With May 31st deadline quickly approaching for Canada’s first mandatory Annual Reports on Forced Labour, many in the Oil, Gas & Petrochem sector may have missed these requirements completely!
Making matters worse, Public Safety Canada’s recently released updated guidance (the “New Guidance”) on Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “FCLA”) leaves a number of “scope” questions unanswered.
On March 20, 2024, Public Safety Canada (“PSC”) released updated guidance (“Guidance”) on the application of the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “FCLA”).
While PSC’s update is aimed to provide clarity, it left many ambiguities, particularly regarding the definitions of “consolidated financial statements”, “asset” and “control”. These terms play a critical role in determining whether a foreign entity may fall within the reporting requirements of the FCLA.
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