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Fighting Against Forced Labour and Child Labour in Supply Chains Act (S-211)

Leveraging supplier risk management to address forced labour

The Fighting Against Forced Labour and Child Labour in Supply Chains Act, also known as S-211, is a law that requires Canadian government institutions and select private sector entities to, “report on the measures taken to prevent and reduce the risk that forced labour or child labour is used by them or in their supply chains.” The Act also provides for an inspection regime to enforce its provisions. As with the UK Modern Slavery Act, Australia Slavery Act, and similar laws, the Act aims to contribute to the global fight against forced labour, child labour and other forms of modern slavery.

Most organizations that do business in Canada must comply with the Act and penalties for violations can reach $250,000, so organizations should immediately assess the risks of forced labour in their supply chains.

Relevant Requirements

  • Report to the Canadian government minister responsible for enforcing the law the steps taken to prevent and reduce the risk that forced labour or child labour is used at any stage of the supply chain

  • Summarize key details about the supply chain, including policies and due diligence processes and remediations

  • Issue a public report attesting to fair labour practices

Managing ESG Risks Across the Extended Enterprise

This analyst report from GRC 20/20 uncovers best practices for including ESG in your third-party risk management program.

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  • Pre-Screen New Suppliers Against ESG Measures

    With Prevalent, you can evaluate new suppliers on their environmental, social and governance (ESG) positions – including labour practices – by reviewing recent business and reputational insights, legal filings, ESG scores and sanctions. Prevalent consolidates these insights into a single supplier profile that can be accessed by all teams in the organization, and aligns it with broader RFx management processes for holistic supplier reviews.

  • Build Forced Labour Provisions into Contracts

    Prevalent enables you to ensure enforcement of forced labour and child labour restrictions by building those provisions into supplier contracts and tracking the supplier’s reporting progress over time. Prevalent integrates contract lifecycle management with the supplier risk assessment process by centralizing the distribution, discussion, retention and review of vendor contracts, and leveraging workflow to automate the contract lifecycle right into the due diligence phase.

  • Calculate Inherent Risk Exposure

    Assess suppliers on the extent of threats to your organization by capturing, tracking and quantifying inherent risks. As it relates to forced labour exposure, criteria used to calculate inherent risk can include:

    • Criticality to business performance and operations
    • Location(s) and related legal or regulatory considerations
    • Level of reliance on fourth parties
    • Exposure to operational or client-facing processes
    • Reputation

    From this inherent risk assessment, your team can automatically tier and profile suppliers; set appropriate levels of further diligence; and determine the scope of ongoing assessments.

  • Conduct Targeted Due Diligence Assessments

    Prevalent automates assessment processes, providing you the ability to centrally review and approve assessment responses, and to automatically register risks or reject responses and request additional input or evidence uploads for attestation. The solution is backed by workflow, tasks and built-in remediation recommendations and reporting to ensure your organization meets its reporting deadlines.

  • Continuously Monitor Suppliers

    With Prevalent, you can validate annual due diligence assessment results with continuous insights into reputational information, adverse media and negative news, regulatory and legal actions, sanctions and more. You can then normalize, correlate and analyze assessment results and continuous monitoring intelligence for unified risk reporting and any further required remediations.

  • Build Forced Labour Provisions into Contracts

    Prevalent enables you to ensure enforcement of forced labour and child labour restrictions by building those provisions into supplier contracts and tracking the supplier’s reporting progress over time. Prevalent integrates contract lifecycle management with the supplier risk assessment process by centralizing the distribution, discussion, retention and review of vendor contracts, and leveraging workflow to automate the contract lifecycle right into the due diligence phase.

  • Inventory, Profile and Map All Suppliers

    Build and maintain a centralized supplier database with Prevalent. The database includes comprehensive supplier profiles and provides role-based access to company contacts, demographics, 4th-party and Nth-party connections, and risk intelligence – starting with any profiled risk data and external risk information captured during the RFx stage. Prevalent enables your team to identify relationships between your organization and third, fourth and Nth parties to discover dependencies and asses your exposure.

  • Remediate Findings

    Prevalent includes built-in remediation suggestions to recommend to suppliers to ensure that risks are addressed prior to audit findings.

  • Report

    Store and distribute supplier labour policy documents, assessment results, monitoring findings, and remediations for dialog and attestation at the time of reporting. Prevalent provides role-based access so that you can extend visibility to external auditors who may be examining your due diligence processes and consulting on annual reporting requirements.

Align Your TPRM Program with Expanding ESG Regulations

Download this guide to review current and future ESG standards and legislation, and learn how to prepare your TPRM program for compliance.

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