��������Ƶ

An Anti-Slavery and Human Trafficking Policy outlines how organizations prevent and address modern slavery in their operations and supply chains. Under Canadian law, particularly the Criminal Code provisions on human trafficking, companies need clear rules to spot and stop exploitation, forced labor, and trafficking risks.

This policy helps businesses meet their legal obligations while protecting vulnerable workers. It typically includes reporting procedures, supplier screening requirements, and employee training guidelines. Canadian companies operating internationally often align these policies with global standards like the UN's Protocol to Prevent Trafficking in Persons and local modern slavery laws in their market regions.

Companies need an Anti-Slavery and Human Trafficking Policy when they operate complex supply chains, work with international suppliers, or expand into new markets. This policy becomes essential for Canadian businesses that employ temporary foreign workers, use labor agencies, or operate in high-risk sectors like manufacturing, construction, or agriculture.

The policy proves particularly valuable during supplier onboarding, merger due diligence, and government contract bids. It helps organizations demonstrate compliance with Canadian criminal laws, protect their reputation, and respond effectively to stakeholder concerns about ethical sourcing and worker protection. Many companies implement it before expanding operations or pursuing major contracts.

• Basic Compliance Policy: Core version focusing on legal requirements under Canadian criminal law, reporting procedures, and basic supplier screening.
• Comprehensive Supply Chain Policy: Expanded version with detailed supplier auditing, risk assessment frameworks, and remediation processes.
• Sector-Specific Policy: Tailored versions for high-risk industries like agriculture, construction, or manufacturing, with industry-specific risk indicators.
• Global Operations Policy: Enhanced version for multinational companies, incorporating international standards and cross-border compliance requirements.
• Small Business Policy: Streamlined version focusing on essential compliance elements and basic due diligence for smaller operations.

• Corporate Legal Teams: Draft and update the Anti-Slavery Policy, ensure compliance with Canadian criminal laws, and coordinate implementation across departments.
• Supply Chain Managers: Apply policy requirements to supplier selection, conduct risk assessments, and monitor compliance throughout the supply network.
• HR Directors: Train employees on policy requirements, manage reporting mechanisms, and oversee labor compliance practices.
• Procurement Officers: Screen potential suppliers, conduct due diligence, and maintain documentation of compliance.
• Senior Executives: Sign off on policy commitments, allocate resources for implementation, and oversee corporate accountability measures.

• Supply Chain Assessment: Map your complete supply chain, identifying high-risk areas and potential vulnerabilities for human trafficking.
• Legal Requirements: Review Canadian criminal code provisions on human trafficking and any industry-specific regulations affecting your business.
• Stakeholder Input: Gather feedback from procurement, HR, and legal teams about existing processes and challenges.
• Risk Analysis: Document your company's specific risk factors, including geographical operations and supplier relationships.
• Implementation Plan: Outline training requirements, reporting mechanisms, and enforcement procedures before finalizing the policy.

• Policy Statement: Clear commitment to preventing modern slavery and human trafficking in operations and supply chains.
• Scope Definition: Detailed coverage of all business operations, subsidiaries, contractors, and supply chain partners.
• Due Diligence Procedures: Specific processes for supplier screening, risk assessment, and ongoing monitoring.
• Reporting Mechanisms: Confidential channels for raising concerns and whistleblower protection measures.
• Training Requirements: Mandatory staff training programs and awareness initiatives.
• Enforcement Measures: Clear consequences for policy violations and remediation procedures.
• Review Process: Annual policy review requirements and update procedures.

While both documents address ethical business practices, an Anti-Slavery and Human Trafficking Policy differs significantly from a Corporate Social Responsibility Policy. The key distinctions lie in their scope, legal requirements, and specific focus areas.

• Legal Framework: Anti-slavery policies specifically address criminal law compliance regarding human trafficking and forced labor, while CSR policies cover broader voluntary social commitments.
• Enforcement Mechanisms: Anti-slavery policies require strict supplier monitoring and reporting procedures, whereas CSR policies often involve more flexible, company-determined standards.
• Risk Management: Anti-slavery policies focus on specific criminal risks in supply chains and operations, while CSR policies address general social impact and stakeholder relationships.
• Implementation Requirements: Anti-slavery policies demand detailed due diligence processes and clear violation consequences, compared to CSR policies' broader improvement goals.