Fighting against forced labour and child labour in Supply Chains Act 2025 to 2026

Introduction

Former Bill S-211, An Act to Enact the Fighting Against Forced Labour and Child Labour in Supply Chains Act and to amend the Customs Tariff (Supply Chain Act), received Royal Assent on May 11, 2023 and came into force on January 1, 2024.

The Supply Chains Act requires the head of every government institution whose activities include producing, purchasing or distributing goods in Canada, or elsewhere, must submit a report to the Minister of Public Safety by May 31 each year.

This report describes the measures implemented by Women and Gender Equality Canada to prevent or mitigate the risk that forced labour is used at any stage in the production process of goods purchased during the last fiscal year (April 1, 2025, to March 31, 2026).

Structure, activities and supply chains

Women and Gender Equality Canada structure

The Department for Women and Gender Equality (WAGE) advances gender equality for women, including social, economic, and political equality with respect to sex, sexual orientation, and gender identity or expression. The Department promotes a greater understanding of the intersection of sex and gender with other identity factors that include race, national and ethnic origin, Indigenous origin or identity, age, sexual orientation, socio-economic condition, place of residence and disability. The Department develops and coordinates policies and programs; and undertakes research and data collection and analyses related to these policies and programs; and raises public awareness through outreach. The Department provides advice to government to achieve Canada’s gender equality outcomes and goals, including advocacy for gender-based budgeting, and facilitates the advancement of gender equality among other partners and stakeholders, through its expertise, contribution to research and funding to community initiatives. The Department serves as a central point for sharing expertise across Canada and with international partners, and uses this knowledge to inform and support Canada’s gender equality priorities.

Part of the 2025-26 departmental plan, WAGE focused on the following five priority areas:

• promote and advance women and gender equality
• lead the systematic application of Gender-based Analysis Plus (GBA Plus) throughout the Government of Canada
• prevent and address gender-based violence (GBV)
• promote and advance 2SLGBTQI+ equality
• strengthen organizational well-being and enhance WAGE capacities

WAGE had a planned 444 full-time equivalents (FTEs) to support the department’s core responsibilities and internal services for 2025-26.

Procurement activities and supply chains

WAGE has integrated PSPC’s updated General Conditions for goods contracts and PSPC’s Code of Conduct for Procurement in our purchasing activities.

While PSPC supports government institutions in their daily operations by acting as the central purchasing agent for the Government of Canada, WAGE undertakes activities under its own procurement authority, independently of the aforementioned PSPC tools.

In 2025-26, WAGE awarded a total of $2,203,137 (before taxes) on contracts and amendments for goods and services, $488,310 (before taxes) were related to the following types of goods:
 

At WAGE, approximately 25% of the annual value of our purchases were made through the use of PSPC and SSC tools such as standing offers and supply arrangements.

Since November 2021, PSPC 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. 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 our contracts for goods resulting from the use of these tools include clauses relating to forced labour which set out human rights and labour rights requirements. These clauses can be found in the policy notification 150 – Anti-forced labour requirements.

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 of Conduct for Procurement (“the Code”) into their procurements.

Pursuant to the aforementioned amendments, WAGE has integrated the Code into its 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 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.

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.

Forced labour and child labour 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, identified key strategies for PSPC to leverage public spending power to raise awareness about forced labour in supply chains. We took note of the recommendations of this risk analysis, and are monitoring related follow-up actions, including the development and implementation of a human rights due diligence framework.

Following this analysis, it was identified that goods purchased in the following categories at WAGE pose a risk for forced labour and child labour:

• Office Supplies and Devices
• Alarm, Signal and Security Detection Systems

Measures taken to remediate any forced labour or child labour

Not applicable. WAGE has not identified any instances of forced labour or child labour in its activities or supply chains. By using established standing offers and supply arrangements, WAGE continues to rely on the processes and measures implemented by PSPC and SSC to address and remediate any instances of forced or child labour in the supply chain.

Measures taken to remediate the loss of income to the most vulnerable families

Not applicable; WAGE has not identified any loss of income to vulnerable families as a result of measures taken to eliminate the use of forced labour or child labour in its activities and supply chains.

Training provided to employees

WAGE Procurement Advisors and Officers participated in the Public Procurement Forum on human rights in Canadian supply chains in February 2026, which focused on combating human trafficking in government procurement practices.

PSPC has developed an online self-paced online 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 since November 2025. During the 2025 to 2026 fiscal year, two procurement officers from WAGE have completed this course. WAGE now requires that all procurement personnel take the course within one year of being appointed to their position.

Assessing effectiveness

WAGE does not currently have its own policies and procedures in place to assess the effectiveness of efforts to prevent the use of forced labour and child labour in its activities and supply chains. Instead, it will rely on the measures established by PSPC through their standing offers and supply arrangements.

WAGE will also coordinate and collaborate with PSPC and other stakeholder departments to ensure the adoption of best practices for internal implementation.

Government of Canada Resources

• Actions to Combat Human Trafficking
• Protecting human rights in federal procurement
• Trade agreements
• Code of Conduct for Procurement
• Canada’s Strategy on Responsible Business Conduct Abroad

International Standards and Tools

• United Nations Guiding Principles on Business and Human Rights
• Corporate Responsibility to Respect Human Rights interpretive guide
• OECD Guidelines for Multinational Enterprises on Responsible Business Conduct
• OECD Due Diligence Guidance for Responsible Business Conduct
• ILO Forced Labour Observatory
• Resources and tools for responsible business conduct
• Guidance by Government, Business and Civil Society
• ILO Indicators of Forced Labour
• Combatting Forced Labour: A Handbook for Employers and Business
• ILO-IOE child labour guidance tool for business: How to do business with respect for children's right to be free from child labour
• Ending child labour, forced labour and human trafficking in global supply chains
• Study of Supply Chain Risks related to Xinjiang forced labour
• Remediation Guidelines for Victims of Exploitation in Extended Mineral Supply Chains
• ISO 20400 – Sustainable procurement
• ISO 26000 – Social responsibility