Canadian Modern Slavery Act Proposed – Would Create Additional Reporting Obligations For U.S.-based Multinationals

At the end of October, a Modern Slavery Act was introduced in the Canadian Senate. The proposed Act is substantially similar to bills introduced earlier in the year and in late 2018 and is broadly consistent with disclosure-only modern slavery legislation adopted in other jurisdictions. Like similar legislation in other jurisdictions, if adopted, a large number of U.S.-based multinationals would be required to comply with the Act. In this Alert, we describe the requirements of the Act and discuss how they would fit into the global modern slavery reporting framework.

Subject Entities

Like modern slavery acts in other jurisdictions, the Act would apply broadly.

Covered activities. An "entity" would be subject to the Act to the extent it engages in any of the following activities: