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Reporting under the Fighting against forced labour and child labour in Supply Chains Act 2024 to 2025

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About this report

The Fighting Against Forced Labour and Child Labour in Supply Chains 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.

Consequently, Health Canada has created and submitted this annual report, for the fiscal year 2024 to 2025 (that is, from April 1, 2024 to March 31, 2025), to the Minister of Public Safety on the steps it has taken to prevent and reduce the risk that forced labour or child labour is used at any step of the production of goods, purchased or distributed by Health Canada.

As per section 8 of the Act, this report has been made available to the public, including by publishing it in a prominent place on Health Canada’s website. In addition, per section 22 of the Act, Health Canada’s annual reports will be held in an electronic registry on the Public Safety Canada (PSC) website that is accessible to the public.

More detailed information on the Act and reporting obligations can be found on PSC’s page on Forced Labour in Canadian Supply Chains.

About Health Canada

Health Canada is the federal department responsible for helping Canadians maintain and improve their health, while respecting individual choices and circumstances. In keeping with the Department’s commitment to making this country’s population among the healthiest in the world, Health Canada strives to:

Health Canada is part of the Health Portfolio, which includes the Public Health Agency of Canada (PHAC), Canadian Food Inspection Agency, Canadian Institutes of Health Research, and the Patented Medicine Prices Review Board.

While the provinces and territories are responsible for delivering healthcare to the majority of Canadians, the federal government also has a number of key roles and responsibilities in areas that affect health and healthcare. In addition to working closely with provincial and territorial governments, Health Canada also works with other federal departments and agencies, non-governmental organizations, other countries, Indigenous partners and the private sector.

From coast to coast to coast, Health Canada employees are working to help Canadians maintain and improve their health. This includes scientists and researchers, inspectors, doctors and nurses, policy analysts and administrative professionals, and many others.

Structure, activities and supply chains

Health Canada has a centralized approach to procurement, with the Procurement and Investment Management Directorate under the Chief Financial Officer Branch delivering centralized procurement and contracting services to Health Canada and the Public Health Agency of Canada to support and advance their respective mandates.

Procurement is governed by a robust management framework that supports effective program delivery and the achievement of best value with consideration of socio-economic, environment and Indigenous objectives. Oversight for the procurement function is provided through governance, defined roles and responsibilities and processes, systems and controls and reporting mechanisms to facilitate fair, open and transparent procurement activities.

Health Canada utilizes the following mechanisms and tools to purchase goods:

Goods that are frequently procured for the Department include, materials and supplies such as medical, laboratory, optical instruments and supplies, Information Technology (IT) and related equipment, and office furniture. Overall, the Departmental activities involve purchasing and distributing goods, both within and outside of Canada.

Steps to prevent and reduce the risk of forced or child labour

Since November 2021, PSPC and SSC implemented anti-forced labour clauses in all goods contracts to ensure that they can terminate contracts where there is credible information that the goods have been produced in whole or in part by forced labour or human trafficking. Additionally, since November 20, 2023, all PSPC and SSC Standing Offers and Supply Arrangements for goods that have been issued, amended, or refreshed include anti-forced labour clauses.

Health Canada is making active efforts to prevent and mitigate the risks associated with forced labour and child labour in its procurement processes. As such, all of our contracts for goods resulting from the use of PSPC and SSC’s tools include the aforementioned 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 150: Anti-forced labour requirements.

Furthermore, the Department has integrated PSPC’s Standard Contract Clauses including PSPC’s Code of Conduct for Procurement (the “Code”) in our purchasing activities. The Code outlines expectations and obligations for contractors and their subcontractors who respond to bid solicitations, and prohibits them from engaging in practices related to human trafficking, forced labour and child labour. 

Health Canada is aware that PSPC has developed awareness-raising guidance materials (including risk mitigation strategies) for suppliers, targeted towards high-risk sectors. The Department will leverage these materials to guide our suppliers and safeguard our supply chains from forced labour and child labour. Other initiatives taken by the Department include, but are not limited to:

Going forward, the Department is committed to building on its action plan initiatives to better understand key areas of risk of forced labour and child labour in our supply chains and implement measures to mitigate these practices.

Policies and due diligence processes

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 into their procurements.

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. This includes forced or compulsory child labour and applies to all goods, regardless of their country of origin.

Pursuant to the aforementioned amendments, Health Canada has integrated the Code into our procurements, with a view to safeguarding federal procurement supply chains from forced labour and child labour. Contracts that our organization has awarded included the Code through 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 on July 1, 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.

Activities and supply chains that carry a risk of forced labour or child labour

In May 2021, a risk analysis of PSPC’s supply chains was completed by the Rights Lab, of the University of Nottingham (United Kingdom), to determine which goods were at the highest risk of exposure to human trafficking, forced labour, and child labour. The analysis and the subsequent report, elaborated key strategies for PSPC to leverage public spending power to raise awareness about forced labour in supply chains.

The Department took note of the findings and recommendations of the risk analysis, and is monitoring related follow-up actions, including the implementation of the Policy on Ethical Procurement and the development of a human rights due diligence framework.

In addition, the findings of the risk analysis were also used as the foundation to initiate an internal analysis at Health Canada, via the annual investment and procurement planning exercise, to identify goods which are likely at risk of exposure to forced labour and child labour. Preliminary results indicate more analysis is needed to understand and identify our high-risk commodities, and the associated sectors and industries to mitigate the risk of forced labour and child labour in our activities and supply chains.

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

Measures taken to remediate any forced labour or child labour

Health Canada has not identified any instances where remediation of any forced labour or child labour was required, as no cases were identified in the fiscal year 2024 to 2025. As the Department continues on our research and analysis, guidance for remediation will be established as needed.

Measures taken to remediate loss of income

Health Canada has not identified any instances where remediation was required as no cases were identified in fiscal year 2024 to 2025. As work continues to identify, implement and advance measures to mitigate risks of forced or child labour, strategies to remediate the loss of income to the most vulnerable families affected by the measures will be explored as needed.

Training

Health Canada is aware that PSPC has developed and is currently piloting a course for procurement officers. The Department will leverage these resources upon their publication in support of a consistent government-wide strategy, and create in own supporting tools, policies and procedures as appropriate.

Additionally, Health Canada will continue to create awareness for its contracting authorities through information sessions and updates during regular team meetings. Earlier in 2025, PSPC and SSC’s Webinar on Forced Labour in the Electronic Supply Chains was added to Health Canada’s list of Procurement Learning resources. In addition, the contracting authorities were encouraged to participate in International Contracting Officers Forum on the topic of human trafficking in global supply chains, and what government procurement bodies are doing to help address this issue. The Department will continue to attend and participate in such sessions, as they become available.

Assessment of effectiveness

Health Canada’s initial priority is to identify and implement measures to ensure that forced labour and child labour are not being used in our contracts. In accordance with this priority, the Department has initiated some steps to prevent and reduce the risk of forced labour and child labour in its supply chains in the fiscal year 2024 to 2025. Once these initiatives are fully implemented, strategies will be explored to establish a monitoring and assessment framework.

Moving forward

In response to the Fighting Against Forced Labour and Child Labour in Supply Chains Act, Health Canada began research and analysis to mitigate the risk of forced labour and child labour in our activities and supply chains. Efforts will continue to advance the research and analysis of the contractors involved in supplying the specialized goods required by Health Canada, establish new and amend existing processes and procedures to mitigate the risks of these abhorrent practices, and create awareness in the contracting and business owner communities. Pertaining to the Act, the Department recognizes the responsibility to ensure that exploitive practices are addressed and eradicated from our supply chains. Health Canada remains committed to increasing awareness, conducting fair, open, and transparent procurement processes, and reviewing, amending and improving business practices as a whole.

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2025-05-30