Update
Further to the information provided in our recent bulletin Canada's New Forced & Child Labour Act: What Public Sector Organizations Need to Know, on March 13, 2024, Public Safety Canada released specific reporting guidance for government institutions. The guidance clarified that some Crown corporations could fall under the definition of a reporting "entity" under the Fighting Against Forced Labour and Child Labour in Supply Chains Act (FCLA). According to this guidance, and as noted in our bulletin, certain sub-federal public sector organizations such as provincial agent Crown corporations may have reporting obligations. Unfortunately, the government has not as yet clarified its intentions in this regard.
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