\/transparency-transparence\/study_forced_labour-etude_travail_force.aspx?lang=eng.\" target=\"_blank\" rel=\"noopener\">[4]<\/a>\u00a0<a href=\"https:\/\/www.international.gc.ca\/transparency-transparence\/study_forced_labour-etude_travail_force.aspx?lang=eng\" target=\"_blank\" rel=\"noreferrer noopener\">https:\/\/www.international.gc.ca\/transparency-transparence\/study_forced_labour-etude_travail_force.aspx?lang=eng<\/a>.<\/p>\n\n\n\n<p><a href=\"https:\/\/ici.radio-canada.ca\/nouvelle\/1972327\/rana-plaza-textile-vetement-effondrement-sang-ouvrier\" target=\"_blank\" rel=\"noopener\">[5]<\/a>\u00a0<a href=\"https:\/\/ici.radio-canada.ca\/nouvelle\/1972327\/rana-plaza-textile-vetement-effondrement-sang-ouvrier\" target=\"_blank\" rel=\"noreferrer noopener\">https:\/\/ici.radio-canada.ca\/nouvelle\/1972327\/rana-plaza-textile-vetement-effondrement-sang-ouvrier<\/a><\/p>\n\n\n\n<p>[6]\u00a0Align with the Government of Canada\u2019s guidance on this issue.<\/p>\n\n\n\n<p><\/p>\n","protected":false},"excerpt":{"rendered":"<p>Since 2024, May has become a race against the clock for many manufacturing and technology companies. Finalizing, approving, and filing their report on combating forced labour and child labour in supply chains is no longer optional \u2014 it is now a strategic imperative. Under the Fighting Against Forced Labour and Child Labour in Supply Chains [&hellip;]<\/p>\n","protected":false},"author":21,"featured_media":5808,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"footnotes":""},"categories":[126],"class_list":["post-5809","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-transactions-internationales"],"acf":[],"_links":{"self":[{"href":"https:\/\/affilia.legal\/en\/wp-json\/wp\/v2\/posts\/5809","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/affilia.legal\/en\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/affilia.legal\/en\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/affilia.legal\/en\/wp-json\/wp\/v2\/users\/21"}],"replies":[{"embeddable":true,"href":"https:\/\/affilia.legal\/en\/wp-json\/wp\/v2\/comments?post=5809"}],"version-history":[{"count":0,"href":"https:\/\/affilia.legal\/en\/wp-json\/wp\/v2\/posts\/5809\/revisions"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/affilia.legal\/en\/wp-json\/wp\/v2\/media\/5808"}],"wp:attachment":[{"href":"https:\/\/affilia.legal\/en\/wp-json\/wp\/v2\/media?parent=5809"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/affilia.legal\/en\/wp-json\/wp\/v2\/categories?post=5809"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}