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Canadian Modern Slavery Act: Insights from New Guidance

In the realm of corporate responsibility, Canada is ushering in a new era with the introduction of the Modern Slavery Act. As companies prepare for their inaugural Modern Slavery reports, the recent guidance released by Public Safety Canada at the end of December serves as a compass, providing essential insights into the intricacies of compliance.

Public Safety Canada's newly launched portal proves to be a valuable resource, offering a comprehensive overview of reporting obligations, essential resources, and a repository for future submissions ('online catalogue'). Beyond the basics, the portal also houses guidance for entities, streamlining the often-complex process.


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A mandatory questionnaire

The standout feature in this release is the introduction of a mandatory questionnaire that must be completed before submitting the report. This questionnaire spans a significant number of questions, covering each requirement outlined in the Act, both through closed and open-ended inquiries. Notably, this questionnaire will be made publicly available.

What does this mean for entities? The questionnaire ensures a standardised approach, fostering consistency across reports. It also serves as a valuable tool for companies, providing a structured template that can guide the report's narrative. Companies have the option to align their reports with the questionnaire structure, a choice that can significantly facilitate benchmarking exercises in the future.

However, entities still need to upload their report on a “prominent” place in their website.  If they are registered under the CBCA (Canada Business Corporations Act), they also have to send it to their shareholders along with the annual financial statements



Format: concise and accessible

When it comes to the report itself, the guidance emphasises brevity and clarity. The prescribed format mandates a PDF file of less than 100MB, with a length restriction of 10 pages in either English or French. For bilingual reports (which are highly recommended by the guidance), a maximum of 20 pages is permitted. Simplicity and accessibility are key, urging companies to use language that is easily comprehensible and to explain any unfamiliar terms. The focus should remain on concrete actions taken, with the option to include an action plan.

Moreover, each report must feature a signed attestation from the relevant governing body, affirming the accuracy and completeness of the provided information. The guidance provides specific language for this attestation, ensuring a standardised and unequivocal commitment.



Definition clarifications and non-compliance guidelines

The guidance extends further clarity on critical terms within the Act, such as "entity" and the often-debated "business presence in Canada." Applying common sense, an entity is deemed to do business in Canada when various activities, from production and distribution to employee presence and contractual engagements, are conducted within the country.

The guidance also outlines the specific scenarios constituting non-compliance:

  • The report is false or misleading

  • Elements under subsections 11(1) or 11(3) of the Act are missing

  • The report has not received the required approvals and does not include the signed attestation

  • The report exceeds the page limit or does not comply with the required format. However, the flexibility to provide links to publicly available information is acknowledged. 

Finally, the guidance offers detailed expectations for each of the seven requirements.



As companies embark on this new reporting journey, BeeAware Consulting stands ready to provide tailored assistance. Our expertise encompasses a spectrum of services, including in-depth risk assessments, strategic supplier engagement, and the establishment of robust reporting frameworks. For personalised guidance on navigating the Canadian Modern Slavery Act, reach out to us at

To understand the essentials of the Canadian Modern Slavery Act, explore our previous article here.


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