In the fight against modern slavery, COVID-19 presents a rare opportunity for Canadian businesses to get it right

Modern slavery in businesses and supply chains in Canada - Part four

6 minute read
20 April 2020


From the first mile to the last, the coronavirus pandemic has devastatingly and irrevocably disrupted so many global supply chains that support and fuel businesses around the world. As Canadian businesses rush to stabilize and adapt amid the ongoing chaos, however, boards of directors should take this once-in-a-lifetime opportunity to really get it right as they reimagine, revitalize and rebuild their supply chains. This includes taking meaningful steps to ensure the exclusion of modern slavery.

As the world continues to search for a "new normal" in so many respects – from the daily obstacles individuals face to strengthening global economic headwinds – there is no "new normal" for forced labour, human trafficking and child labour (collectively, "modern slavery") in Canadian businesses and their supply chains. Indeed, as consumers, buyers and procurement departments alike frantically scramble to fill their supply chains from suppliers around the globe, the presence of modern slavery is more likely than ever to be overlooked or go unrecognized.

This notwithstanding, during the past few years, many major brands have successfully developed and implemented various initiatives to combat modern slavery in their supply chains. Such measures include revised purchasing policies, factory inspections and supplier audits – as well as programs to monitor and report on these efforts.

In these uncertain times, businesses – like doctors – must heed the words of Hippocrates in his works Of the Epidemics: Primum non nocere "First, do no harm".

Whether it is on-shoring, near-shoring or leaving pre-pandemic supplier relationships intact, boards of directors must address the risks of modern slavery in their supply chains to ensure the long term-sustainability of their businesses.


  • Step 1: The Board can adopt and have management implement a policy that prohibits modern slavery in the business, its operations and supply chains. Investors and stakeholders are already looking for this.
  • Step 2: Management can conduct risk assessments (both qualitative and quantitative) of the presence of modern slavery in the business, its operations and supply chains, and then implement remediation measures where needed.
  • Step 3: The Board and management can engage with stakeholders, employees and suppliers in implementing its modern slavery prohibition measures, and provide education and training as appropriate.

Boards of directors need to carefully consider these issues in implementing their pandemic responses and in developing post-pandemic strategies that will drive the sustainability and long-term value of their business or organization. Boards of directors and business leaders would be well-advised to take the necessary steps to create a "next normal" for their business of which they, shareholders and stakeholders (and Hippocrates) can be proud.

More in this series

For further information, please read the other parts of our Guide to addressing modern slavery in your business and supply chain for Canadian directors:

How we can help

To find out more about how Gowling WLG can help your business expertly organize and manage due diligence and other governance, risk, compliance and supply chain issues, please contact the author Stephen Pike.

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