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BRIEF ON BILL S-211 An Act to enact the Fighting Against Forced Labour and Child Labour in Supply Chains Act and to amend the Customs Tariff

The Canadian Ombudsperson for Responsible Enterprise (CORE) is pleased to provide this brief to the Standing Senate Committee on Human Rights in its deliberations on Bill S-211, referred to the Committee on December 14, 2021.


The CORE commends Senator Miville-Dechêne for her persistent and determined efforts to develop and propose supply chain transparency legislation (“transparency legislation”).

Bill S-211 (“the bill”) represents a step forward by proposing transparency legislation that will add to measures to strengthen respect for human rights by Canadian companies in their operations and supply chains abroad. The CORE recommends the following changes to enhance the bill’s effectiveness:

  1. Add fighting against labour trafficking to the purpose of the proposed legislation.
  2. Add the ability to make regulations to identify other threshold considerations for identifying entities subject to reporting obligations (e.g., in sectors with high-risk supply chains).
  3. Make reporting requirements more detailed and specific.
  4. Strengthen oversight including by providing for independent audits of annual reports.

The CORE recommends that the adoption of transparency legislation not detract from the need to introduce mandatory human rights due diligence legislation requiring Canadian companies to exercise due diligence with respect to all human rights and to strengthen access to remedy for impacted individuals and communities by providing the CORE with the ability to compel testimony and documents.Footnote1

Who is the CORE?


Add Labour Trafficking to the Purpose Section

the recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation. Exploitation shall include, at a minimum, … forced labour or services, slavery or practices similar to slavery, servitude…. (emphasis added)

Regulatory power to add threshold conditions that define “entity”

Consistent and Comprehensive Reporting

Business enterprises may be involved with adverse impacts either through their own activities or as a result of their business relationships with other parties. …  “business relationships” are understood to include relationships with business partners, entities in its value chain, and any other non-State or State entity directly linked to its business operations, products or services.

Strengthening Oversight


Certification of Annual Report

The CORE appreciates the opportunity to provide this brief and looks forward to following the progress of Bill S-211.

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