Modern Slavery Legislation

Canada Legislation:
Canada has adopted a more enforcement-focused approach to forced labour within its trade and human rights framework. Amendments to the Customs Tariff Act introduced in July 2020 prohibited imports produced wholly or partly through forced labour. The restriction was expanded to include child labour in January 2024. In June 2026, Canada introduced Bill C-35 to strengthen border enforcement through high-risk goods listings and enhanced supply chain tracing requirements. The Bill remains before Parliament and is not yet in force.

This direction was further strengthened in 2023 through the Fighting Against Forced Labour and Child Labour in Supply Chains Act, commonly referred to as Bill S 211. The legislation requires certain private sector organisations and public institutions to publish annual reports. These reports explain how risks associated with forced and child labour are identified, assessed, and managed across operations and supply chains. Supported by the potential for financial penalties, the framework places increased emphasis on credible due diligence. It also requires active oversight of supplier relationships. Clear organisational accountability is expected, rather than reliance on disclosure alone.

United States Legislation:
In the United States, action on forced labour operates through both state and federal measures aimed at increasing transparency and strengthening enforcement. At the state level, the California Transparency in Supply Chains Act requires certain large companies to publicly disclose the steps they take to address risks of forced labour and human trafficking within their direct supply chains. This provides greater visibility into corporate risk management practices.

At the federal level, the Tariff Act of 1930 gives U.S. Customs and Border Protection the authority to detain shipments. This applies where evidence suggests goods may have been produced using forced or indentured labour. It prevents those products from entering the United States market. These measures were further reinforced through the Uyghur Forced Labour Prevention Act. The Act establishes a presumption that goods connected to the Xinjiang Uyghur Autonomous Region are produced using forced labour. Importers must provide sufficient evidence to demonstrate otherwise. 

United Kingdom Legislation:

The Modern Slavery Act 2015 represented a major change in the way the United Kingdom addresses slavery, servitude, and human trafficking. The legislation brought previously separate offences together under a single legal structure. It expanded enforcement powers through prevention orders and asset recovery mechanisms. It also strengthened protections and support available to victims. It also established the Independent Anti Slavery Commissioner to improve coordination and effectiveness across national prevention and enforcement activity.

In addition to its enforcement focus, the Act introduced a reporting requirement for larger organisations, requiring annual public statements describing how modern slavery risks are managed across operations and supply chains. While this requirement has improved transparency around corporate practices, the absence of direct financial penalties has reduced its impact in some instances. A 2019 independent review proposed reforms aimed at strengthening accountability and aligning the United Kingdom’s framework more closely with evolving international reporting expectations.

Australian Legislation:

Australia introduced a mandatory reporting framework through the Modern Slavery Act 2018, applying to organisations with consolidated annual revenue of at least AUD 100 million. Entities captured by the legislation are required to publish an annual statement explaining how modern slavery risks are identified, assessed, and addressed across both operations and supply chains. These statements are made publicly available through a register administered by the Australian Border Force, improving transparency and access for investors, customers, and the broader community.

While the legislation does not currently impose direct financial penalties for reporting failures, inadequate disclosure can still carry significant consequences. Non-compliant entities may be publicly identified and face reputational harm or increased stakeholder scrutiny. In July 2026, the Australian Government announced proposed civil penalties for breaches of current reporting requirements and a new criminal offence for companies that fail to prevent modern slavery in their supply chains. These reforms remain under consultation and are not yet in force. They signal a move towards stronger accountability, credible action, and effective risk management.

New Zealand Legislation:
In 2022, the New Zealand Government outlined a stronger policy direction on modern slavery and worker exploitation through draft legislative proposals. The proposed changes reflect a move beyond transparency focused approaches toward more active organisational responsibility. Businesses are expected to take reasonable and proportionate steps to identify and address modern slavery risks. This applies across both domestic operations and international supply chains.

From a corporate responsibility perspective, the draft framework places increased emphasis on accountability and prevention. Reporting obligations are proposed to apply on a tiered basis. Medium and large organisations would be required to publicly outline the actions taken to prevent modern slavery. Larger entities would face additional expectations, including more formal human rights due diligence processes. Collectively, the proposals indicate an intention to align New Zealand more closely with developing international standards and reinforce the role of business in actively managing ethical supply chains.

European Legislation:

In 2024, the European Parliament adopted the Forced Labour Regulation, representing a significant step in how the European Union addresses forced labour risks within global supply chains. The Regulation empowers competent authorities to investigate suspected cases of forced labour and to restrict goods produced under such conditions from being placed on, sold within, or exported from the EU market. Where violations are confirmed, affected products may be prohibited and withdrawn from circulation.

From a corporate responsibility perspective, the Regulation signals a shift toward prevention supported by trade enforcement mechanisms. Non compliance may result in financial penalties, regulatory intervention, and exclusion from public procurement opportunities. The framework raises expectations around supply chain traceability, strengthened human rights due diligence, and evidence based risk management. It reinforces that organisations operating in or trading with the EU are expected to take proactive steps to prevent forced labour. This moves beyond relying solely on disclosure.

France Legislation:

France has strengthened expectations for responsible business conduct through the Corporate Duty of Vigilance Law, which applies to certain large organisations operating within the country. The legislation introduces mandatory human rights and environmental due diligence requirements. It obligates organisations within scope to develop, implement, and publicly disclose a vigilance plan. This plan outlines how significant risks are identified, prevented, and mitigated across both operations and supply chains.

From a corporate responsibility perspective, the framework moves beyond passive monitoring toward active accountability. Non compliance may result in legal proceedings and financial liability. This underscores the importance of documented processes and effective governance structures. It also requires clear evidence that risk management measures are operating in practice. The law reinforces that managing human rights and environmental impacts is an ongoing responsibility that must be integrated into everyday business activities and commercial relationships.

Germany Legislation:

Germany introduced the Supply Chain Due Diligence Act to strengthen legal expectations around responsible business conduct, with the legislation taking effect in 2023. The law requires large organisations operating in Germany to implement structured processes to identify and address human rights and environmental risks arising from both their own operations and their supply chains. This includes exposure to risks such as forced labour and child labour, with organisations expected to establish systematic approaches to risk identification, prevention, and reporting. Amendments introduced in 2024 lowered the employee threshold, expanding the number of organisations captured by the legislation and increasing its overall reach.

Norway Legislation:

Norway strengthened expectations around responsible business conduct through the Transparency Act, which came into effect in 2022. The legislation applies to companies meeting defined size thresholds and introduces mandatory human rights due diligence requirements. Organisations within scope must assess risks associated with both their own activities and supply chains and publicly explain how those risks are identified, managed, and addressed over time.

A defining element of the framework is its strong focus on transparency and public access to information. Individuals are entitled to request information about a company’s human rights impacts and the steps taken to prevent or reduce harm. From a corporate responsibility perspective, this establishes clear expectations for organisations operating in Norway. They are required to maintain effective due diligence processes and clear accountability structures. Organisations must also provide reliable evidence showing that identified risks are being actively managed in practice.