Modern Slavery Risk Assessment for Canada

Modern Slavery Risk Assessment Template for Canada

A comprehensive document designed to evaluate and address modern slavery risks within an organization's operations and supply chains, compliant with Canadian federal and provincial legislation. The assessment provides a structured analysis of potential exposure to forced labor, human trafficking, and other forms of modern slavery, along with detailed recommendations for risk mitigation. It includes supply chain mapping, risk evaluation matrices, control assessments, and action plans tailored to meet both current regulatory requirements and anticipated legislation such as Bill S-211 (Fighting Against Forced Labour and Child Labour in Supply Chains Act).

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What is a Modern Slavery Risk Assessment?

The Modern Slavery Risk Assessment is a critical tool for organizations operating in Canada to evaluate their exposure to modern slavery risks and ensure compliance with existing and emerging legislation. This document becomes necessary when organizations need to assess their operations and supply chains for potential modern slavery risks, particularly in light of increasing regulatory scrutiny and stakeholder expectations. It provides a structured approach to identifying, assessing, and mitigating risks related to forced labor, human trafficking, and other forms of modern slavery. The assessment is especially relevant given Canada's proposed Bill S-211 and existing federal legislation addressing forced labor and human trafficking. It includes comprehensive supply chain mapping, risk evaluation frameworks, control assessments, and detailed recommendations for risk mitigation, serving as both a compliance tool and a guide for implementing robust anti-slavery measures.

What sections should be included in a Modern Slavery Risk Assessment?

1. Executive Summary: Overview of key findings, major risks identified, and primary recommendations

2. Introduction: Purpose of the assessment, scope, and methodology used

3. Regulatory Framework: Overview of applicable laws, regulations, and compliance requirements in Canada and relevant jurisdictions

4. Organization Overview: Description of the organization's structure, operations, and supply chains

5. Risk Assessment Methodology: Detailed explanation of risk assessment approach, criteria, and scoring system

6. Supply Chain Mapping: Analysis of supply chain tiers, geographical spread, and identification of high-risk areas

7. Risk Identification: Detailed findings of modern slavery risks across operations and supply chains

8. Current Controls Assessment: Evaluation of existing policies, procedures, and controls to prevent modern slavery

9. Gap Analysis: Identification of areas where current controls fall short of requirements or best practices

10. Risk Mitigation Recommendations: Specific actions and measures recommended to address identified risks

11. Implementation Plan: Prioritized action plan with timelines, responsibilities, and resource requirements

12. Monitoring Framework: Proposed approach for ongoing monitoring and review of modern slavery risks

What sections are optional to include in a Modern Slavery Risk Assessment?

1. Industry-Specific Risk Analysis: Detailed analysis of risks specific to the organization's industry sectors - include when operating across multiple industries

2. Stakeholder Engagement Summary: Overview of consultation with stakeholders - include when extensive stakeholder engagement was conducted

3. Cost-Benefit Analysis: Analysis of financial implications of recommended measures - include when significant investments are required

4. Training and Awareness Program: Detailed training recommendations - include when significant capability gaps are identified

5. Case Studies: Examples of identified risks or near-misses - include when specific examples help illustrate key risks

6. Compliance Reporting Templates: Templates for ongoing compliance reporting - include when organization requires standardized reporting

What schedules should be included in a Modern Slavery Risk Assessment?

1. Appendix A: Risk Assessment Matrix: Detailed risk scoring matrix and methodology

2. Appendix B: Supply Chain Map: Visual representation of supply chain structure and risk areas

3. Appendix C: Supplier Risk Assessment Results: Detailed results of supplier risk assessments

4. Appendix D: Relevant Legislation Summary: Detailed summary of applicable laws and requirements

5. Appendix E: Due Diligence Questionnaires: Templates for supplier and contractor due diligence

6. Appendix F: Action Plan Timeline: Detailed implementation timeline and milestones

7. Appendix G: Monitoring and Reporting Templates: Templates for ongoing risk monitoring and reporting

Authors

Alex Denne

Head of Growth (Open Source Law) @ Genie AI | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

Jurisdiction

Canada

Publisher

Genie AI

Cost

Free to use
Relevant legal definitions
Clauses
Relevant Industries

Manufacturing

Construction

Agriculture and Food Production

Mining and Resources

Textile and Apparel

Retail

Transportation and Logistics

Electronics

Hospitality

Fishing and Seafood

Professional Services

Import/Export

Consumer Goods

Relevant Teams

Legal

Compliance

Supply Chain

Procurement

Risk Management

Human Resources

Operations

Sustainability

Corporate Social Responsibility

Ethics

Internal Audit

Global Trade

Supplier Relations

Due Diligence

Relevant Roles

Chief Compliance Officer

Supply Chain Manager

Risk Management Director

Procurement Manager

Legal Counsel

ESG Director

Human Rights Officer

Operations Director

Sustainability Manager

Corporate Social Responsibility Manager

Ethics and Compliance Manager

Human Resources Director

Supplier Relations Manager

Due Diligence Specialist

Global Trade Manager

Industries
Criminal Code of Canada (R.S.C., 1985, c. C-46): Sections 279.01 to 279.04 specifically criminalize human trafficking and forced labor in Canada, providing the foundational legal framework for addressing modern slavery
Immigration and Refugee Protection Act (S.C. 2001, c. 27): Contains provisions prohibiting human trafficking and the exploitation of foreign workers, particularly relevant for identifying risks in labor supply chains
Customs Tariff Act (S.C. 1997, c. 36): Tariff Item No. 9897.00.00 prohibits the importation of goods manufactured or produced by prison or forced labor
Modern Slavery Act (Proposed): While not yet in force, Bill S-211 (Fighting Against Forced Labour and Child Labour in Supply Chains Act) will require companies to report on measures taken to prevent and reduce forced labor risks in supply chains
United Nations Protocol to Prevent, Suppress and Punish Trafficking in Persons: International protocol ratified by Canada that provides definitions and frameworks for addressing human trafficking and modern slavery
Canada Labour Code (R.S.C., 1985, c. L-2): Federal labor law that sets standards for working conditions and helps identify potential indicators of forced labor or exploitation
Proceeds of Crime (Money Laundering) and Terrorist Financing Act: Relevant for assessing financial risks and reporting obligations related to proceeds from modern slavery and human trafficking
Provincial Employment Standards Acts: Provincial legislation that sets minimum employment standards and can help identify potential exploitation risks at the provincial level
Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks,  Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination,  Severance Pay, Governing Law, Entire Agreemen

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