CADA informs dealers about Canada’s new Modern Slavery Act
April 15, 2024
To help dealers navigate the impact of new federal legislation that is aimed at fighting forced labour and child labour around the world and in global supply chains, CADA held a webinar last month for dealer members with the law firm McCarthy Tétrault.
The Fighting Against Forced Labour and Child Labour in Supply Chains Act, formerly Bill S-211, and referred to as Canada’s Modern Slavery Act came into force on January 1, 2024.
“The legislation imposes an obligation on businesses meeting certain criteria to report annually by May 31, on the measures they have taken to prevent and reduce the risk that forced labour or child labour is used in their supply chains,” said Tim Ryan, CADA’s Vice-President and Director Industry Relations & General Counsel. “We want to ensure our dealers are aware of the issue, and want to make information available for them.”
If they are required to file a report, dealers must scrutinize their supply chains, gather information required to prepare the report, obtain board approval, complete an online questionnaire, and file their initial report with Public Safety Canada by May 31st, 2024. They will also need to post the report in a prominent place on their website.
Failure to comply could result in penalties, including fines per offense of up to $250,000, reputational damage and liability for officers and directors.
The analysis of whether a dealer is required to file a report will be a fact-specific exercise. Dealers should consult with their advisors and prioritize determining whether they have a reporting obligation under the legislation.
Dealers can also refer to an email from CADA sent out to dealers on April 11, 2024 that links to the CADA website at www.cada.ca and provides information about the legislation including recordings of the webinars held on March 28, 2024 in English and April 2, 2024 in French along with supporting information.