Compliance Briefing — February 14, 2025

Executive briefing: The Fighting Against Forced Labour and Child Labour in Supply Chains Act (S.C. 2023, c. 9) requires covered federal and provincially listed entities to file annual reports with Public Safety Canada and publish them online by May 31, 2025. After the inaugural 2024 filings, compliance teams must strengthen supplier assessments, remediation evidence, and governance for the second reporting cycle.

Key compliance checkpoints

Board approval. Section 11 mandates that reports receive approval from the governing body (board or equivalent) and include director signatures.
Risk assessment detail. Reports must describe forced labour risk identification, prioritisation, and mitigation steps, including audits and supplier training.
Remediation evidence. Entities must explain remediation for identified incidents and describe support provided to affected workers.

Control alignment

Supplier management. Integrate Act requirements into third-party questionnaires, contract clauses, and on-site audits.
Data integration. Link procurement, ESG, and legal systems to consolidate remediation logs, training records, and grievance outcomes.
Publication readiness. Prepare bilingual (English/French) reports, accessible PDFs, and web publishing processes to satisfy Section 11(3).

Enablement moves

Set interim deadlines for supplier attestations, risk scoring updates, and board review materials.
Coordinate with global modern slavery reporting regimes (UK, Australia) to harmonise metrics and narratives.
Develop KPIs covering supplier risk tiers, grievance resolution time, and training completion to show progress year-over-year.

Sources

Zeph Tech aligns Canadian supply chain transparency programmes with global human rights due diligence obligations, ensuring credible reporting and remediation evidence.