Supply Chain Act Report for 2024-2025
Part 1: Identifying information
Financial Reporting Year
- Fiscal year 2024-25 (April 1, 2024 – March 31, 2025).
Status of Report (revised or original)
- This is the original report submitted on May 31, 2025 by CWA.
Is this a report for a federal Crown corporation or a subsidiary of a federal Crown corporation:
- N/A
Part 2: Report contents
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1. Which of the following accurately describes the government institution’s structure?
- Federal department or agency
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2. Information on the government institution’s structure, activities, and supply chains.
Which of the following accurately describes the government institution’s activities?
- Producing goods (including manufacturing, extracting, growing, and processing)
- in Canada
- outside Canada
- Purchasing goods
- in Canada
- outside Canada
- Distributing goods
- in Canada
- outside Canada
CWA is involved in the purchasing of goods. Acquired goods are sourced from suppliers both inside Canada and outside Canada.
Additional information on the government institution’s structure, activities, and supply chains.
CWA is the lead federal department for strategic action to improve freshwater management in Canada by providing leadership, effective collaboration federally, and improved coordination and collaboration with provinces, territories, and Indigenous Peoples to proactively address national and regional transboundary freshwater challenges and opportunities.Under the Canada Water Act, the powers, duties, and functions of the Minister of CWA extend to matters such as:
- Comprehensive water resource management programs
- Water quality management
Over the course of financial reporting year 2024-25, CWA conducted an estimated total of $2 M in procurement contracts (services, goods, and construction included). Of this total, CWA acquired approximately $17 K in goods, across different commodities including, but not limited to, informatics equipment and hardware, and software licenses.
At CWA, approximately 23% of the annual value of purchases were made using Public Services and Procurement Canada (PSPC) tools such as Standing Offers (SOs) and Supply Arrangements (SAs). An additional 7% of CWA’s contracts were awarded by PSPC on behalf of the department.
Since November 2021, PSPC implemented anti-forced labour clauses in all goods contracts to ensure that contracts could be terminated where there was credible information that the goods had been produced in whole or in part by forced labour or human trafficking. Additionally, since November 20, 2023, all PSPC SOs and SAs for goods that had been Issued, amended, or refreshed now include anti-forced labour clauses.
As such, all of CWA goods contracts resulting from the use of these tools include clauses relating to forced labour which set out, among other things, human rights, and labour rights requirements. These clauses can be found in the Policy Notification ID 150 – Anti-forced labour requirements.
In addition to the above, CWA awarded approximately $1.2 M in services contracts during the 2024-25 fiscal year, which is almost 70% of all its contracts. All the services contracts included references the Code of Conduct for Procurement as well clauses relating to forced labour and child labour.
- Producing goods (including manufacturing, extracting, growing, and processing)
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3. What steps has the government institution taken in 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?
In June 2023, CWA launched as a branch within Environment and Climate Change Canada (ECCC). The following year, legislation to establish CWA as a standalone agency received Royal Assent and came into force on October 15, 2024. As such, ECCC has been providing procurement services on behalf of CWA for the 24-25 fiscal year.
ECCC integrated PSPC’s General Conditions and PSPC’s Code of Conduct for Procurement into many of its purchasing activities. The Code of Conduct for Procurement identifies expectations and obligations that suppliers must meet when providing goods and services to Canada. This includes obligations in terms of human trafficking, forced labour and child labour. ECCC uses PSPC’s updated General Conditions and PSPC’s Code of Conduct for Procurement in its services contracts.
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4. Does the government institution currently have policies and due diligence processes in place related to forced labour and/or child labour?
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.
Pursuant to the amendments, ECCC has integrated the Code into CWA’s procurements for services with a view to safeguarding federal procurement from forced labour and child labour. The General Conditions applicable to the procurement of goods are presently being updated to also include reference to the Code.
The Code requires that vendors, providing goods and services to the Government of Canada and their sub-contractors, comply with all applicable laws and regulations. In addition, the Code 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.
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5. 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?
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.
CWA has identified the risks are extremely low to the best of our ability and will continue to strive to identify risks as they may occur.
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6. Has the government institution identified forced labour or child labour risks in its activities and supply chains related to any specific sectors and industries?
- No
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7. Has the government institution taken any measures to remediate any forced labour or child labour in its activities and supply chains?
This is not applicable as CWA has not identified any forced labour or child labour in its activities and supply chains.
The Parole Board of Canada (PBC) will be providing procurement and contracting management services to the CWA starting in the 25-26 Fiscal Year. The PBC will be supporting and enabling the broad management of procurement through the development and implementation of departmental policies and procedures.
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8. 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?
This is not currently applicable as CWA 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.
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9. Does the government institution currently provide training to employees on forced labour and/or child labour?
- No
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10. 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?
- No
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