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ARTICLE · 25 NOVEMBER 2024

Better Guidance Equals Better Reporting: Navigating The Supply Chains Act For Year 2 Reporting

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Updated guidance for entities (Guidance) has been published with respect to the reporting obligations under the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Supply Chains Act).

CanadaInternational Law
Benedict S. Wray
Benedict S. Wray
Laura Levine
Laura Levine
Benjamin Fuhrmann
Benjamin Fuhrmann
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Updated guidance for entities (Guidance) has been published with respect to the reporting obligations under the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Supply Chains Act). The revisions provide significant clarification in several areas where there was previous uncertainty, including with respect to the definition of "assets" and the type of activities that will trigger a reporting obligation. The Guidance also includes tips for avoiding common errors observed by Public Safety Canada during the first reporting period ending May 31, 2024.

Change in "asset" definition

Foreign parent companies without a nexus to Canada other than the ownership of shares of their Canadian subsidiaries now have clarity that Public Safety Canada will not consider them "entities" under the Supply Chains Act. Whether an organization is an "entity" under the Supply Chains Act depends on whether it has a place of business in Canada, does business in

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