In June 2021, Global Affairs Canada released its enhanced due diligence guidance targeting forced labor and child labor risks in supply chains. The guidance primarily focuses on clothing and agricultural imports, given the well-documented vulnerabilities in these sectors. The guidance came at a time when the international scrutiny of Canadian importers was growing, and the country’s trading partners and civil society groups were pushing for stronger accountability measures. From the start of implementation later that year, it became evident that the guidance was more than a formality. It was, in effect, a demand for concrete, data-supported action from importers.
One notable feature of the guidance is its emphasis on evidence-based risk mapping. Canadian importers are encouraged—arguably required—to embed open-data tools into their due diligence programs. The Walk Free Foundation’s Global Slavery Index, for example, is cited in many circles as a core reference for identifying high-risk countries and sectors. Likewise, datasets from the U.S. Department of Labor, the International Labour Organization, and regional NGOs are increasingly part of standard supplier assessments. What this means in practice is that importers can no longer rely solely on supplier self-declarations or third-party certifications without corroboration. They are expected to demonstrate that they have used independent, publicly available data to identify, assess, and address the risk of forced labor in their supply chains. It sounds straightforward, but in practice it has proven far from simple.
Many Canadian apparel and agricultural firms have begun aligning their supplier surveys with these open-data tools. In theory, this means mapping their supply chains against known risk profiles, asking pointed questions about recruitment practices, wage payments, and grievance mechanisms, and following up where red flags appear. But in reality, implementation has been uneven. Some companies have robust systems that integrate risk atlas data directly into their enterprise resource planning software, allowing automated risk scoring for suppliers. Others are still experimenting, unsure how best to operationalize these tools or struggling with data quality and consistency across jurisdictions. And there’s the added complexity of interpreting what the data means at a supplier or sub-supplier level. Risk at the country level doesn’t always translate neatly to risk at a given facility, and companies are finding that nuanced, site-specific assessments are resource-intensive.
Transparency is another area where the guidance raised the bar. Canadian importers are expected to publicly post summaries of their due diligence activities. The expectation is not for boilerplate statements, but for meaningful disclosures that outline risk assessment processes, main findings, and mitigation measures. Some companies have begun publishing these summaries on their websites or through sectoral platforms, offering insights into both their methodology and the outcomes of their supply chain reviews. Others appear hesitant, concerned about legal liability or reputational harm if they acknowledge specific risks. This tension—between transparency and fear of exposure—is one of the most difficult challenges of the guidance’s first implementation phase.
For firms seeking to meet the new standard, a practical path forward starts with aligning their supplier surveys to human-rights risk atlas tools in a systematic way. That means not just referencing these tools but structuring supplier assessments around them. Companies can, for example, create tiered questionnaires that escalate scrutiny depending on a supplier’s location or sector risk profile. High-risk suppliers might be asked to provide additional documentation or undergo independent audits. The data from these assessments should then be consolidated into a central risk dashboard, updated regularly, and used to inform sourcing decisions.
Public disclosure of due diligence summaries can follow a structured, repeatable process. Importers should define a reporting template that covers the core elements: the tools and data sources used in risk assessments; an overview of key risk findings, disaggregated by sector and geography where possible; and a summary of actions taken, whether that be supplier engagement, remediation, or disengagement. It’s important that these summaries are written in clear, accessible language. Overly legalistic or technical language risks alienating the very audiences—consumers, investors, regulators—that these disclosures are meant to inform.
The first year of implementation under Canada’s enhanced due diligence guidance has offered a glimpse into what effective modern-slavery risk management could look like. But it has also exposed the gaps—particularly in data integration, supplier engagement depth, and public transparency—that many importers still need to address. The open-data tools are there, the guidance is clear enough in its direction, but the hard work of translating policy into practice is only just beginning. Some companies are moving faster than others, learning by doing, iterating their approaches as new challenges emerge. Others may find themselves playing catch-up as regulatory scrutiny tightens and public expectations rise. It is, in many ways, an inflection point for Canadian supply-chain governance. The question now is how quickly—and how credibly—importers will respond.