By 2018, the conversation around modern slavery in Canadian supply chains had regained momentum, even though Bill C-383—the proposed Modern Slavery Act introduced as a private member’s bill in 2016—had failed to pass. That legislative defeat did not put the issue to rest. If anything, it created space for new coalitions of lawmakers, industry groups, and civil society organizations to reconsider how Canada might address forced labor risks embedded in its import and production networks. The year marked an inflection point where voluntary action began to fill gaps left by the absence of binding law, as key sectors started to take cues from international peers.
The apparel industry and the mining sector were at the forefront of this shift. Both had long been in the spotlight, given the complex and often opaque nature of their supply chains, which frequently spanned jurisdictions with varying degrees of labor oversight. For these industries, the failure of Bill C-383 underscored a simple truth: waiting for federal legislation to mandate transparency would not shield companies from reputational risk or market pressures. Large buyers, investors, and increasingly vocal consumers were already expecting companies to demonstrate a clear commitment to eradicating forced labor from their operations. And so, by 2018, Canadian firms in these sectors began to look more seriously at adopting best practices, even in the absence of a legal requirement to do so.
One of the models they turned to was the United Kingdom’s Modern Slavery Act, in force since 2015. The UK law required large companies doing business in the country to publish annual statements describing steps taken to prevent modern slavery within their supply chains. Importantly, these statements were made public via a central transparency register. This register became a point of reference not just for regulators, but for activists, investors, and competitors seeking to benchmark their own practices. Canadian firms began to voluntarily mirror this approach. Some crafted public modern slavery statements aligned with the UK’s reporting structure, while others explored integrating such disclosures into their broader sustainability reports.
Open data played a pivotal role in these efforts. Resources like the Walk Free Foundation’s global slavery index and associated databases offered firms practical tools for assessing risk. By overlaying supply chain maps with these data sets, companies could begin to identify regions, sectors, and tiers of suppliers most exposed to forced labor concerns. For apparel importers, this might mean mapping textile factories and raw material providers against forced labor prevalence rates in key sourcing countries. For mining firms, it involved examining contractor and subcontractor arrangements at extraction and processing sites, particularly in regions flagged for poor labor standards. The open nature of the Walk Free data made it accessible to firms of varying sizes, reducing the cost barrier for those looking to build more robust risk assessments.
In addition to internal supply chain mapping, some companies took the extra step of creating what could be described as voluntary “forced-labor risk portals.” These were digital platforms hosted on corporate websites that outlined a company’s exposure to modern slavery risks and the measures it was taking to mitigate them. The portals often included summaries of supplier audits, descriptions of capacity-building efforts, and links to external data sources such as Walk Free’s index or the U.K. transparency registry. For firms with global operations, these portals served multiple audiences at once: domestic stakeholders seeking evidence of corporate responsibility, international partners evaluating compliance alignment, and regulators in jurisdictions where reporting was already mandatory.
The development of these portals, while still in its early stages in 2018, pointed to a broader trend. Companies recognized that transparency itself could serve as a form of competitive advantage. By proactively sharing information about how they approached forced labor risks, firms aimed to build trust with customers and partners while preempting potential criticisms. There was also a practical dimension. Publishing this information often facilitated better internal coordination across procurement, compliance, and corporate social responsibility teams. Preparing public statements and dashboards forced companies to clarify roles, refine data collection processes, and invest in more systematic supplier engagement.
At the same time, industry coalitions played an important role in shaping how voluntary reporting evolved during this period. Trade associations and multi-stakeholder initiatives provided templates, training, and peer learning opportunities that helped standardize practices across firms. In the mining sector, where shared infrastructure and joint ventures were common, these collective efforts reduced duplication and encouraged consistency in reporting frameworks. Among apparel importers, informal benchmarking of modern slavery statements encouraged firms to go beyond minimum disclosures, as few wanted to be seen as lagging behind their peers.
What became clear by the end of 2018 was that the absence of federal legislation did not preclude meaningful action. Companies facing international supply chain risks and reputational pressures found practical pathways to enhance transparency and accountability. In doing so, they began to lay the groundwork for what a future Canadian Modern Slavery Act might eventually require. Whether through voluntary statements, risk portals, or engagement with open data sources, these efforts signaled a growing maturity in how Canadian firms addressed forced labor challenges, even as legislative debate continued in Ottawa.