# Dashboard & Reporting Obligations

The statutory reporting framework, approval mechanics, and governance authorities that anchor annual S-211 compliance work.

## The Core Reporting Framework Under the Supply Chains Act

The Act applies to entities engaged in specified goods-related activities and requires an annual May 31 report covering the mandatory categories in section 11.

For private-sector entities, the legal starting point is section 9 of the Fighting Against Forced Labour and Child Labour in Supply Chains Act. It captures entities that produce, sell, or distribute goods, import goods into Canada, or control entities carrying on those activities. Section 11 then requires an annual report to the Minister of Public Safety on or before May 31 describing the steps taken during the previous financial year to prevent and reduce the risk that forced labour or child labour is used in the production of goods or in imported goods.

Section 11(3) is the operative checklist for annual reporting. It requires disclosure about structure, activities and supply chains; policies and due diligence processes; risk areas and the steps taken to assess and manage those risks; remediation measures for forced labour or child labour; remediation of loss of income to vulnerable families; training; and how the entity assesses effectiveness. Public Safety Canada's reporting guidance tracks this structure closely and expects narrative disclosure about what the entity actually did, not generic statements of aspiration.

The reporting page and Public Safety Canada's guidance also matter operationally because they explain where the report has to appear after submission: in the federal catalogue and in a prominent place on the reporting entity's own website. For dashboard and readiness purposes, that means the legal compliance task is not complete when a PDF is drafted. It is complete only when approval, attestation, submission, and public posting are all aligned.

### Citations

- Supply Chains Act, s 9: Fighting Against Forced Labour and Child Labour in Supply Chains Act, s 9 (application to entities) (https://laws-lois.justice.gc.ca/eng/acts/F-10.6/section-9.html)
- Supply Chains Act, s 11: Fighting Against Forced Labour and Child Labour in Supply Chains Act, s 11 (annual report, mandatory contents, approval and attestation) (https://laws-lois.justice.gc.ca/eng/acts/F-10.6/section-11.html)
- PSC Reporting Obligations: Public Safety Canada, Reporting obligations (https://www.publicsafety.gc.ca/cnt/cntrng-crm/frcd-lbr-cndn-spply-chns/rprtng-blgtns-en.aspx)

## Board Approval, Attestation, and Informed Oversight

The Act makes governing-body approval and attestation mandatory, while Canadian governance authorities explain why directors should approach that step as a real risk-oversight exercise.

Section 11(4) and (5) of the Act require the report to be approved by the governing body and evidenced by a statement of approval plus the signature of one or more members of that governing body. That statutory design is important: it elevates supply-chain reporting from a back-office disclosure task to a governance task that must be owned at board or equivalent governing-body level.

BCE and Peoples are not S-211 cases, but they are core Canadian governance authorities for how directors should approach this role. BCE explains that directors act in the best interests of the corporation viewed as a good corporate citizen and may consider the interests of affected stakeholders. Peoples emphasizes that directors must act prudently and on a reasonably informed basis. Read together, those authorities support using the annual report process as a structured board review of supply-chain human-rights risk, not a rubber-stamp exercise.

National Policy 58-201 is also helpful by analogy because it recommends that boards adopt a written mandate for stewardship of principal business risks and ensure systems are in place to manage them. In an S-211 setting, the practical implication is straightforward: if the board is asked to approve and attest to a report, management should be able to show the evidence chain behind the report, the risk methodology used, and the process by which the governing body reviewed the draft before signing.

### Citations

- Supply Chains Act, s 11(4)-(5): Fighting Against Forced Labour and Child Labour in Supply Chains Act, s 11(4)-(5) (approval and attestation) (https://laws-lois.justice.gc.ca/eng/acts/F-10.6/section-11.html)
- 2008 SCC 69: BCE Inc. v. 1976 Debentureholders, 2008 SCC 69, [2008] 3 SCR 560 (https://scc-csc.lexum.com/scc-csc/scc-csc/en/item/6238/index.do)
- 2004 SCC 68: Peoples Department Stores Inc. (Trustee of) v. Wise, 2004 SCC 68, [2004] 3 SCR 461 (https://scc-csc.lexum.com/scc-csc/scc-csc/en/item/2184/index.do)
- NP 58-201: National Policy 58-201, Effective Corporate Governance (https://www.osc.ca/en/securities-law/instruments-rules-policies/5/58-201/national-policy-np-58-201-effective-corporate-governance)