Canada’s Modern Slavery Act, passed quietly in 2018, began to show its sharper teeth in 2023. For the first time, Canadian courts issued orders compelling companies—some large, some perhaps caught off guard—to produce modern slavery statements. This development, anticipated by some and surprising to others, signals that the enforcement phase of the legislation is no longer theoretical. There had been a period when the law seemed, to put it delicately, more aspirational than practical. The first court orders mark a shift. Companies, particularly in high-risk sectors like mining and apparel, are being asked not just to have policies in place, but to demonstrate what those policies look like in practice.
What’s interesting—if slightly troubling—is that many firms had assumed their existing disclosures, often buried deep in sustainability reports, would suffice. The reality has been more complicated. The courts, backed by regulators, are looking for statements that are not only present but also substantive. They want to see that a company has mapped its supply chains, identified risks, and described mitigation steps. Vague language or boilerplate assurances are no longer enough, or at least that seems to be the emerging standard. There is, of course, still some ambiguity here. The legislation itself leaves room for interpretation, and that may be both a strength and a weakness. Flexibility can encourage thoughtful responses, but it also creates uncertainty about what exactly is expected.
For mining and apparel firms navigating this new terrain, open data from Canada’s Business Information System (BIS) is proving to be a valuable, if sometimes underutilized, resource. BIS maintains a variety of datasets on corporate registrations, trade activities, and in some cases, supplier networks. By integrating BIS data into internal supply chain management tools, companies can begin to build more detailed labor-risk profiles. This might sound straightforward, but in practice, the process can be messy. Data quality varies. Records are sometimes incomplete or inconsistent, and linking BIS information to tier-two or tier-three suppliers, where risks are often highest, can be challenging. That said, for firms willing to invest the time, BIS data offers a starting point—an external reference point against which to check supplier claims and map relationships that might otherwise go unnoticed.
Integrating modern slavery statements into corporate websites, while seemingly the easy part, is another area where practice varies widely. Some companies have opted for highly visible disclosures—a dedicated section on their homepage or sustainability page, easy to find and written in accessible language. Others, whether by design or oversight, have buried their statements in dense investor reports or tucked them away in corners of their sites that few visitors are likely to find. The trend, at least among firms hoping to demonstrate leadership, is toward greater visibility and clarity. From a technical standpoint, most firms are adopting a standard workflow: drafting the statement in line with legal requirements, clearing it through legal and compliance teams, and then working with web developers to publish it, typically in PDF or HTML format. A few are going further, creating interactive dashboards or embedding supply chain maps directly on their sites—a move that, while still rare, may become more common as stakeholder expectations evolve.
There’s a certain tension at play here. Companies are being asked to shine a light on parts of their operations that were, until relatively recently, largely invisible to consumers and investors. Some are embracing this opportunity, seeing it as a chance to build trust and demonstrate values. Others are, understandably, proceeding more cautiously, worried about legal exposure or reputational risks that might come from revealing more than they had planned. The first orders to produce statements have brought these dynamics to the fore, forcing firms to think carefully not only about what they disclose, but how, where, and to whom.