Law Firm Warns About Looming Canadian Supply Chain Reporting Deadline
Companies with certain business activities in Canada have until May 31 to file with the Canadian government and publish a report on their supply chain due diligence procedures as part of that country's anti-forced labor law, ArentFox said in a client alert this week.
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The firm said the deadline “demands immediate attention” from companies that haven’t yet prepared their first report to Canada and their shareholders under the Fighting Against Forced Labour and Child Labour in Supply Chains Act. International mining companies in particular should assess whether they need to file, ArentFox said, adding that even mining firms that do business “almost exclusively” outside Canada “inevitably end up having some connection to Canada (as it is a major financial jurisdiction for the mining sector), resulting in making them subject to the Act.” Those companies also have “many upstream users of the products from mine operations (as minerals are used in almost every industrial sector).”
The Canadian law requires reporting on how companies are putting in place “preventative measures” to reduce forced labor risks in their supply chains, the firm said. It applies to international mining companies that “meet minimum threshold levels of Canadian business activities,” companies that are listed on a Canadian stock exchange, or companies that engage in certain “prescribed activities” in Canada, ArentFox said. Companies that fail to report or that submit false information may face fines or criminal charges.