In May 2019, Canada took a decisive step toward addressing forced labor and human trafficking risks in supply chains with the launch of a public consultation on a proposed Modern Slavery Act. The consultation process, led by Global Affairs Canada, invited feedback from a broad cross-section of society—including businesses, civil society organizations, and concerned individuals—on how best to design a legislative framework that would align Canada with international best practices. By October 2019, preliminary findings began to outline the shape of what might eventually become Canada’s first federal law mandating transparency on modern slavery risks.
The consultation revealed that most stakeholders, particularly those in the textiles and mining sectors, recognized the need for mandatory supplier disclosures as a cornerstone of any future legislation. Voluntary efforts, while commendable in isolated cases, were seen as insufficient to address the systemic risks of forced labor across complex global supply chains. There was wide consensus that reporting should not merely be an aspirational exercise but a requirement tied to clear enforcement mechanisms and penalties for non-compliance. In this regard, participants drew inspiration from existing models, such as the U.K. Modern Slavery Act and Australia’s Modern Slavery Act, both of which had already begun reshaping corporate behavior abroad.
For textile manufacturers, the consultation highlighted the importance of tracing risks deep into Tier 2 and Tier 3 suppliers, where the potential for forced labor is most acute—particularly in cotton farming and garment assembly operations located in high-risk regions. Canadian apparel brands and importers were urged to anticipate future requirements by developing detailed supplier maps and initiating independent audits focused on labor conditions. The mining sector, on the other hand, emphasized the need for clarity on how disclosures would address artisanal and small-scale mining operations, where informal labor practices often make due diligence more challenging. Companies operating in this space advocated for greater alignment between Canadian policy and international initiatives such as the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals.
In preparation for what many viewed as an inevitable shift toward mandatory reporting, Global Affairs Canada encouraged stakeholders to engage actively through its open consultation portal. This portal provided a structured way for businesses and organizations to contribute their perspectives and help shape the final policy framework. Position papers submitted through the portal typically addressed several core themes: the scope of the reporting requirement, the definition of forced labor, mechanisms for independent verification, and the role of public registries in ensuring accountability.
For companies preparing to contribute meaningfully to this policy dialogue, having a clear and well-structured position paper was critical. A standard template for such submissions generally included the organization’s name and industry, a brief overview of current supply chain practices related to labor rights, and specific recommendations for how the legislation should be designed to balance effectiveness with feasibility. Key sections typically focused on proposed reporting thresholds (for example, minimum annual revenue or employee counts triggering the obligation), expectations for supplier disclosure depth (Tier 1 versus deeper tiers), and views on penalties for non-compliance. Many position papers also included annexes containing case studies or examples of existing corporate efforts to address forced labor risks, offering concrete illustrations of what workable reporting could look like in practice.
By October 2019, the contours of Canada’s emerging policy framework on modern slavery were becoming clearer thanks in no small part to the robust participation in the consultation process. The experience underscored the value of transparent, open engagement between government and industry in tackling one of the most complex ethical challenges facing global supply chains today. Whether or not the eventual legislation would fully meet stakeholder expectations remained to be seen, but the groundwork laid during 2019 positioned Canada to join the growing community of nations committed to combating modern slavery through supply chain transparency.