2024–2025 Report on reporting obligations under the Fighting Against Forced Labour and Child Labour in Supply Chains Act (S-211)

1 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 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, Mandate and Member Services and Internal Services). Through these services, the ATSSC supports improving access to justice for Canadians.

2.1 Structure, activities, and supply chains

At the ATSSC, approximately 74.09% of the annual value of our purchases were made using PSPC tools such as Standing Offers and Supply Arrangements.

The ATSSC awarded 66 contracts and issued 4 amendments for goods between April 1, 2024, to March 31, 2025. The total cost of goods procured was $1,930,406.34.

Since November 2021, Public Services and Procurement Canada (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:

• 5835: Sound Recording and Reproducing Equipment
• 7010: Automatic Data Processing Equipment (ADPE) System Configuration
• 7030: Automatic Data Processing (ADP) Software
• 7110: Office Furniture
• 7510: Office Supplies

2.2 Information on the steps taken 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

Indicate steps taken in the 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.

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 and services under its own procurement authority in the following areas:

• office furniture
• office supplies
• information technology
• audio-visual equipment

Before purchasing the goods or service, procurement officers verify the list of ineligible and suspended suppliers through the Office of Supplier Integrity and Compliance. They 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 Information on the policies and due diligence processes in relation to forced labour and child labour

Does the government institution currently have policies and due diligence processes in place related to forced labour and/or 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:

• verifying the Office of Supplier Integrity and Compliance (Integrity Regime) list of Ineligible and suspended suppliers, regardless of the value
• 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.

Has the government institution identified the parts of its activities and supply chains that carry a risk of forced labour or child labour being used?

The ATSSC has started the process of identifying risks, but there are still gaps in its assessments.

In May 2021, a risk analysis of PSPC’s supply chains was completed by Right 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 took note of the findings and recommendations of this risk analysis and is monitoring related follow-action, including implementing the Policy on Ethical Procurement and developing a human rights due diligence framework.

SSC is committed to ongoing risk identification, promotion and development of mitigation practices. It is leading ongoing activities to raise awareness within its procurement community and engage with industry and strategic partners.

Has the government institution identified forced labour or child labour risks in its activities and supply chains related to any of the following sectors and industries?

• Agriculture, forestry, fishing and hunting
• Mining, quarrying, and oil and gas extraction
• Utilities
• Construction
• Manufacturing
• Wholesale trade
• Retail trade
• Transportation and warehousing
• Information and cultural industries
• Finance and insurance
• Real estate and rental and leasing
• Professional, scientific and technical services
• Management of companies and enterprises
• Administrative and support, waste management and remediation services
• Educational services
• Health care and social assistance
• Arts, entertainment and recreation
• Accommodation and food services
• Other services (except public administration)
• Public administration
• None of the above
• Other, please specify

The ATSSC has not identified forced labour or child labour risks in its activities and supply chains related to any of the sectors and industries listed above.

2.5 Information on any measures taken to remediate any forced labour or child labour

Has the government institution taken any measures to remediate any forced labour or child labour in its activities and supply chains?

The ATSSC has not identified any forced labour or child labour in our activities and supply chains.

2.6 Information on any 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

Has the government institution taken any measures to remediate the loss of income to the most vulnerable families that results from any measure taken to eliminate the use of forced or child labour in its 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 our activities and supply chains.

2.7 Information on the training provided to employees on forced labour and child labour

Does the government institution currently provide training to employees on forced labour and/or child labour?

The ATSSC doesn’t currently provide training to its employees. However, the ATSSC is aware that PSPC is piloting a course for procurement officers and it will leverage this course once it is available. The SSC is committed to ongoing risk identification, promotion and development of mitigation practices. It is leading activities to raise awareness within its procurement community and engage with industry and strategic partners.

2.8 Information on how the government institution assesses its effectiveness in ensuring that forced labour and child labour are not being used in its activities and supply chains

Does the government institution currently have policies and procedures in place to assess its effectiveness in ensuring that forced labour and child labour are not being used in its 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:

• verifying the Office of Supplier Integrity and Compliance (Integrity Regime) list of Ineligible and suspended suppliers, regardless of the value
• 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