Modern Slavery Act, 2015
Organisations that supply goods/
services with turnover > £36M pa
Thresholds
Supply chain only?
Reporting
requirements?
Rights covered
Timing
Publishing requirements
Penalties & enforcement
Government reporting/
procurement
Modern Slavery Act (Commonwealth), 2018
Duty of Vigilance Act, 2017
Bill S-211 (proposed)
Entities which carry on business in
Australia with > $100M pa
Companies whose head office is in France with
>5,000 employees (including subsidiaries)
Companies that sell, produce, distribute or import goods (or control an entity that does so) and either:
are listed on a Canadian stock exchange, or
meet 2 out of the 3 following criteria:
$20M in assets 250 employees
$40M in annual revenue
U.K.
Australia
France
Canada
Allows voluntary opt-in
Companies established in France with
>10,000 employees (including subsidiaries)
Operations and supply chains
Operations and supply chains
Operations
Subcontractors & suppliers with established business relationship
Operations and supply chains
Reporting only – 6 suggested categories
Reporting only – 4 mandatory criteria plus consultation process with controlled entities
Must establish, publish & implement a Vigilance Plan, covering 5 mandatory criteria
Reporting only – 7 mandatory criteria
Slavery & human trafficking (includes forced labour)
“Modern slavery” (includes trafficking & child labour)
All human rights
Forced and child labour
Annually, within 6 months of financial year end
Annually, within 6 months of financial year end
Annually following financial year end
Annually, by May 31
Must be made public on website or provided
within 30 days upon written request
Minister to maintain public repository
Must be made public and included
in annual report
Must be submitted to minister and made public (including website)
Minister to maintain public registry
Minister may bring court action for injunction
No penalties. If entity is in default, minister may require an explanation or remediation. Where request not complied with, identity may be published.
Interested parties can apply to court to enforce reporting
Fine of up to $250,000 for company and/or directors/officers for:
Failure to report False, misleading statements
Indirect enforcement through Competition Act or provincial consumer protection laws
Indirect enforcement through consumer law
Creates direct civil right of action against reporting company to compensate harm
No
Australian government to publish annual statement covering all Commonwealth Procurement
No
All government institutions
Comparison of modern slavery legislation, 2022
Modern SlaveryAct, 2015
U.K.
Modern Slavery Act (Commonwealth), 2018
Australia
Duty of Vigilance Act, 2017
France
Bill S-211 (proposed)
Canada
Modern Slavery Act, 2015
U.K.
Modern Slavery Act (Commonwealth), 2018
Australia
Duty of Vigilance Act, 2017
France
Bill S-211 (proposed)
Canada
Modern Slavery Act, 2015
U.K.
Modern Slavery Act (Commonwealth), 2018
Australia
Duty of Vigilance Act, 2017
France
Bill S-211 (proposed)
Canada
Modern Slavery Act, 2015
U.K.
Modern Slavery Act (Commonwealth), 2018
Australia
Duty of Vigilance Act, 2017
France
Bill S-211 (proposed)
Canada
Modern Slavery Act, 2015
U.K.
Modern Slavery Act (Commonwealth), 2018
Australia
Duty of Vigilance Act, 2017
France
Bill S-211 (proposed)
Canada
Modern Slavery Act, 2015
U.K.
Modern Slavery Act (Commonwealth), 2018
Australia
Duty of Vigilance Act, 2017
France
Bill S-211 (proposed)
Canada
Modern Slavery Act, 2015
U.K.
Modern Slavery Act (Commonwealth), 2018
Australia
Duty of Vigilance Act, 2017
France
Bill S-211 (proposed)
Canada
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Modern Slavery Act, 2015
U.K.
Modern Slavery Act (Commonwealth), 2018
Australia
Duty of Vigilance Act, 2017
France
Bill S-211 (proposed)
Canada
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Annually, within 6 months of financial year end
Annually, within 6 months of financial year end
Annually following financial year end
Annually, by May 31