The defeat of Canada’s Modern Slavery Act, Bill C-383, in 2016 did not put an end to the country’s conversation on corporate responsibility and supply chain transparency. In fact, it arguably catalyzed new forms of engagement by industry associations determined to fill the regulatory void through voluntary measures. By 2017, several prominent business coalitions representing sectors such as apparel manufacturing, mining, and retail had released recommended guidelines aimed at helping companies address forced labor risks in their supplier networks. These guidelines, though non-binding, reflected a growing consensus that Canadian firms could not afford to remain passive in the face of intensifying public scrutiny and shifting global standards.
Among the most influential tools promoted by these associations was the Open Apparel Registry. The Registry provided a free, open-source platform for mapping apparel production facilities worldwide. It allowed companies to disclose the names, locations, and affiliations of their direct suppliers, creating a baseline for accountability and enabling stakeholders—including consumers, NGOs, and investors—to assess sourcing practices more systematically. Industry groups encouraged member companies to publish their supplier lists using the Registry, framing this as both a reputational safeguard and a practical step toward ethical sourcing. While participation remained voluntary, the Registry’s adoption by leading global brands added pressure on others to follow suit, lest they appear indifferent to modern slavery concerns.
For apparel and mining firms seeking to align with these recommendations, the initial task often involved gathering accurate, up-to-date supplier information. This could prove challenging, particularly for companies with sprawling, multi-tiered networks of subcontractors and affiliates. In many cases, firms found that their internal records were incomplete or inconsistent, necessitating fresh supplier outreach and the development of clearer contractual requirements around disclosure. Once basic supplier data had been consolidated, companies could upload it to the Open Apparel Registry or other sector-relevant transparency platforms, thereby signaling a commitment to openness and continuous improvement.
However, disclosure alone did not address the more substantive task of ensuring that suppliers met ethical sourcing standards. Here, the industry guidelines typically urged companies to go further by constructing formal candidate-supplier whitelists. Such lists identified vendors that had not only disclosed their facilities but also demonstrated alignment with recognized labor standards and human rights principles. Developing these lists required a structured methodology that combined desk-based research, supplier self-assessments, independent audits, and, where possible, direct site visits.
A step-by-step approach to building an ethical sourcing whitelist generally began with risk mapping. Companies analyzed their supplier base by geography, product type, and production tier, identifying areas most associated with forced labor or other high-risk practices. Publicly available tools, such as Walk Free’s Global Slavery Index or U.S. Department of Labor reports, often informed these assessments. This risk mapping process helped firms prioritize their due diligence efforts and allocate resources more effectively.
Once high-risk suppliers had been identified, companies initiated targeted reviews. This could involve requiring suppliers to complete detailed questionnaires addressing labor policies, subcontracting practices, recruitment methods, and grievance mechanisms. The responses, combined with third-party audit findings where available, allowed firms to evaluate supplier performance against predefined criteria. Suppliers meeting these standards could then be added to the ethical sourcing whitelist, while those falling short might be offered support to improve or, in cases of serious non-compliance, removed from consideration altogether.
The final stage in developing the whitelist involved embedding it into core business processes. Companies integrated the approved supplier list into procurement systems, ensuring that purchasing decisions aligned with ethical sourcing commitments. Many also established periodic review cycles to refresh risk assessments and update whitelist entries based on new information or changing conditions. The objective was to create a living document that reflected the dynamic nature of global supply chains, rather than a static register that quickly became outdated.
By adopting these voluntary measures, Canadian apparel and mining firms aimed not only to reduce their exposure to modern slavery risks but also to demonstrate leadership in the absence of binding national legislation. While some critics questioned whether voluntary initiatives could achieve the systemic change needed to eradicate forced labor, others saw them as an important interim step that could lay the groundwork for future regulatory frameworks. The experience of 2017 suggested that even without the force of law, industry standards and peer benchmarking could exert meaningful influence on corporate behavior.
In the years that followed, the conversation around modern slavery legislation in Canada continued, with fresh proposals and renewed parliamentary interest. Yet the groundwork laid by the 2017 industry guidelines remained relevant, offering companies both a model for action and a reminder of the reputational and ethical stakes involved. As global supply chains grew more complex and interconnected, the importance of proactive, transparent sourcing practices only became clearer.