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Can You Stop Exploitation in Your Supply Chain?

In democracies, we vote for various levels of government hoping they will execute and create policies in alignment with our interests and values. But whether we are conscious of it or not, we also vote with how we decide to spend our money. Unfortunately, at least some of the goods that we rely on today are a product of forced and/or child labour. And like the law, being unaware does not absolve us from responsibility and indirectly contributing to the problem.

In Canada, formerly known as Bill S-211, Fighting Against Forced Labour and Child Labour in Supply Chains Act and to amend the Customs Tariff is set to take effect. I included some of the most crucial parts of the Act below, but you can do additional research at Public Safety Canada's website.

Who does it apply to:

Canadian linked entity that meets two of the three following conditions in one of the last two financial years:

  1. Had $20 million or more in assets

  2. Generated at least $40 million in revenue or

  3. Employed an average of at least 250 employees.

What is required:

The Act primarily requires that entities report their efforts to address forced and child labour but doesn't necessarily prescribe how it is accomplished. I am sure that methods to identify and prevent forced and child labour will become more effective over time.

Reports to be submitted to the Minister of Public Safety on or before May 31, of each year must include:

  • The steps the entity has taken during its previous financial year to prevent and reduce the risk that forced labour or child labour is used at any step of the production of goods in Canada or elsewhere by the entity or of goods imported into Canada by the entity.

  • 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.

In addition to submitting the report to the Minister, the entity must make the report available to the public, including by publishing it in a prominent place on its website.

In the case of entities incorporated under the Canada Business Corporations Act or under any other Act of Parliament, the report must also be distributed to each shareholder, along with its annual financial statements.

Definition of child and forced labour:

Child labour means labour or services provided or offered to be provided by persons under the age of 18 years and that

  1. are provided or offered to be provided in Canada under circumstances that are contrary to the laws applicable in Canada;

  2. are provided or offered to be provided under circumstances that are mentally, physically, socially, or morally dangerous to them;

  3. interfere with their schooling by depriving them of the opportunity to attend school, obliging them to leave school prematurely, or requiring them to attempt to combine school attendance with excessively long and heavy work; or

  4. constitute the worst forms of child labour as defined in article 3 of the Worst Forms of Child Labour Convention, 1999, adopted at Geneva on June 17, 1999. (travail des enfants)

Forced labour means labour or service provided or offered to be provided by a person under circumstances that

  1. could reasonably be expected to cause the person to believe their safety or the safety of a person known to them would be threatened if they failed to provide or offer to provide the labour or service; or

  2. constitute forced or compulsory labour as defined in article 2 of the Forced Labour Convention, 1930, adopted in Geneva on June 28, 1930. (travail forcé)


I don't think I have to argue the moral or social case against forced and child labour and while there may be a short-term financial gain for the perpetrators, it isn't in the long-term economic interest of a business or society to repress others for cheap or free labour. This form of labour stunts skills development and innovation which are the true drivers of economic progress.

If you want 1 year of prosperity, grow grain. If you want 10 years of prosperity, grow trees. If you want 100 years of prosperity, grow people. - Chinese Proverb


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