Game Changer -- Part 2 of 3

Preparing for an upcoming change is not simple or easy. Whether it is being emotionally prepared for a change that can affect one personally or a change within a process to provide a stronger foundation for efficiency and effectiveness, change is something to be aware of and to navigate with proper support and insights.

One upcoming GAME CHANGER is the bill passed in Canada in the spring named S-211. This new initiative is focused on eliminating the use of forced and child labor.


Preparing for and aligning with the requirements of this new regulation is a must. In a recent webinar hosted by the Canadian Apparel Federation (http://www.apparel.ca/) and presented by William Pellerin of McMillan (https://mcmillan.ca/people/william-pellerin/), an interesting insight was how far in advance of the initial filing requirements scheduled for May 2024 should a corporation prepare. The suggestion was to work backwards. If the reporting requirements dictate that the filing must take place by May 2024, and the filing requires board approval, then when is the next board meeting taking place? Will the board provide feedback that will need updates to the filing? If so, will approval only take place at the following board meeting? If a board meeting occurs once a quarter, then corporations should be starting to prepare their filings well before the end of 2023.

Another interesting aspect of this regulation is that there are no specific formats to use. In the policy, there is a general (and, dare I say, vague) outline of what the reporting requirements are and what the contents should encompass, but how to present this information is not outlined. How much or how little should be included in the report is not addressed within the regulations. There are various opinions about this and the suggestion is to consult with compliance experts to discuss and review the tentative/proposed report being prepared for submission.

Lastly, the Government of Canada has included a key piece of legislation in this new bill C-211. Currently, the Canadian Government is the only jurisdiction to include extensive focus regarding child labor within the context of regulating forced labor. 

Corporations may be aware that the Government of Canada does not currently have extensive resources to enforce these regulations. However, keep in mind that:
- hefty penalties will be issued for non-compliance (with non-compliance meaning simply that a report was not submitted and is not available on the corporate web-site)
- Negative media coverage can impact a business far more than a monetary fine imposed by the Governmental department overseeing the compliance of this legislation.
- Corporate Social Responsibility is not something to sweep under the rug but something to be proactive about. 

Be aware that The Canadian Ombudsperson for Responsible Enterprise (CORE -- https://core-ombuds.canada.ca/index.aspx?lang=eng) initiates communication based on complaints received. Mr. Pellerin suggested a strategy that, should a notice be received from CORE, it should not be ignored. Consider giving proper attention to the notice by initiating dialogue and responses with CORE.


The key focus is to PREPARE and not to procrastinate until the 11th hour to prepare and finalize the report and the required elements that need to be reported.


This past summer I was invited to spend some time at an overnight camp that my kids attend. My wife was the camp mom and I was asked if I wanted to come and have the "camp experience". As someone that never attended camp in his youth, I was terrified. The thought of "roughing it" was overwhelming. I was supposed to spend just under two weeks at camp. I lasted 6 days. The reason was that I did not prepare well. I did not ask the right questions nor did I bring the correct gear to facilitate a positive camp experience. There was much to offer including hikes, water-skiing, and volunteering in the various camp sections. The opportunity was there to create a positive experience. However, after arriving I quickly realized that I did not bring items that would have exponentially assisted in making this opportunity an enjoyable one.
I did have a great time seeing my kids enjoying themselves and the interaction during key points throughout each day did shine some positive light on the situation.
Looking back, it would seem that I should try again. If there should be a next time, I should make sure that I am ready for what to expect and how to handle each arising opportunity.


Reporting requirements under bill C-211 are real and will become mandatory on January 1, 2024 with reports needed to be filed by May, 2024. Prepare for these requirements well in advance. THINK AHEAD so that you are not left behind.


With thanks to:
- Bob Kirke (https://www.linkedin.com/in/bob-kirke-25b9979/) and the Canadian Apparel Federation 
- William Pellerin (https://www.linkedin.com/in/williampellerin/) of McMillan
(https://www.linkedin.com/company/mcmillanllp/) for presenting the webinar on Bill S-211
- Olivier Doizy (https://www.linkedin.com/in/olivier-doizy-79265218/) for all of his feedback and our collaboration on being prepared.
Location: Montreal, QC, Canada

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