Organizations must meet reporting requirements by May 31
As the deadline for Canada’s Bill S-211 looms, health and safety professionals across the country are preparing to meet the reporting requirements mandated by the "Fighting Against Forced Labour and Child Labour in Supply Chains Act."
This legislation, which took effect in January, requires companies to disclose measures they are taking to address and mitigate risks of forced labour and child labour in their supply chains. With the first reporting deadline on May 31, organizations must ensure they are compliant to avoid penalties and enhance their supply chain transparency.
“Our team has been very dialed into the regulation even going back to last year," explains Alex Bowles, senior manager at Transparency-One, an ISN company, which is a contractor and supplier information management software company.
He’s been working with Canadian companies to meet the requirements outlined in the new regulation and remain compliant.
Understanding the requirements
The legislation mandates that businesses prepare a detailed report outlining the policies and practices they have in place to combat forced labour and child labour. This includes due diligence processes, risk assessments, and any actions taken to address identified risks. According to Bowles, the clarity of the Act’s criteria on revenue and assets in Canada means that most organizations should already know if the reporting requirement applies to them.
"For those organizations that are working through their report, there are key framework requirements that have been published in accordance with the Act that outline what exactly needs to be in this first report, ranging from examples of policies that need to be demonstrated to assessing risks in the supply chain," says Bowles. "The systems and processes that organizations must have in place to monitor forced labour risk on an ongoing basis are also detailed."
Challenges in compliance
One of the major challenges highlighted by Bowles is the complexity of auditing suppliers, particularly those located internationally who might be less concerned about Canadian regulations.
"It's critical that they have a clear understanding not only of their direct suppliers that are providing products but also the sub-suppliers," Bowles notes. "And that's, I think, where organizations will be really challenged especially after this May 31 deadline. It requires a couple of things: one, data capture in some form, so going out to suppliers, surveying them for information about who's in their supply chain, who these companies are, where they're located."
He added that some companies are outsourcing their auditing efforts to third-party groups, which conduct interviews, policy reviews, and other assessments to ensure compliance.
Proactive approaches and technology solutions
Bowles emphasized the importance of leveraging technology to manage the requirements effectively. "When we've been working with our customers, we've said if you're looking to technology, it should accomplish three things: communication of new expectations with suppliers, data capture from suppliers, and a screening mechanism for forced labour risk."
This approach includes using technology platforms to document interactions with suppliers, gather necessary data, and continuously monitor compliance against international standards and sanction lists. "Having a system in place to capture and assess this information is crucial for meeting the ongoing requirements of Bill S-211," Bowles advises.
Looking ahead
As the May 31 deadline approaches, Bowles underscores the necessity for organizations to be proactive. "The report itself asks for those details of the how, and then I think the organizations over the next coming year after May 31, they'll have to be more focused on executing these new systems."
For health and safety professionals, understanding and implementing the requirements of Bill S-211 is not just about compliance; it’s about contributing to a larger effort to eradicate forced and child labour from supply chains.
