Modern Slavery Risk Assessment Template for Canada

A Modern Slavery Risk Assessment is a comprehensive document that helps you systematically evaluate your organization's exposure to forced labor, human trafficking, and other forms of modern slavery throughout your operations and supply chains. This assessment serves as both a compliance tool and strategic document, enabling you to identify vulnerabilities, implement controls, and demonstrate due diligence in preventing modern slavery practices within your business ecosystem.

When do you need this document?

You need a Modern Slavery Risk Assessment when your organization operates complex supply chains involving high-risk industries such as manufacturing, agriculture, construction, or textile production. This becomes particularly crucial if you source materials or services from regions with weak labor protections, employ migrant workers, or work with multiple subcontractors and suppliers. The assessment is essential when preparing for compliance with emerging legislation like Bill S-211, responding to stakeholder inquiries about your anti-slavery measures, or conducting due diligence for mergers and acquisitions. You should also conduct this assessment if your organization has experienced supply chain disruptions, received reports of labor violations, or operates in sectors frequently associated with modern slavery risks.

Key legal considerations

Your Modern Slavery Risk Assessment must address several critical legal elements to ensure comprehensive protection and compliance. The document should include detailed supply chain mapping that identifies all tiers of suppliers, subcontractors, and service providers, along with their geographic locations and labor practices. Risk evaluation criteria must cover indicators such as migrant worker populations, debt bondage practices, restricted movement of workers, and inadequate living conditions. The assessment should establish clear control frameworks including supplier codes of conduct, regular auditing procedures, worker grievance mechanisms, and corrective action protocols. Documentation requirements are crucial, as you must maintain records of risk assessments, supplier evaluations, training programs, and remediation efforts to demonstrate ongoing compliance and due diligence efforts.

Legal requirements in Canada

Under Canadian federal law, your Modern Slavery Risk Assessment must comply with the Criminal Code sections 279.01 to 279.04, which criminalize human trafficking and forced labor, establishing your legal obligation to avoid complicity in these practices. The Immigration and Refugee Protection Act requires particular attention to foreign worker exploitation risks in your supply chains and operations. If you import goods, the Customs Tariff Act prohibits importing products manufactured with prison or forced labor, making supply chain due diligence legally mandatory. The proposed Fighting Against Forced Labour and Child Labour in Supply Chains Act (Bill S-211) will require qualifying organizations to publicly report on their efforts to prevent and reduce forced labor risks, making comprehensive risk assessments a regulatory necessity. Your assessment must also consider provincial employment standards and occupational health and safety requirements that complement federal anti-slavery legislation.