2026 Annual Report under the Fighting Against Forced Labour and Child Labour in Supply Chains Act

PDF Version: 2026 Annual Report under the Fighting Against Forced Labour and Child Labour in Supply Chains Act (PDF, 0.5 MB)

As per its reporting obligations under the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Act), which came into force on January 1, 2024, Immigration, Refugees and Citizenship Canada (IRCC) has prepared its third annual report on forced labour in Canadian Supply Chains.

This document was submitted in parallel with the mandatory Questionnaire and, once finalized, will be available on IRCC’s website and in the Public Safety Canada Catalogue.

Submission information

Name of government institution
Immigration, Refugees and Citizenship Canada

Financial reporting year
April 1, 2025 to March 31, 2026

Indicate if this is a revised report
This is the original report.

Indicate if this is a report produced by a federal Crown corporation or a subsidiary of a federal Crown corporation
Not applicable

Annual report

Structure, activities and supply chains

Immigration, Refugees and Citizenship Canada (IRCC) is a Federal department that is responsible for the Citizenship Act, shares responsibility with Public Safety Canada for the Immigration and Refugee Protection Act and is also responsible for Passport Canada. IRCC’s procurement and contracting activities are guided by its mission to build a stronger Canada by:

• Developing and implementing policies, programs and services that:
  • facilitate the arrival of people and their integration into Canada in a way that maximizes their contribution to the country while protecting the health, safety and security of Canadians;
  • maintain Canada’s humanitarian tradition by protecting refugees and people in need of protection;
  • enhance the values and promote the rights and responsibilities of Canadian citizenship; and
  • reach out to all Canadians and foster increased intercultural understanding and an integrated society with equal opportunity for all, regardless of race, ethnicity and religion.
• Advancing global migration policies in a way that supports Canada’s immigration and humanitarian objectives.

IRCC’s procurement activities include, but are not limited to, the purchase, distribution and production of goods in and outside of Canada. During this reporting period, IRCC purchased goods for a total of $19,290,938.06, of which $3,352,076.96 was under its own procurement authority. The top three categories of goods purchased under IRCC’s own procurement authority, as identified through the Goods and Services Identification Numbers (GSIN), for the highest number of contracts and the highest aggregate contract value were:

• N7030 – ADP Software (39 contracts, aggregate value of $1,700,666.76)
• N7110 – Office Furniture (21 contracts, aggregate value of $1,061,422.95)
• N7025105 – Printers Ink Jet Colour (1 contract, aggregate value of $183,060.00)

At IRCC, approximately 20.6% of the annual value of IRCC’s goods purchases were made through the use of PSPC tools such as Standing Offers and Supply Arrangements.

Since November, 2021, PSPC implemented anti-forced labour clauses in all goods contracts to add a requirement for contractors to not deliver or sell goods to Canada manufactured wholly or in part by forced labour. The clauses ensure that Canada 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 Standing Offers and Supply Arrangements for goods that have been issued, amended, or refreshed include anti-forced labour clauses.

As such, all of IRCC’s contracts for goods 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.

At IRCC, approximately 7.5% of the annual value of IRCC’s goods purchases were made through the use of Shared Services Canada (SSC) tools such as Standing Offers and Supply Arrangements.

Since November 2021, SSC has implemented anti-forced labour clauses in all goods contracts to ensure that it 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. Furthermore, as of November 20, 2023, all SSC Standing Offers and Supply Arrangements that have been issued, amended, or refreshed include anti-forced labour clauses as part of the general conditions for goods.

As such, all IRCC contracts for goods resulting from the use of SSC’s tools include PSPC’s clauses relating to forced labour, which outline, among other things, human rights and labour rights requirements.

During this reporting period, IRCC purchased goods under its own procurement authority in the following categories (GSINs):

• N2310 – Passenger Motor Vehicles
• N3610BDD – Offset Equipment, Sheet Fed
• N4940 – Maintenance and Repair Shop Specialized Equipment, Miscellaneous
• N5836 – Video Recording and Reproduction Equipment
• N6350 – Alarm, Signal, and Security Detection Systems , Miscellaneous
• N6545B – First Aid Kit, General purpose
• N6675LP – Stereoscopes, Photographic Interpretation
• N6940 – Communication Training Devices
• N7025105 – Printers Ink Jet Colour
• N7025134 – Scanners, Document
• N7030 – ADP Software
• N7030165 – Computer Software, Building Construction, Facility/Property Management – Other than Microcomputers
• N7030535 – Computer Software, Human Resources Management, Personnel, Etc. – Other than Microcomputers
• N7045 – Computer Supplies
• N7110 – Office Furniture
• N7110C – Chair (Office)
• N7110CCJ – Chair, Rotary, Multi-task (Except SPEC.)
• N7110E – Desk
• N7125 – Cabinets, Lockers, Bins and Shelving
• N7195 – Miscellaneous Furniture and Fixtures
• N7195G – Plant, Decorative, Tropical
• N7490QC – Mailing Machine, Electric
• N7490T – Postage Meter
• N7510 – Office Supplies
• N7530 – Stationery and Record Forms
• N7540 – Standard Forms
• N8105 – Bags and Sacks
• N8455ACB – Badge, Identification, Laminated Plastic, with engraved lettering

Steps taken to prevent and reduce risks of forced labour and child labour

IRCC aligns all of its procurement practices with the Directive on the Management of Procurement and has integrated PSPC’s Standard Contract Clauses including PSPC’s Code of Conduct for Procurement and anti-forced labour clauses in its purchasing activities. IRCC also proactively updated its in-house General Terms and Conditions to include an Anti-Forced Labour Requirements clause so that all IRCC requirements, whether using PSPC or IRCC General Conditions, would include this clause. In addition, to prevent and reduce the risk of forced labour or child labour in its procurements, IRCC has used the following list of PSPC’s tools:

• Standing Offers
• Supply Arrangements
• Anti-forced labour contract clauses

During the 2025 to 2026 fiscal year, IRCC issued a department-wide communication to all IRCC employees to raise awareness on their role as Government of Canada employees in ethical procurement and combating forced labour and child labour in supply chains. This communication encouraged all IRCC employees to complete the new Canada School of Public Service course: Introduction to ethical procurement (CHC118) and provided a link to a Forced Labour in Canadian Supply Chains Resource Guide.

PSPC has developed awareness-raising guidance materials (including risk mitigation strategies) for suppliers, targeted towards high-risk sectors. The materials are progressively becoming available on the canada.ca website.

IRCC has used PSPC’s awareness materials to guide its suppliers and safeguard its supply chains from forced labour and child labour.

Furthermore, IRCC is referring its procurement personnel to these materials for awareness.

The April 1, 2023 amendments to the Treasury Board Directive on the Management of Procurement required contracting authorities to incorporate the Code of Conduct for Procurement (“the Code”) into their procurements. In compliance with these amendments, SSC has integrated the Code into its procurements. To prevent and reduce the risk of forced labour or child labour in our procurements through the General Conditions for goods.

IRCC has used the following list of SSC’s tools to which the Code applies:

• Standing Offers
• Supply Arrangements
• Contracts

As a common service provider, SSC is responsible for ensuring that government departments have access to reliable, secure, and cost-effective IT infrastructure and solutions, including shared services related to networks and network security, data centres and Cloud offerings, digital communications, and IT tools.

Policies and due diligence processes in relation to forced labour and 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.

The Code requires that vendors, providing goods 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, IRCC has continued to integrate the Code into its procurements, with a view to safeguarding federal procurement supply chains from forced labour and child labour. Contracts that IRCC 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.

Identifying parts of IRCC’s activities and supply chains that carry a risk of forced labour or child labour being used and the steps taken to assess and manage those risks

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, recommended key strategies for PSPC to leverage public spending power to raise awareness about forced labour in supply chains.

IRCC took note of the recommendations of this risk analysis, and is monitoring related follow-up action, including the development and implementation of a human rights due diligence framework.

SSC is 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

To date, IRCC has not been made aware or does not have any information supporting that any forced labour or child labour has occurred in its procurement activities or supply chains.

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 IRCC’s activities and supply chains

IRCC 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.

Training provided to employees on forced labour and child labour

During the 2025 to 2026 fiscal year, IRCC issued a department-wide communication to all IRCC employees to raise awareness on their role as Government of Canada employees in ethical procurement and combating forced labour and child labour in supply chains. This communication encouraged all IRCC employees to complete the new Canada School of Public Service course: Introduction to ethical procurement (CHC118) and provided a link to a Forced Labour in Canadian Supply Chains Resource Guide which contains information about:

• the Fighting Against Forced Labour and Child Labour in Supply Chains Act;
• the role of business owners as per the Directive on the Management of Procurement;
• Canada’s response (e.g., trade agreements, , Risk Analysis of Human Trafficking, Forced Labour and Child Labour in PSPC’s Procurement Supply Chains, Introduction to ethical procurement (CHC118), other Public Services and Procurement Canada and Public Safety Canada initiatives and resources);
• external resources (e.g., Organization for Economic Co-Operation and Development (OECD), International Labour Organization (ILO), and International Organization for Standardization (ISO) information and resources); and
• procurement tools (e.g., Standard Contract Clause Inventory, Requirements for the ethical procurement of apparel (PN-132), Code of Conduct for Procurement).

PSPC has developed an online self-paced course for procurement officers titled “Introduction to Ethical Procurement”. The course is available to federal public servants on the Canada School of Public Service’s learning platform as of November 2025. During the 2025 to 2026 fiscal year, 31 employees from IRCC have completed this course. In addition, IRCC requires that its procurement personnel take the course as part of their mandatory training.

Assessing effectiveness in ensuring that forced labour and child labour are not being used in activities and supply chains

IRCC is monitoring the development of guidance and resources from PSPC, including the development and implementation of a human rights due diligence framework, and will leverage these resources upon their release.