Modern Slavery Legislation

Canada Legislation:
Canada has moved toward a more enforcement oriented position on forced labour within its trade and human rights policy framework. Amendments to the Customs Tariff Act took effect in 2020. These changes introduced a ban on the import of goods produced wholly or in part through forced labour. They use border controls as a mechanism to enforce this restriction. This helps prevent exploitative products from entering the domestic market.

This direction was reinforced 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 entities and public institutions to publish annual reports. These reports describe how they identify, assess, and address risks of forced labour and child labour. This applies across their operations and supply chains. Supported by the potential for financial penalties, the framework carries stronger enforcement weight. In June 2026, Canada introduced Bill C-35 to strengthen enforcement through high-risk goods listings and enhanced supply chain tracing requirements. The Bill is not yet in force.

United States Legislation:
At the state level, the California Transparency in Supply Chains Act requires certain large businesses to disclose how they address risks of forced labour and human trafficking within their direct supply chains. Federally, the Tariff Act of 1930 provides enforcement authority. It empowers U.S. Customs and Border Protection to detain shipments. This occurs where there is evidence that goods were produced using forced or indentured labour. As a result, such products are prevented from entering the United States market.

These authorities were further reinforced through the Uyghur Forced Labour Prevention Act. It establishes a presumption that goods connected to the Xinjiang Uyghur Autonomous Region are produced with forced labour. This means they are restricted from entry. The restriction applies unless importers can provide sufficient evidence to the contrary. Collectively, these measures create clear expectations for rigorous due diligence, dependable supply chain traceability, and evidence based sourcing practices for organisations importing goods into the United States.

United Kingdom Legislation:

The Modern Slavery Act 2015 strengthened the United Kingdom response to slavery, servitude, and human trafficking by consolidating related offences within a single statutory framework. The legislation broadened the powers of courts and enforcement agencies to disrupt exploitation, prevent criminal activity, and enhance protections for victims. It also created the position of the Independent Anti-Slavery Commissioner to promote more coordinated and effective prevention and enforcement efforts.

The Act also introduced a corporate transparency requirement. It applies to organisations above a specified turnover threshold. These organisations are required to publish annual statements. The statements outline how modern slavery risks are identified and addressed. This applies across their operations and supply chains. Although this measure has improved public disclosure, the lack of financial penalties has constrained enforceability. An independent review in 2019 called for stronger compliance mechanisms, reflecting increasing expectations that transparency should be accompanied by practical action and clear organisational accountability.

Australian Legislation:

Australia introduced a mandatory reporting regime through the Modern Slavery Act 2018, which applies to organisations with consolidated annual revenue of at least 100 million Australian dollars. Entities within scope are required to publish an annual statement describing how modern slavery risks are identified, assessed, and managed across their operations and supply chains. These statements are made publicly available through a central register overseen by the Australian Border Force.

While the legislation does not currently impose direct financial penalties for reporting failures, weak compliance can still have significant consequences. Inadequate disclosure or ineffective governance may lead to public identification, reputational harm, and increased scrutiny from investors, customers, regulators, and civil society groups. Following a statutory review, the Australian Government announced proposed reforms in July 2026. These include civil penalties for breaches of existing reporting obligations and a new criminal offence for companies that fail to prevent modern slavery in their supply chains. The reforms are not yet in force but signal a move towards stronger accountability, credible action, and effective risk management.

New Zealand Legislation:
In 2022, the New Zealand Government signalled a more assertive approach to modern slavery and worker exploitation through draft legislative proposals. These proposals indicate a shift in approach. They move beyond passive transparency. Instead, they emphasise more active responsibility. Organisations are expected to take reasonable and proportionate steps. This includes identifying and addressing modern slavery risks. It applies across both domestic operations and international supply chains.

From a corporate responsibility standpoint, the draft framework places greater weight on accountability and prevention. Reporting obligations would apply on a tiered basis. Medium and large organisations would be required to outline publicly the measures they are taking to prevent modern slavery. Larger entities would face additional expectations. These include more formal human rights due diligence processes. Collectively, the proposals suggest an intention to align New Zealand more closely with developing international standards and to strengthen the role of business in actively managing ethical supply chains.

European Legislation:

In 2024, the European Parliament adopted the Forced Labour Regulation, marking a major step in how the European Union addresses forced labour within global supply chains. The regulation authorises competent authorities to investigate suspected cases of forced labour and to block goods produced under such conditions from being placed on, sold within, or exported from the EU market. Where breaches are confirmed, products may be banned and required to be removed from circulation.

From a corporate responsibility perspective, the Regulation signals a decisive move toward prevention through trade based enforcement. Non compliance can result in financial penalties, regulatory restrictions, and exclusion from public procurement processes. The framework heightens expectations across several areas. It strengthens requirements for supply chain traceability. It also emphasises strong human rights due diligence. There is a clear focus on evidence based risk management. Together, these expectations reinforce that organisations operating in or trading with the EU must take active steps to prevent forced labour. They cannot rely on disclosure alone.

France Legislation:

France has strengthened expectations for responsible business conduct through the Corporate Duty of Vigilance Law, which applies to certain large companies operating in the country. The legislation introduces mandatory human rights and environmental due diligence obligations. It requires organisations within scope to establish and implement a vigilance plan. They must also publicly disclose this plan. The plan outlines how risks are identified, prevented, and mitigated. This applies across their operations and supply chains.

From a corporate responsibility perspective, the framework moves beyond passive oversight toward active stewardship. Non compliance can result in legal proceedings and financial penalties, highlighting the need for documented processes, effective governance, and demonstrable implementation. The law reinforces that managing human rights and environmental impacts must be an ongoing and accountable effort embedded within daily business operations and commercial relationships.

Germany Legislation:

Germany has strengthened expectations for responsible business conduct through the Supply Chain Due Diligence Act, which took effect in 2023. The legislation introduces mandatory human rights and environmental due diligence obligations for large organisations operating in Germany. It requires them to systematically identify and prevent risks. They must also report on those risks. This applies within their own activities and across their supply chains. It includes exposure to forced labour and child labour. An expansion in 2024 lowered the employee threshold, bringing a significantly larger number of organisations within scope and extending the reach of the regime.

From a corporate responsibility perspective, the Act reinforces the expectation that businesses maintain an active and ongoing role in safeguarding human rights. Non compliance may lead to substantial financial penalties and exclusion from public procurement opportunities, highlighting the importance of documented procedures, consistent oversight, and effective risk management. The framework reflects a clear shift toward continuous due diligence and accountable supply chain stewardship rather than reliance on one time assessments or disclosure alone.

Norway Legislation:

Norway strengthened expectations for responsible business conduct through the Transparency Act, which came into force in 2022. The law applies to companies that meet specified size criteria and introduces mandatory human rights due diligence obligations. Organisations within scope are required to evaluate risks across their own activities and supply chains and to explain publicly how those risks are identified, managed, and addressed.

A notable element of the framework is its emphasis on openness. Individuals have the right to request information about a company’s human rights impacts and the measures taken to prevent or reduce harm. From a corporate responsibility standpoint, this creates considerable expectations for organisations operating in Norway. They are required to maintain robust due diligence systems. Clear accountability structures are also expected. In addition, organisations must provide credible evidence that identified risks are being actively managed in practice.