2025–2026 Report on reporting obligations under the Fighting Against Forced Labour and Child Labour in Supply Chains Act (S-211)
2025–2026 Report on reporting obligations under the Fighting Against Forced Labour and Child Labour in Supply Chains Act (S-211)May 31, 2026
ISSN: 2818–4262
1. Introduction
Purpose and Scope
The Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Act) came into force on January 1, 2024.
The Act stipulates that any government institution producing, purchasing or distributing goods in Canada or elsewhere must, on or before May 31 of each year, submit a report to the Minister of Public Safety. The report must detail the steps the government institution has taken during its previous financial year to prevent and reduce the risk that forced labour or child labour is used at any step of the production of goods produced, purchased or distributed by the government institution.
As a result, the Administrative Tribunals Support Service of Canada (ATSSC) has created and submitted this annual report for the 2025–2026 fiscal year to the Minister of Public Safety. Given that the ATSSC does not produce goods, the report details the steps taken to prevent and reduce the risk that forced labour or child labour was used at any step of the production of goods purchased by the ATSSC.
According to Section 8 of the Act, this report has been made available to the public, including by publishing it in a prominent place on the ATSSC’s website. Also, under Section 22 of the Act, the ATSSC’s annual reports will be held in an electronic registry on the Public Safety Canada (PSC) website where the public can access them.
About the ATSSC
The ATSSC was established with the coming into force on November 1, 2014, of the Administrative Tribunals Support Service of Canada Act. The ATSSC is responsible for providing support services and facilities to 12 federal administrative tribunals and the National Joint Council (NJC) by way of a single, integrated organization.
These services include the specialized services required to support the mandate of each tribunal (registry services, legal services and mandate and member services), as well as internal services (human resources, financial services, information management and technology, accommodation, security, planning, and communications). Through these specialized services, the ATSSC supports improving access to justice for Canadians.
2. Annual Report
2.1 Structure, activities, and supply chains
At the ATSSC, approximately 82.94% of the annual value of our purchases were made using Public Services Procurement Canada (PSPC) and Shared Services Canada (SSC) tools such as Standing Offers and Supply Arrangements.
The ATSSC awarded 49 contracts and issued 4 amendments for goods between April 1, 2025, to March 31, 2026. The total cost of goods procured was $972,819.00.
Since November 2021, PSPC has added anti-forced labour clauses to all contracts for goods. These clauses allow PSPC to terminate contracts if there is credible information that the goods were produced, in whole or in part, using forced labour or human trafficking. Starting November 20, 2023, all PSPC Standing Offers and Supply Arrangements for goods that have been issued, amended, or refreshed include anti-forced labour clauses.
Because of this, all ATSSC contracts for goods that use these tools include clauses about forced labour which set out, among other things, human rights and labour rights requirements. These clauses can be found in the policy notification 150 – Anti-forced labour requirements.
The most common types of goods procured by the ATSSC are:
- 5836: Video Recording and Reproduction Equipment
- 7010: Automatic Data Processing Equipment (ADPE) System Configuration
- 7030: Automatic Data Processing (ADP) Software
- 7035 Automatic Data Processing (ADP) Support Equipment
- 7045: Computer Supplies and Accessories
2.2 Steps to prevent and reduce risks of forced labour or child labour
The ATSSC has used PSPC’s tools, including Standing Offers and Supply Arrangements, and integrated PSPC’s updated General Conditions for goods contracts and PSPC’s Code of Conduct for Procurement in its purchasing activities to prevent and reduce the risk of forced labour or child labour in our procurements.
While PSPC supports government institutions in their daily operations by acting as the central purchasing agent for the Government of Canada, the ATSSC undertakes activities under its own procurement authority, independently of PSPC tools.
During the previous fiscal year, the ATSSC purchased goods under its own procurement authority in the following areas:
- information technology
- audio-visual equipment
Before purchasing the goods, procurement officers verify the Public Safety catalogue of reports to ensure that the supplier has submitted an annual report. They also verify the Canadian Ombudsperson for Responsible Enterprise news, reports and events to ensure no complaints have been filed against the supplier. These checks are part of the required steps when PSPC or Shared Services Canada (SSC) tools are not used.
2.3 Policies and due diligence processes in relation to forced labour and child labour
The ATSSC does not currently have policies in place. However, when requirements do not use pre-established PSPC and SSC procurement instruments and they are considered a high-risk commodity, the ATSSC follows a due diligence process. This process includes researching the suppliers by:
- reviewing Public Safety Canada’s catalogue of reports website to determine if the supplier has completed a report
- verifying the Canadian Ombudsperson for Responsible Enterprise news, reports and events (garment, mining, oil and gas) to ensure there have been no complaints or investigations
Effective April 1, 2023, amendments to the Treasury Board Directive on the Management of Procurement require contracting authorities from all departments listed in Schedules I, I.1 and II of the Financial Administration Act (with the exception of the Canada Revenue Agency) and commissions established in accordance with the Inquiries Act and designated as a department for the purposes of the Financial Administration Act to incorporate the Code of Conduct for Procurement (“the Code”) into their procurements.
The Code requires vendors providing goods and services to the Government of Canada and their sub-contractors to comply with all applicable laws and regulations. The Code also requires vendors and their sub-contractors to comply with Canada’s prohibition on the importation of goods produced, in whole or in part, by forced or compulsory labour. This includes forced or compulsory child labour and applies to all goods, regardless of their country of origin.
Following these amendments, the ATSSC has continued to integrate the Code into its procurements, to safeguard federal procurement supply chains from forced labour and child labour. The contracts that the ATSSC has awarded include the Code as part of the general conditions for goods.
The prohibition on the importation of goods produced wholly or in part by forced labour came into force under the Customs Tariff in July 2020. This amendment implemented a commitment in the Labour Chapter of the Canada-United States-Mexico Agreement (CUSMA) and applies to all imports, regardless of origin.
2.4 Information on the parts of its activities and supply chains that carry a risk of forced labour or child labour being used and the steps taken to assess and manage that risk.
The ATSSC does not currently have departmental measures in place to assess the risk of forced labour and child labour in its supply chains. However, the majority of the ATSSC’s goods are procured through Standing Offers and Supply Arrangements managed by PSPC and SSC.
The ATSSC is committed to collaborating with stakeholders and federal partners to enhance its understanding and capacity to evaluate such risks across its operations and supply chains. Furthermore, the ATSSC ensures that competitive procurement processes incorporate child labour-related clauses provided by central authorities.
In May 2021, a risk analysis of PSPC's supply chains was completed by Rights Lab, of the University of Nottingham (U.K.), to determine which goods were at the highest risk of exposure to human trafficking, forced labour, and child labour. The analysis, and subsequent report, elaborated key strategies for PSPC to leverage public spending power to raise awareness about forced labour in supply chains.
The ATSSC is aware of the information on the risk assessment provided by PSPC, and is monitoring related follow-action, including the development of a PSPC Policy on Ethical Procurement.
2.5 Measures taken to remediate any forced labour or child labour
The ATSSC has not identified any forced labour or child labour in its activities and supply chains.
2.6 Measures taken to remediate the loss of income to the most vulnerable families that results from any measure taken to eliminate the use of forced labour or child labour in the institution’s activities and supply chains
The ATSSC has not identified any loss of income to vulnerable families resulting from measures taken to eliminate the use of forced labour or child labour in its activities and supply chains.
2.7 Information on the training provided to employees on forced labour and child labour
The ATSSC doesn’t currently provide training to its employees. However, the ATSSC is aware that PSPC is developing awareness-raising guidance materials (including risk mitigation strategies) for suppliers, targeted towards high-risk sectors. The ATSSC will leverage these resources upon their publication.
2.8 Assessing effectiveness in ensuring that forced labour and child labour are not being used in activities and supply chains
The ATSSC does not currently have policies in place. However, when requirements don’t use pre-established PSPC and SSC procurement instruments and they are identified as a high-risk commodity, the ATSSC has put in place a due diligence process to conduct research on the suppliers by:
- reviewing Public Safety Canada’s Catalogue of Reports website to determine if the supplier has completed a report
- verifying the Canadian Ombudsperson for Responsible Enterprise news, reports and events (garment, mining, oil and gas) to ensure there have been no complaints or investigations.
ATSSC is also monitoring the development of guidance and resources from PSPC, including the PSPC Policy on Ethical Procurement, and will leverage these resources upon their release.