Modern Slavery Legislation

Canada Legislation:
Amendments to the Customs Tariff Act made it illegal to import goods produced wholly or partially through forced labour. This change significantly expanded the government’s ability to detain or prevent goods from entering the Canadian market. It applies where labour exploitation is suspected. This increases exposure for importers that lack visibility into upstream supplier practices.

This enforcement approach was strengthened in 2023 through the introduction of the Fighting Against Forced Labour and Child Labour in Supply Chains Act, commonly referred to as Bill S 211. The legislation introduces public reporting requirements for certain private sector organisations and public institutions. It requires disclosure of how risks relating to forced and child labour are identified, addressed, and mitigated. This applies across both operations and supply chains.

Together, these developments move expectations beyond general awareness toward demonstrable risk management. Potential penalties of up to CAD 250,000 for non compliance reinforce the importance of structured governance. 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 Kingdom Legislation:

The United Kingdom’s Modern Slavery Act 2015 established a comprehensive legal framework aimed at addressing modern slavery and human trafficking. It combines criminal enforcement measures with corporate transparency requirements. The legislation places responsibility on large organisations to publicly explain how modern slavery risk is considered and managed within their operations and supply chains.

From an enforcement standpoint, the Act brought together existing slavery and trafficking offences. It also expanded the powers available to courts. This includes the use of prevention orders, asset confiscation linked to exploitation, and stronger protections for victims. It also introduced the role of the Independent Anti Slavery Commissioner to promote more consistent national approaches to prevention, coordination, and enforcement.

For organisations managing supply chains, the most immediate impact is the transparency obligation applying to entities with annual turnover above £36 million. These organisations are required to publish an annual statement outlining the steps taken to identify and address modern slavery risk across both operational activities and supplier networks.

Australian Legislation:
Australia’s Modern Slavery Act 2018 applies to organisations with consolidated annual revenue of AUD 100 million or more and operates through a mandatory reporting framework rather than direct enforcement mechanisms. Organisations captured by the legislation are required to publish an annual statement outlining how modern slavery risks are identified, assessed, and managed across both operations and supply chains.

The Australian Government publishes these statements on the Modern Slavery Statements Register, which is administered by the Attorney-General’s Department. This provides visibility to investors, customers, civil society, and other stakeholders. In July 2026, the government announced proposed 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. These reforms are not yet in force but indicate a shift towards stronger enforcement and accountability.

New Zealand Legislation:
In 2022, New Zealand signalled a shift toward a more intervention focused approach to modern slavery. This aligns with broader international developments. It also increases expectations on businesses to actively manage exploitation risks across both domestic operations and global supply chains.

Draft proposals signalled a move away from relying on high level commitments alone. They place greater emphasis on practical risk assessment. They also highlight the need for stronger supply chain visibility and preventative action where risks are identified. Medium and large organisations would be expected to publicly disclose how these activities are carried out, with larger entities potentially subject to more detailed due diligence obligations.

European Legislation:

In 2024, the European Union moved beyond disclosure based approaches by adopting the Forced Labour Regulation, granting authorities the power to remove goods linked to forced labour from the EU market. Under the regulation, affected products can be prohibited from sale, import, or export, with non compliant goods required to be withdrawn entirely from circulation.

The enforcement framework introduces significant commercial consequences, including financial penalties, sanctions, and potential exclusion from public procurement opportunities. For supply chain professionals, the direction is clear. Continued access to the EU market increasingly depends on credible upstream risk management. Organisations are expected to actively identify, prevent, and address forced labour exposure across their supply networks. This goes beyond relying solely on reporting obligations.

France Legislation:

France’s Corporate Duty of Vigilance Law introduced one of the more structured human rights due diligence frameworks globally. Enacted in 2017, it applies to large organisations employing more than 5,000 people. It establishes clear obligations for managing human rights and environmental risks. These obligations extend across both internal operations and extended supply chains.

Organisations captured by the legislation must develop, implement, and publicly disclose a vigilance plan outlining how risks are identified, prevented, and addressed throughout their value chain. The requirement extends beyond transparency, placing emphasis on ongoing risk mapping, preventative measures, and continuous monitoring rather than one off disclosure.

Germany Legislation:

Germany’s Supply Chain Due Diligence Act introduces a mandatory and enforceable framework for managing human rights and environmental risks across supply chains. Passed in 2021 and coming into effect in 2023, the legislation initially applied to companies with more than 3,000 employees before expanding in 2024 to include organisations with 1,000 or more employees.

Organisations within scope must establish processes to identify, prevent, and respond to risks such as forced labour and child labour across both their own operations and supplier networks. The law places emphasis on ongoing monitoring and regular public reporting, reflecting an expectation of continuous oversight rather than periodic assessment.

Failure to comply can result in substantial financial penalties and exclusion from public procurement opportunities.

Norway Legislation:

Since 2022, Norway’s Transparency Act has introduced a formal obligation for businesses with 50 or more employees to carry out human rights due diligence, extending regulatory expectations beyond large multinational organisations. The legislation requires in scope companies to take a structured approach to identifying and managing human rights risks across both their own operations and supplier networks.

Organisations are expected to assess risks on an ongoing basis and explain how those risks are identified, addressed, and monitored over time. The emphasis is placed on maintaining continuous processes rather than relying on isolated or periodic assessments.

A distinguishing element of the Act is its strong transparency requirement. Members of the public are able to request information about a company’s human rights impacts and the actions taken in response, increasing external visibility and scrutiny.