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2025 Supply Chain Compliance: A Procurement Roadmap for Canada's Evolving Forced Labour Regulations

As you prepare your company's second Modern Slavery Statement due by May 31st, 2025, you're likely facing heightened expectations and evolving requirements. The landscape has notably shifted with two recent developments: Public Safety Canada's updated online guidance released in November 2024, and the Government's Fall Economic Statement published in December 2024. These documents signal a clear direction toward more rigorous reporting standards and increased scrutiny of your supply chain practices. If you're responsible for updating your company's statement, you know that navigating these new expectations while maintaining operational efficiency presents a significant challenge.


Based on our analysis of these recent developments, we've identified four key steps to help ensure your 2025 Modern Slavery Statement not only meets compliance requirements but also aligns with both government guidance and stakeholder expectations.



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Step 1: Update your risk assessment


Your risk assessment needs to evolve as your business landscape changes. We've identified three crucial approaches to ensure your risk assessment captures the current reality of your supply chain.


First, consider any actual risks that have materialised over the past year. Whether you were made aware of them through adverse media coverage, word of mouth, or direct experience within your supply chain, these concrete instances must be incorporated into your assessment, particularly if they weren't previously identified as potential risks.


Second, leverage the insights gained through your prevention and mitigation efforts. The data collected from questionnaires, audits, and training sessions provides valuable information that can help you refine your risk calculations. Use these learnings to update your assessment of likelihood, impact, and potential for improvement.


Finally, conduct a thorough sense-check of last year's assessment. Has your business scope changed through acquisitions or divestitures? Are you sourcing new products that weren't considered in your previous assessment? Review your risk scores in light of your accumulated knowledge and emerging global or sector-specific risks.

 


 

Step 2: Measure and demonstrate your impact


Following last year's risk assessment, you likely implemented various risk mitigation actions. Now is the time to showcase the effectiveness of these initiatives. Your statement should highlight concrete actions taken, such as enhanced risk understanding through training programs, improved supply chain traceability, supplier questionnaires, audits, and policy reinforcement.


Equally important is tracking the key performance indicators (KPIs) you established last year. Analyse your results carefully: Are they showing progress? If so, consider how to build on this momentum and achieve even better outcomes in the coming year. If not, examine what obstacles you encountered and how you can adjust your approach to achieve the desired impact.

 


 

Step 3: Align your report structure with new expectations


Public Safety Canada's updated guidelines introduce several important changes to report formatting and submission requirements. While the previous 10-page limit has been removed, your report must still be submitted as a PDF file not exceeding 100MB.


The attestation wording has also been updated. The specific declaration acknowledging compliance with the Fighting Against Forced Labour and Child Labour in Supply Chains Act, complete with your full name, title, date, and signature is available here.


Additionally, the timing of publication has become more stringent. Rather than publishing "at your earliest convenience," your report must now be posted in a prominent place on your company's website simultaneously with its submission to Public Safety Canada.

 


 

Step 4: Prepare for an update of the legislation


The 2024 Fall Economic Statement suggests significant changes on the horizon. Canada appears to be moving toward alignment with international supply chain due diligence legislation, potentially transitioning from a reporting-focused law to one requiring specific actions to combat forced labour in supply chains.


This shift could mirror developments in other jurisdictions, potentially expanding beyond forced labour to encompass broader sustainability topics including environmental impact, community relations, discrimination, and health and safety – similar to the French Duty of Vigilance or the European Corporate Sustainability Due Diligence Directive (CSDDD).


To prepare for these anticipated changes, consider taking four proactive steps:

  1. Expand your risk assessment to cover all ESG aspects, enabling you to develop a comprehensive and coherent responsible sourcing strategy.

  2. Invest in training and expertise to better understand the key risks in your supply chain.

  3. Improve traceability for high-risk categories by working with suppliers to identify raw material origins.

  4. Engage meaningfully with your suppliers and affected communities to raise awareness and collaboratively improve your supply chain.


This comprehensive approach will not only help you meet current requirements but also position your organisation to adapt smoothly to future legislative changes. By taking these steps now, you'll be better equipped to demonstrate your commitment to responsible sourcing and maintain compliance with evolving regulations.



 

 

Remember, your Modern Slavery Statement is more than a compliance document – it's an opportunity to demonstrate your organisation's commitment to ethical business practices and supply chain transparency. By following these guidelines and preparing for future developments, you're not just meeting legal requirements; you're contributing to the global fight against forced labour and child labour while building a more resilient and responsible supply chain.


Need support in updating your Modern Slavery Statement or developing your responsible sourcing strategy? Our team of experts is here to help you navigate these evolving requirements and strengthen your supply chain practices. Contact us today at info@beeaware-consulting.com or using the contact form for discovering how we can support your compliance journey.

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