Do Canada's Modern Slavery Reporting Requirements Impact Investment Managers?

You may have seen recent headlines about a reporting requirement due on May 31, 2024, under the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Act, sometimes referred to as the Modern Slavery Act) which came into force on January 1. A number of our clients are asking whether these reporting requirements could apply to them as investment managers - read on for some considerations that will help you assess the potential impact on your business.

Generally, the Modern Slavery Act is intended to address Canada's commitments to contribute to the fight against modern slavery in our supply chains, and, as such, is targeted at the production, sale or distribution of goods in Canada or elsewhere, or the importation of goods into Canada. The Act also imposes reporting requirements on certain businesses that control an entity that produces, sells, distributes or imports goods in Canada.