Shared Services Canada – 2026 Annual Report under the Fighting Against Forced Labour and Child Labour in Supply Chains Act

Introduction

Forced labour is a global issue that affects many industries, including public procurement. Several countries, including Canada, have enacted laws to help prevent the importation of goods that may have been produced using forced labour or child labour. The Government of Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act (Supply Chains Act) came into force on January 1, 2024, and requires all departments of the federal government listed on Schedule 1 of the Financial Administration Act to file an annual public report to the Minister of Public Safety. The report must detail the steps the government institution has taken during its previous fiscal 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.

As the main provider of information technology (IT) services to the Government of Canada, Shared Services Canada (SSC) primarily procures information and communication technology products, including electronic goods, which have been identified as having problematic product lines. In recent fiscal years, SSC collaborated with Public Services and Procurement Canada (PSPC) and a non-governmental organization (NGO) to assess and manage the risks of forced labour and child labour in its electronics supply chains, to be better informed and equipped with measures to prevent and reduce these risks.

During the 2025-2026 fiscal year, SSC continued to make progress in addressing its requirements under the Supply Chains Act. SSC actively supported interdepartmental initiatives through participation in and promotion of training and learning opportunities. These included engagement sessions and forums with suppliers, government departments, and expert NGOs centred on addressing forced labour and child labour in Canadian supply chains.

Additionally, SSC continued to implement measures, such as anti-forced labour clauses in contracts with suppliers for goods, to manage the risk that forced labour or child labour is being used at any step of the production of the electronic goods it purchases and distributes.

Part I: Departmental Background Information

1.1 – Identifying information

This report is submitted by SSC and outlines the steps SSC has taken between April 1, 2025, and March 31, 2026, to prevent and reduce the risk of forced labour and child labour in its supply chains. As a department of the federal government listed in Schedule 1 of the Financial Administration Act, SSC is required under the Supply Chains Act to report annually to the Minister of Public Safety, by May 31st, on the supply chains for the goods it purchases and distributes.

1.2 – Departmental structure, activities, and supply chains

SSC was created in 2011 with the mandate to modernize the Government’s IT infrastructure. This mandate was reinforced in 2012 through the passage of the Shared Services Canada Act. As a common service provider, SSC purchases and distributes IT goods and services for over 140 federal organizations. SSC’s core mandate includes the provision of shared services related to email, data centres, networks, and end-user IT services.

SSC’s procurement activities ensure that government departments have access to reliable, secure, and cost-effective IT infrastructure and solutions, in support of IT operations across the Government of Canada. SSC’s procurement operations follow a strategic sourcing and procurement plan through the centralization of contract administration and the acquisition of IT goods and other IT-related services. With careful attention to the overall planning and procurement strategy, and supporting technology, SSC effectively manages long-term partnerships and ensures that supplied goods are of high quality, are procured at the best value, and are provided in a timely fashion.

The mandate of the department was further consolidated by the Order-in-Council (OIC) 2015-1071 on September 1, 2015. OIC 2015-1071 restated SSC’s mandate to provide a full range of shared information management and information technology services to its mandatory partner departments (those listed in Schedule I, I.1 or II of the Financial Administration Act), and a subset of those services to all other Government of Canada departments and agencies. In meeting its mandate, SSC ensures compliance with the requirements of the Policy on the Planning and Management of Investments, the Policy on Service and Digital, the Directive on the Management of Procurement and all other pertinent Acts and regulations.

Between April 1, 2025 and March 31, 2026, SSC funded and awarded 828 contracts for goods valued at $1.5B. SSC also awarded 3,738 contracts for goods valued at $1.0B funded by other government departments (OGDs). A further breakdown of these contracts is displayed in the tables below.

Guided by the Supply Chains Act, SSC strives to support efforts to increase the visibility of supply chains for goods purchased under its delegated authority, contributing to the prevention and reduction of risks related to forced or child labour.

Part II: Measures taken to prevent and reduce the risk of forced labour or child labour

2.1 – Preventing and reducing the risk of forced labour or child labour in SSC procurements, and remediation of loss of income

Effective April 1, 2023, amendments to the Treasury Board Directive on the Management of Procurement require contracting authorities from departments listed in Schedules I, I.1 and II 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, including child labour.

The prohibition on the importation of goods produced wholly or in part by forced labour came into force via an amendment to the Customs Tariff on July 1, 2020. This amendment implemented a commitment regarding the prohibition of forced labour in the Labour Chapter of the Canada-United States-Mexico Agreement (CUSMA) and applies to all imports, regardless of the origin of goods.

Pursuant to the Directive on the Management of Procurement, SSC has continued integrating the Code into its procurements during the 2025-2026 fiscal year, with a view of safeguarding federal procurement supply chains from forced labour and child labour, and has continued to incorporate PSPC’s anti-forced labour clauses into its contracts, Standing Offers and Supply Arrangements. The clauses allow SSC to terminate a contract and suspend or cancel a standing offer or supply arrangement where there is credible information that goods have been produced in whole or in part by forced labour or human trafficking.

In 2024, SSC expanded its use of anti-forced labour contract clauses, which were originally applicable only to goods, to include additional procurement categories subject to the Code of Conduct for Procurement including Services and Professional Services. SSC issued an “Anti-Forced Labour Requirements” procurement information notice to inform its procurement officers of the mandatory inclusion of these clauses in new and amended procurement contracts and the notice continues to be available for reference.

In fiscal year 2025-2026, SSC also continued to implement the revised and expanded Ineligibility and Suspension Policy in line with guidance provided by PSPC’s Office of Supplier Integrity and Compliance. The main purpose of the Policy is to protect the integrity of federal procurements by ensuring that the Government of Canada only does business with ethical, law‑abiding suppliers.

In February 2026, SSC signed a renewed Memorandum of Understanding with PSPC for Integrity Verification Services and the referral of cases of supplier misconduct. SSC applies the Ineligibility and Suspension Policy by:

• including the Ineligibility and Suspension Policy clauses in all applicable contracts and procurement processes
• verifying with PSPC’s Office of Supplier Integrity and Compliance to confirm that a supplier is not ineligible or suspended prior to entering into a contract
• referring cases of founded supplier misconduct to PSPC

2.2 – Assessment and management of risk

In 2021, PSPC engaged the University of Nottingham’s Rights Lab to conduct a risk analysis of human trafficking, forced labour, and child labour across its departmental supply chains. The analysis identified electrical and electronic equipment components as among the Goods and Services Identification Number codes presenting the highest risk. Furthermore, an analysis and subsequent report elaborated key strategies for PSPC to leverage public spending power to raise awareness about forced labour in supply chains.

With a focus on interdepartmental collaboration to promote ethical procurement and a whole-of-government approach aligned with the National Strategy to Combat Human Trafficking, SSC joined PSPC in the 2024–2025 fiscal year to conduct a risk assessment of SSC and PSPC’s supply chains specific to electronics goods. SSC engaged Electronics Watch, an expert NGO, to assess the risks linked to IT products within SSC’s supply chains – such as computers, notebooks, tablets, smartphones, and other devices. The assessment identified risks based on production locations and supply chain tiers and informed the development of a supplier engagement plan and model contract clauses. Electronics Watch also provided guidance on challenges and mitigation best practices, enhancing SSC’s understanding of the complexities and exposure to forced labour and human rights risks in electronics supply chains.

Building on this foundational work jointly undertaken by SSC and PSPC, the risk assessment report was finalized and published in October 2025. This work strengthened SSC’s capacity to assess and manage risks related to forced labour, child labour, and human trafficking.

As part of continued risk assessment efforts, in fiscal year 2025-2026, SSC conducted an analysis of supplier participation and reporting compliance for requirements under the Supply Chains Act. The Act requires applicable suppliers to submit an annual report to the Minister of Public Safety, outlining the measures that suppliers have taken during the previous financial year to prevent and reduce the risk that forced labour or child labour might be involved at any stage of the production of goods in Canada or abroad, or in goods imported into Canada.

In this analysis, SSC examined submission data from Public Safety Canada’s publicly accessible Catalogue of Reports for the 2024–2025 fiscal year. The results indicate that approximately 16% of SSC’s suppliers who were awarded contracts for the provision of goods in fiscal year 2024–2025 submitted reports under the Supply Chains Act to Public Safety Canada in 2025. These suppliers accounted for 433 goods contracts, representing approximately 37% of SSC’s 2024-2025 contract award volume for goods. With a combined contract value of over $127 million, this also represents an estimated 15% of the total value of all SSC-funded goods contracts awarded in fiscal year 2024-2025. This data provides SSC with a baseline for assessing the transparency of the supply chains of suppliers awarded contracts by the department for electronic goods.

Finally, in fiscal year 2025–2026, SSC contributed to PSPC-led research and the development of risk management practices to support organizations in identifying, preventing, mitigating, and accounting for adverse human rights impacts linked to their operations, products, and services; these practices are currently informing the development of enhanced measures under a PSPC Human Rights Due Diligence framework.

2.3 – Interdepartmental engagement

In fiscal year 2025-2026, SSC participated in several interdepartmental initiatives related to protecting human rights in federal procurement. Building on the momentum from the International Contracting Officers Forum hosted by PSPC in February 2025, in collaboration with the Steering Committee for the Principles to Guide Government Action to Combat Human Trafficking in Global Supply Chains, SSC attended the Public Procurement Forum on Human Rights in Canadian Supply Chains in February 2026. Attendees learned about initiatives undertaken across various public organizations to address the risks of forced labour in supply chains. The forum featured presentations from the Government of Canada, McGill University, and the Swedish National Secretariat for Sustainable Public Procurement.

In February 2026, SSC took part in and promoted the PSPC-hosted webinar, “Managing Forced and Child Labour Risks in Canadian Supply Chains”. SSC issued a notification to all SSC suppliers via the departmental electronic procurement system, increasing visibility of the event for the supplier community. The webinar offered insights into best practices for preventing, detecting, and addressing risks of forced and child labour, drawing on the research and practical experience of ReStructure Lab (an initiative aimed at combating forced labour, modern slavery, and human trafficking globally), while raising awareness of this issue among SSC suppliers, including small and medium-sized enterprises.

In March 2026, SSC representatives attended an exhibition entitled “Through Their Eyes: Visions of Forced Labour”, hosted by Public Safety Canada and organized by the United Nations’ International Labour Organization and the NGO, Human Resources Without Borders. The exhibition showcased powerful illustrations to raise awareness of and inspire action against forced labour globally. It also included an expert panel discussion on the global economy of forced labour, the ways that Canada and Canadians are exposed to it, and measures for combating forced labour. The exhibition shed light on the human stories behind forced labour and drew attention to how the Supply Chains Act, along with broader Government of Canada efforts, are addressing forced labour in Canadian supply chains.

2.4 – Measures taken to remediate any forced labour or child labour

The conditions imposed by corporations on workers and their families and communities in underdeveloped countries have received heightened attention in recent years. Based on updates made to the Code of Conduct for Procurement in May 2023 to include clauses that uphold international human and labour rights for all goods and services purchased by the Government of Canada, SSC began incorporating these updated clauses into its procurements.

During the 2025-2026 fiscal year, SSC 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. As such, no measures have been taken to remediate the loss of income for the most vulnerable families.

Nonetheless, SSC has continued to demonstrate efforts to engage with suppliers and ensure that SSC procurement officers are informed of any newly developed frameworks that will impact procurement processes and remediation mechanisms, such as expanded due diligence measures developed by other government departments in collaboration with SSC.

2.5 – Training provided to employees on forced labour and child labour

In the 2025-2026 fiscal year, SSC continued to improve training and expand learning opportunities about fair labour practices, sustainability, and the ethical treatment of suppliers and workers.

SSC contributed to the review of the Introduction to Ethical Procurement course on the Canada School of Public Service platform. SSC supported the review of course materials, contributed to content development, and assisted in revising the course for delivery as a government-wide training resource for procurement professionals and other employees interested in learning about ethical procurement.

The course was launched in November 2025, and introduces the concept of ethical procurement, outlines risks of forced labour in public procurement, and provides an overview of annual reporting obligations for federal institutions under the Supply Chains Act.

Following its launch, SSC promoted the course through internal communications channels, including a training and development bulletin issued to SSC procurement officers. SSC will continue to encourage uptake of the course in the coming year.

In 2026, SSC also continued its information-sharing efforts and promotion of various learning opportunities. SSC issued notices through internal communications channels to promote initiatives, events, and forums hosted by other government entities, including:

• the Public Procurement Forum on Human Rights in Canadian Supply Chains for international public organizations to share best practices and lessons learned, held in February 2026
• the webinar on managing forced and child labour risks in Canadian supply chains, including mitigation strategies for suppliers, held in February 2026
• the exhibition for federal government employees and the public, highlighting the human impacts of forced labour and designed to raise awareness and encourage action, held in March 2026

Finally, when conducting procurements, SSC procurement officers have continued to be advised to refer to SSC’s “Anti-Forced Labour Requirements” procurement information notice, which outlines the anti-forced labour requirements and the associated contracting clauses to be incorporated into SSC procurements.

2.6 – Assessing effectiveness of ethical procurement measures

During the 2025-2026 fiscal year, SSC assessed the effectiveness of ethical procurement measures by advancing risk assessment initiatives of departmental electronic goods supply chains and expanding the departmental Compliance and Quality Assurance Program to include an ethical procurement validation process at various stages of the procurement process.

The risk assessment of SSC’s electronics goods supply chains (focusing on computers, notebooks, tablets, smartphones, and other IT devices) completed in 2025, in partnership with PSPC and Electronics Watch, allowed SSC to identify and understand the evolving risks in departmental supply chains. The risk assessment highlighted the importance of using anti-forced labour contract clauses, conducting awareness-raising sessions with suppliers and procurement officers, and refining due diligence measures within SSC supply chains. The 2026-2027 fiscal year presents an opportunity for SSC to further advance due diligence efforts internally and in collaboration with PSPC.

In the 2025-2026 fiscal year, SSC began monitoring the inclusion of mandatory anti-forced labour contract clauses in SSC procurements via SSC’s Compliance and Quality Assurance Program. The program’s pre-solicitation reviews and post-contract award audits are used to assess procurement strategies and related documentation to ensure compliance with applicable laws, regulations, and government policies. The program checklists were expanded to verify the inclusion of anti-forced labour clauses in SSC procurements, which allows SSC to monitor and enforce required clause implementation and identify and address any gaps.

Furthermore, through the initiative to review SSC suppliers’ fulfillment of reporting obligations under the Supply Chains Act in the 2024-2025 fiscal year, SSC has taken preliminary steps to assess the transparency of contracted suppliers’ supply chains, which form a part of SSC’s supply chains. SSC plans to continue advancing its understanding of its supply chains through the analysis of supplier reports on Public Safety Canada’s publicly accessible Catalogue of Reports in the coming year.

Conclusion

The 2025–2026 fiscal year signified continued efforts to prevent and reduce risks of forced labour, child labour, and human trafficking in SSC’s procurement supply chains. SSC increased access to information on ethical procurement practices for procurement officers and suppliers through diverse learning and engagement opportunities aimed at developing both practical and theoretical knowledge in this area.

The anti-forced labour clauses introduced in prior fiscal years continued to be implemented during the 2025–2026 fiscal year in new or amended contracts, as well as in new or refreshed standing offers and supply arrangements. These clauses were also applied to contracts for services and professional services within the scope of services to which the Code of Conduct for Procurement applies.

Having accessed awareness-raising materials from expert NGOs, academic institutions, and other government departments, and advanced departmental risk assessment measures, SSC has entered the 2026–2027 fiscal year from an informed position. Whether by leveraging future policies and due diligence processes or through further engagement with its internal and external stakeholders, SSC remains committed to the protection of human rights in its electronics goods supply chains.