Since the introduction of Canada’s Bill C-14, the Modern Slavery Act, in June 2020, many retailers and importers have found themselves facing an uncomfortable but necessary reckoning. The bill, though still progressing through the legislative process, has already sent a strong signal: the era of voluntary modern slavery reporting is drawing to a close. For Canadian companies, particularly in retail and consumer goods, the time to act is now—not when the reporting obligations become law, but well in advance. There is simply too much at stake, both in terms of compliance risk and reputational exposure, to justify waiting.
Among the most practical early steps retailers can take is to begin collecting attestations from suppliers confirming that their operations—and those of their sub-suppliers—are free of forced or child labor. This may sound simple enough on paper. In reality, eliciting meaningful attestations, ones that go beyond boilerplate assurances, is far from straightforward. Some suppliers, particularly those in jurisdictions where forced labor remains a pervasive problem, may be reluctant or slow to respond. Others may issue declarations that, while technically compliant, offer little in the way of substantive evidence. Canadian firms must therefore design attestation requests that are both clear and firm, specifying what documentation or audit reports are expected and setting reasonable but definite timelines for submission.
An important complement to supplier attestations is the use of data analytics to identify parts of the supply chain that may carry elevated risks of modern slavery exposure. This is where publicly available data from the Canada Revenue Agency (CRA) on importer registrations and activity can be especially useful. By cross-referencing importer records with internal procurement data, retailers can begin to map out their upstream import pathways and flag nodes where risk concentrations appear highest. For example, shipments routed through certain ports, involving specific commodities or originating from particular countries, might warrant closer scrutiny. Building this kind of data map requires patience. The CRA’s importer data is extensive, and aligning it with company procurement systems often reveals gaps and inconsistencies that need to be addressed. But the effort pays off, providing a more granular picture of where vigilance is most urgently required.
Once a retailer has gathered a critical mass of attestations and developed a preliminary import risk map, the next logical step is to consider how best to communicate its findings and actions to the public. The expectation that companies will report transparently on their modern slavery risk management efforts is only likely to intensify. In anticipation of this, some Canadian firms are already exploring the creation of public risk assessment portals—digital platforms where stakeholders can view high-level information about supply chain structures, risk areas, and mitigation measures. Designing such a portal involves a number of decisions. What level of detail should be disclosed? How frequently should information be updated? How should sensitive supplier data be protected while still offering meaningful transparency?
A basic guide for constructing a modern slavery risk assessment portal might begin with the selection of key data elements to display. This could include summaries of supplier attestation status, with aggregate statistics on how much of the supply chain is covered by valid declarations.
It might also feature visualizations of import risk concentrations, such as heat maps showing geographic hotspots or network diagrams of supplier relationships. Narrative sections can help explain the methodologies used and the limitations of the data, acknowledging where uncertainties remain or where further work is planned. It is important that such disclosures do not come across as self-congratulatory. Stakeholders—whether consumers, investors, or regulators—are increasingly adept at spotting empty rhetoric. What resonates is candor about challenges and clear evidence of action.
The process of developing these portals often uncovers unexpected internal benefits. In some cases, simply pulling together the necessary data reveals weaknesses in supplier management systems or highlights inconsistencies in procurement records that had gone unnoticed. It can also foster closer collaboration between compliance teams, procurement officers, and IT departments, as the technical and operational aspects of risk assessment become more integrated. Over time, this work helps build a culture of transparency and accountability that extends beyond modern slavery issues to other aspects of ethical sourcing and corporate responsibility.
Yet it would be naive to suggest that these initiatives are without difficulty. Companies will face tensions between transparency and confidentiality, between the desire to act swiftly and the need to ensure data accuracy. There will be moments of friction, as suppliers push back against attestation requests or question the basis for being flagged as high risk. Retailers must be prepared to engage constructively, offering support where appropriate but standing firm on expectations. The stakes are too high to do otherwise. Forced labor is not merely a compliance issue; it is a moral one, and Canadian consumers and policymakers are making it clear that they expect action, not excuses.
The precise contours of Bill C-14’s final reporting requirements remain to be seen. But waiting for perfect clarity is unlikely to be a winning strategy. By beginning the work now—collecting attestations, mapping import nodes, building public reporting frameworks—Canadian retailers position themselves not only for compliance but for leadership in what is sure to be an increasingly scrutinized aspect of global supply chain management.