Training requirements and implementation strategies for compliance with modern day slavery laws in Canada

The Fighting Against Forced Labour and Child Labour in Supply Chains Act in Canada establishes comprehensive training requirements as a fundamental component of effective compliance programmes. The legislation requires entities to describe in their annual reports the training provided to employees on forced labour and child labour, recognising that human capacity building is essential for identifying risks, implementing due diligence measures and ensuring the effectiveness of prevention and remediation efforts.

Training under the Act must be appropriate to the roles and responsibilities of different employees within the organisation. This risk-based approach to training ensures that resources are allocated effectively and that employees receive relevant, actionable information that enables them to contribute to the organisation's compliance efforts. Senior management requires strategic oversight training, while procurement staff need detailed guidance on supplier assessment and contract management and operational employees may need awareness training on recognising indicators of forced labour and child labour.

The Act requires entities to report not only on the training provided but also on its effectiveness in achieving the organisation's objectives for preventing and addressing forced labour and child labour. This effectiveness requirement moves beyond simple compliance metrics such as training completion rates to focus on whether training is actually improving the organisation's ability to identify and address risks. Entities must therefore implement systems for measuring training effectiveness and continuously improving their training programmes based on these assessments.

Effective training programmes begin with comprehensive needs assessments that identify the specific knowledge, skills and competencies required for different roles within the organisation. For senior executives and board members, training should focus on governance responsibilities, legal obligations and strategic risk management. This audience requires understanding of the business case for addressing forced labour and child labour risks, including potential financial, operational and reputational impacts on the organisation.

Procurement and supply chain professionals require detailed technical training on conducting supplier assessments, evaluating labour practices and implementing contract provisions related to forced labour and child labour prevention. This training should include practical skills such as conducting supplier interviews, reviewing documentation and identifying red flags that may indicate labour violations. These professionals also need training on remediation procedures and how to work with suppliers to address identified issues.

Human resources personnel require training on internal labour practices, employee rights and procedures for addressing potential issues within the organisation's own operations. This includes understanding vulnerable worker populations, recognising signs of forced labour and implementing appropriate recruitment and employment practices. HR professionals also play a key role in implementing training programmes and ensuring that all employees receive appropriate awareness training.

Operational managers and supervisors need training on recognising indicators of forced labour and child labour in day-to-day operations, including signs of worker exploitation, inadequate working conditions and inappropriate employment practices. This training should be practical and action-oriented, providing clear guidance on what to do when potential issues are identified and how to report concerns through appropriate channels.

All employees should receive baseline awareness training on the organisation's policies regarding forced labour and child labour, their role in preventing these practices and available reporting mechanisms. This training should be accessible, culturally appropriate and regularly updated to reflect changes in policies, procedures and regulatory requirements.

Training content should be developed based on current research and best practices in addressing forced labour and child labour. This includes understanding the root causes of these practices, the sectors and regions where they are most prevalent and the indicators that may suggest their presence. Training should also cover the organisation's specific policies and procedures, including codes of conduct, supplier requirements and grievance mechanisms.

Delivery methods for training should be varied and appropriate to different audiences and learning styles. This may include in-person workshops, online modules, webinars, case studies and simulation exercises. Interactive training methods that engage participants and provide opportunities for practice and feedback are generally more effective than passive presentations. Training should also be regularly updated to reflect new risks, regulatory changes and lessons learned from the organisation's experience.

Measuring training effectiveness requires establishing clear learning objectives and implementing assessment methods that evaluate whether these objectives have been achieved. This may include pre- and post-training assessments, practical exercises and ongoing performance monitoring. Organisations should also collect feedback from training participants to identify areas for improvement and ensure that training remains relevant and engaging.

Regular refresher training is essential for maintaining awareness and keeping employees informed about changes in risks, policies and procedures. The frequency of refresher training should be based on the level of risk associated with different roles and the rate of change in the organisation's operating environment. High-risk positions may require annual or even more frequent training updates, while lower-risk positions may require less frequent refresher training.

Documentation of training activities is crucial for meeting the Act's reporting requirements and demonstrating compliance with regulatory obligations. Organisations should maintain records of training content, attendance, assessment results and effectiveness measures. This documentation should be regularly reviewed to identify trends and opportunities for improvement in training programmes.

Integration of training with other compliance activities helps ensure that learning is reinforced and applied in practice. This may include incorporating forced labour and child labour considerations into performance evaluations, linking training to career development opportunities and creating ongoing communications that reinforce training messages. Regular communication from senior leadership about the importance of these issues also helps maintain focus and commitment throughout the organisation.