To combat modern slavery, the Ministry of Public Safety Canada has released updated guidelines for entities required to submit a modern slavery report under the new legislative act.
The enhanced guidance aims to refine the reporting process, ensuring thorough documentation and transparency in the fight against forced and child labour within supply chains. Entities bound by the act must comply with the reporting process by May 31, beginning with preparing a detailed report that adheres to the act's requirements. This involves internal consultations and data collection to ensure the report's completeness. Following the preparation, the report requires approval and attestation from the relevant governing bodies, affirming its accuracy and compliance.
An essential step involves completing an online questionnaire reflecting the report's contents, consisting of open and closed-ended questions designed to cover the act's stipulations. In cases where the online completion is impracticable, entities must submit their responses via email to the Ministry. The final steps include uploading the attested report in PDF format and publishing it on the entity's website, and making it accessible on Public Safety Canada's platform.
The report must encompass a wide range of information mandated by the act, such as the measures taken to mitigate the risks of forced and child labour within the entity's operations and supply chains, structure, policies, risk assessments, and training initiatives. It also calls for a review of the effectiveness of these measures in eliminating forced and child labour.
Moreover, the updated guidelines emphasized the need for entities to submit their reports and complete questionnaires in one of Canada's official languages. However, providing versions in both English and French is encouraged for broader accessibility. Reports are suggested not to exceed ten pages, although this is not a strict requirement.
Entities have the opportunity to use the questionnaire as a tool for drafting their reports, offering both mandatory and optional queries that facilitate a thorough exploration of their practices and policies regarding modern slavery. The guidance also allows for the inclusion of additional documents and links within the report, providing a comprehensive view of the entity's efforts and leadership in addressing forced and child labour risks.
The updated guidance underscored transparency and due diligence in corporate practices, aiming to improve entities' capabilities in identifying and addressing modern slavery risks. The government said it will continue to strengthen the reporting guidance. The reporting process and questionnaire may be subject to change in the coming years.