Public Safety Canada Has Updated Its December 2023 Modern Slavery Act Guidance

On March 5, 2024, Public Safety Canada ("PSC") amended the Guidance for entities (the "Guidance"), which was originally published in December 2023 (the "December 2023 Guidance") and updated in January 2024 to provide additional guidance to entities that need to submit a report under the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the "Act"). Miller Thomson published a summary of the December 2023 Guidance when it was initially published.

The substantial changes that PSC made to the December 2023 Guidance include:

• Removal in the Guidance of any reference to "selling or distributing" goods when discussing the interpretation of Section 9(a) of the Act, emphasizing that "production and importation" are the activities captured by the Act;