August 21, 2026
To whom it may concern,
Thank you for the opportunity to comment on Canada’s measures to address forced labour and labour exploitation in global supply chains.
More people are living in conditions of modern slavery today than at any point in recorded history. Forced labour, debt bondage, human trafficking, and other forms of exploitation continue to generate enormous profits by stripping millions of people of their freedom, safety, and dignity.
Canada has committed to helping eradicate modern slavery by 2030. Achieving that objective requires more than transparency and corporate reporting. It requires enforceable legal obligations, meaningful consequences for non-compliance, and effective remedies for workers whose rights have been violated.
Canada’s forced labour import prohibition and the Fighting Against Forced Labour and Child Labour in Supply Chains Act were important steps forward. However, transparency alone is not accountability. Canada now needs a comprehensive human rights due diligence regime supported by enforcement, civil liability, and independent oversight.
The following recommendations are intended to ensure that Canada’s approach aligns with its commitment to eradicate modern slavery and reflects emerging international standards for corporate human rights accountability.
Recommendation 1: Eradicate All Forms of Forced Labour
Canada should not create a system that effectively distinguishes between forms of forced labour that will be tolerated and those that will not.
The objective must be clear: no forced labour, debt bondage, human trafficking, or severe labour exploitation should be permitted to sustain goods or services entering the Canadian market.
Canada’s legal framework should be designed to prevent and eliminate exploitation throughout supply chains, rather than merely requiring companies to disclose its existence. Efforts to combat forced labour should focus on protecting workers and preventing harm, not simply increasing corporate reporting.
Recommendation 2: Create Civil Liability for Failure to Conduct Adequate Due Diligence
A due diligence obligation without meaningful consequences for failing to meet it risks becoming little more than another reporting exercise.
Workers subjected to forced labour or serious labour exploitation should have a statutory right to bring claims in Canadian courts against companies that fail to exercise adequate human rights due diligence over their operations and supply chains.
Civil liability is essential because corporate accountability cannot depend entirely on government enforcement. The possibility of litigation, damages, and other legal consequences creates a strong incentive for companies to identify, prevent, and address risks before harm occurs.
However, a right that cannot realistically be exercised is no right at all. Parliament must address the significant financial and procedural barriers faced by workers bringing claims from abroad. This should include protections against prohibitive legal costs, mechanisms for representative or collective proceedings, and clear rules governing available remedies and damages.
This need is particularly acute following the elimination of the Canadian Ombudsperson for Responsible Enterprise. Workers should not be left without either an effective independent complaints mechanism or a realistic pathway to seek justice through the courts.
Recommendation 3: Establish a Strong, Independent Ombudsperson for Responsible Enterprise
Corporate due diligence cannot rely on companies effectively regulating themselves without independent oversight or enforceable accountability.
Canada needs an independent institution with the authority and resources to investigate allegations of forced labour and serious human rights abuses, monitor corporate compliance, identify systemic risks, and hear directly from affected workers and civil society organizations.
The Canadian Ombudsperson for Responsible Enterprise was intended to help fulfill this role. However, it never received the powers necessary to do so effectively. Without the authority to compel documents or testimony, its ability to investigate corporate conduct was fundamentally limited.
Eliminating the office did not address those shortcomings; it removed one of the few existing mechanisms through which workers and civil society could seek independent review of corporate conduct.
Canada should establish a new independent Ombudsperson or Commissioner for Responsible Enterprise with genuine investigatory authority, including the power to compel evidence, receive complaints directly from affected workers and civil society organizations, conduct independent investigations, and issue enforceable findings or orders within its jurisdiction.
Oversight must be independent of the companies being investigated and sufficiently empowered to uncover facts that companies may have little incentive to disclose voluntarily.
Conclusion
Canada’s commitment to eradicate modern slavery must be reflected in a legal framework that prevents exploitation, holds companies accountable, and provides meaningful remedies to those harmed.
Important progress has been made through import restrictions and supply chain transparency requirements. However, transparency alone cannot prevent forced labour, nor can it guarantee accountability when abuses occur.
A credible Canadian approach requires mandatory human rights due diligence, effective enforcement mechanisms, civil liability for companies that fail to meet their obligations, meaningful access to justice for affected workers, and an independent oversight body with the authority to investigate and act.
Canada should ensure that no business operating in or benefiting from the Canadian market can do so at the expense of workers’ fundamental rights. The costs of forced labour and exploitation should be borne by those who enable or profit from them, not by the workers subjected to abuse.
If Canada is serious about achieving its commitment to eliminate modern slavery, it must move beyond transparency and establish a system that prevents harm, delivers accountability, and protects human dignity throughout global supply chains.
Respectfully submitted,
Elizabeth May, O.C. Member of Parliament for Saanich—Gulf Islands Leader of the Green Party of Canada