April 30, 2024

Bill S-211 Summary

As of January 1, 2024, Bill S-211 has come into force to promote transparency in the supply chains of Canadian companies, specifically as it relates to forced labor. The first risk report is due May 31st and each year thereafter, with fines for non-compliance totaling up to CA $250,000. Canadian firms that qualify include those that are publicly listed or those that import or produce or sell or distribute goods, regardless of destination, and have two of the three following attributes: sales over CA $40m, assets over CA $20m, or staff over 250, at a global level. Impacted entities must submit a risk report, populate a questionnaire, and make the risk report data available on their website.

Report Requirements

Entities subject to Bill S-211 are required to develop a 10-page supply chain risk report on an annual basis, published with the Canadian Federal Government on or before May 31st of each year, detailing the steps the business has taken during its previous financial year to prevent and reduce the risk of forced labor or child labor in the supply chain. The report will also need to include further information about the business and how it complies with the bill. This includes:

  • Business and Supply Chain Structure
  • Risk Management Processes
  • Policies and Due Diligence
  • Risk Concentrations and Assessments
  • Forced Labor Remediation
  • Supply Chain Training
  • Monitoring and Governance

The report’s contents must also be available on your website, and a survey is required to be completed online.

Risks of Noncompliance

It is crucial that you are well prepared and informed about annual reporting requirements and the risks of non-compliance, which can include:

  • Risk of reputation damage
  • Disruption to business continuity and growth
  • Being subject to fines up to CA $250,000

How We Can Help

If you need support addressing Bill S-211 for items such as supply chain risk assessments, gap analysis and strategy setting, reporting management, or implementation and governance matters, you can contact your GBQ advisor.

 

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