2024-25 Annual Report under the Fighting Against Forced Labour and Child Labour in Supply Chains

Part 1: Identifying information

• Privy Council Office
• April 1, 2024 to March 31, 2025

Part 2: Report contents

2.1 Information on the government institution’s structure, activities and supply chains

Description of the government institution’s activities

The Privy Council Office’s primary activities include the purchasing of goods and services within Canada.

Additional information on the government institution’s structure, activities and supply chains

The Privy Council Office’s (PCO) serves Canada by providing advice and support to the Prime Minister, portfolio ministers, and Cabinet. This includes supporting the development and implementation of the Government of Canada’s policy and legislative agendas, coordinating responses to issues facing the Government and the country, and supporting the effective operation of Cabinet.

During fiscal year 2024-25, PCO awarded 183 contracts for goods, including amendments valued at $9.4 million. Of this value, 131 contracts valued at $8.7 million, representing 92.0% of the value of PCO’s goods contracts were awarded under Public Services and Procurement Canada (PSPC) and Shared Services Canada (SSC) contracting authority or methods of supply, such as Standing Offers and Supply Arrangements.

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. In 2024-25, PCO also introduced PSPC’s anti-forced labour clauses into its own directed contracts. These clauses can be found in PSPC policy notification 150 – Anti-forced labour requirements.

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

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

To reduce the risk that forced labour or child labour is used at any step in its supply chains, the PCO has:

• Increased its use of methods of supply under Public Service and Procurement Canada (PSPC) and Shared Services Canada (SSC);
• Incorporated PSPC’s updated General Conditions, a set of standardized clauses including those specific to Anti-forced labour as well as PSPC’s Code of Conduct for Procurement into contracts awarded under its own authority, outside of PSPC and SSC methods of supply; and
• Continues to ensure all Procurement and Contracting Officers participate fully in all Anti-forced labour information and training sessions delivered by PSPC

During 2024-25, goods purchases made outside of PSPC and SSC methods of supply totaled $0.8 million and consisted of informatics equipment (53.3%), office supplies and miscellaneous manufactured articles (15.2%), Office equipment and furniture (9.9%), and other low dollar value purchases (11%).

2.3 Information on the 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 required 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 aforementioned amendments, the PCO integrated the Code into our procurements with a view to safeguarding federal procurement supply chains from forced labour and child labour. Contracts that the PCO awarded included the Code through the General Conditions for goods.

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

The prohibition on the importation of goods produced wholly or in part by forced labour came into force under 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.

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

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 PCO has familiarized itself with information on the risk assessment provided by PSPC, and continues to monitor information and policy updates as well as participate in information sessions led by PSPC.

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?

The PCO has reviewed the commodity codes of contracts awarded under its own delegation against the areas of top ten highest risk commodity types identified in the risk analysis report shared by PSPC and identified that of the $0.8 million awarded, none of the contracts fell in these categories. When expanded to include the additional commodity codes considered high risk based on volume, the value of contracts awarded directly by the PCO no further contract values were in scope. PCO will continue to utilize the methods of supply under PSPC and SSC and continue to engage with its partners on best practices for implementation going forward.

2.5 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

The PCO has not identified any vulnerable families who have lost income following its actions to eliminate the use of forced labour or child labour in its activities and supply chains. As such, no measures have been taken to establish grievance mechanisms or remediation measures.

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

PCO procurement officers participated in PSPC’s information session on Forced Labour in Supply Chains of the Electronics Industry in March 2024, and is committed to ensuring full participation as further information and training opportunities become available. The PCO will also leverage awareness-raising guidance materials made available by PSPC (including risk mitigation strategies) for suppliers towards high-risk sectors in communicating responsibilities across the department.

2.7 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

The PCO does not have its own policies and procedures to assess its effectiveness in ensuring that forced labour and child labour are not being used in its activities and supply chains where they fall outside of the tools establish by PSPC.