If you’re a Canadian company or have Canadian subsidiaries, FRDM can help you get your Bill S211 reports up and running in time for your May reporting deadline. This is because we can help you set a baseline, show graphical reports of actions and improvements, and (as an SCRM) house custom reports and audit paperwork within our platform.
Below is a line-by-line breakdown of where FRDM can help you with your reporting. Both in 2024 and in perpetuity.
Bill S211 requires you to include 7 things in your report. They are:
- Information on your structure, activities, and supply chains;
- Your policies and due diligence processes in relation to forced labour and child labour;
- Where your risk lies, and steps taken to assess and manage that risk;
- Accounting of your remediation efforts;
- Loss of income remediation resulting from your actions to mitigate forced or child labor;
- Training on forced and child labor; and
- Assessment of effectiveness.
1. Information on your structure, activities, and supply chain.
FRDM can map your supply chain, and help you understand where your relationships lie upstream without the need to ever contact your suppliers. We can tell you where your suppliers do business, with what companies, and operating out of which countries.
This gives you a far greater understanding of your supply chain, in a far shorter time than you could accomplish with questionnaires. In addition, the very act of setting up your FRDM account will fulfill most of the stipulations of the first S211 requirement, you just need to report on it.
All these visuals, plus the raw data behind it, will allow you to tell a clear story about what your supply chain looks like.
2. Your policies and due diligence processes in relation to forced and child labour
FRDM helps assess your company’s policies and procedures as well as federating the policies and procedures of all suppliers. We work with companies all over the world, advising them on best practices.
FRDM works with hundreds of companies within dozens of legal jurisdictions. While we don’t offer direct legal compliance advice, we’re happy to provide context based on our experience to help your team shape their own internal policies. Our in-app assessment tool will help you determine where you stand:
In addition, modules within FRDM can help provide frameworks for internal policies:
FRDM tracks Human Rights Media Alerts based on the countries, industries, products and suppliers uploaded into our system.
Creating a set cadence for monitoring, responding to and tracking these alerts could be a viable policy for S211 reporting.
Use this information to build out processes for vetting new suppliers or help existing suppliers find less risky sourcing opportunities. Reach out to support to find out more ways to utilize this data!
3. Where your risk lies, and steps taken to assess and manage that risk;
Reporting must include information about a company's risk analysis of the entire supply chain and the steps it has taken to assess and manage that risk. FRDM will take the supplier information provided and automatically analyze risk based on a multitude of leading human rights reporting sources.
FRDM can help you risk rank so you know where your highest exposure is. You can then create a plan for what your relationship looks like with these suppliers moving forward.
Now that you know where the risk is, you know where to start!
This may include finding alternative sources for the necessary products, or having a conversation with the suppliers where they provide mitigating documentation showing their commitment to rooting out human rights abuses in their own supply chain. You can then collect that documentation right in the platform:
In addition to the sorting and filtering in the platform, the FRDM support team can also help you build custom data extracts so that you can slice and dice the data we provide in anyway you see fit. Reach out to support@frdm.co to learn more about custom reporting!
4. Accounting of your Remediation Efforts
Once risk is determined FRDM offers multiple mitigation tools to address risk. This means showing the actions, uploading audits and custom action plans, as well as monitoring media alerts and resolving those alerts.
Your actions are tracked in aggregate:
And individually:
You can use our standard visuals or, as with everything else in FRDM, your FRDM support team can help you build custom data extracts so you can display your data exactly how you want it.
5. Measures taken to remediate the loss of income incurred by the most vulnerable families that results from any measure taken to eliminate the use of forced or child labour from its activities and supply chains.
In a nebulous piece of legislation scant on detailed reporting guidance, this may be the most broad requirement. Any corporate donations around human rights causes is most likely reportable in this section. For FRDM’s part, we donate a portion of all of our contracts to organizations and projects protecting children from slavery. This can (and should) be part of your reporting for this requirement.
6. Training provided to employees.
FRDM has both synchronous and asynchronous training opportunities for our clients. Here are just a few of the options available:
- Slavery Footprint - Build finding out your personal slavery footprint into your team’s human rights awareness training.
- Modern Slavery Training - Free for FRDM customers, take our Modern Slavery Training courses.
- Workshops - Collaborate with the FRDM support team to build internal, or co-hosted, modern slavery awareness workshops for your team.
- Keynotes - In addition to being our CEO and Founder, Justin Dillon, is a writer, activist and speaker.
As a company founded on the mission to stop forced labour, we can and will help your organization understand the true impact of your due diligence and improve.
7.Assessment of effectiveness.
FRDM tracks your and your supplier’s risk and mitigation efforts over time. Both within the platform itself and via the custom reporting you’ll build out with your support team, you can compare your current standing with past performance in order to see how your mitigation efforts are working over time:
These are just a few ways that FRDM can help you with your S211 statement. If you’re not a FRDM user currently, reach out to our team to discuss how we can help!
If you’re currently a FRDM user, what are you waiting for? Log in and start managing your modern slavery risk!
