On January 1, 2024, the Fighting Against Forced Labour and Child Labour in Supply Chains Act came into force.
The act orders any government institution producing, purchasing, or distributing goods and services 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.
The act’s reporting obligations also apply to entities producing goods in Canada or elsewhere or importing goods produced outside Canada.
The report below is for the Communications Security Establishment Canada (CSE) fiscal year 2024-2025 (April 1, 2024 to March 31, 2025).
On this page
- Structure, activities and supply chains
- Steps to prevent and reduce risks of forced labour and child labour
- Policies and due diligence processes
- Forced labour and child labour risks
- Assessment and risk management steps
- Remediation measures for forced and child labour
- Remediation measures for vulnerable families' income loss
- Training
- Assessing effectiveness
Structure, activities and supply chains
CSE is a federal agency that procures goods and services both domestically and internationally to support its operational and technical mandates.
CSE has incorporated the updated General Conditions for goods and services contracts and the Code of Conduct for Procurement from Public Services and Procurement Canada (PSPC) into its procurement activities. To address the risk of forced labour and child labour in our supply chain, CSE has leveraged several PSPC tools designed to enhance transparency and ethical procurement practices, including:
- Standing Offers (SO)
- Supply Arrangements (SA)
- Anti-forced labour contract clauses
While PSPC serves as the Government of Canada’s central purchasing agent, CSE also conducts procurement independently under its own authority, separate from PSPC-managed tools and frameworks.
In the previous fiscal year, CSE procured goods and services under its own authority, and continues monitoring procurement practices to ensure compliance with evolving PSPC and legislative standards.
Steps to prevent and reduce risks of forced labour and child labour
At CSE, approximately 2% of the annual value of our purchases were made using PSPC available tools, such as SOs and SAs. Additionally, 58% of our purchases were made through PSPC using other procurement channels, mostly for specialized IT procurement.
Since November 2021, PSPC has implemented anti-forced labour clauses in all goods and services contracts. These clauses ensure that PSPC could terminate contracts where credible evidence exists that goods and services were produced, in whole or in part, using forced labour or human trafficking. Furthermore, as of November 20, 2023, all PSPC SOs and Sas for goods and services issued, amended, or refreshed have incorporated these anti-forced labor clauses. These clauses can be found in Notification 150 - Anti-forced Labour Requirements.
For the 2024-2025 fiscal year, CSE purchased 29% of our annual value through Shared Services Canada (SSC) for IT equipment under available SSC methods of supply, such as non-specialized equipment and Commercial Off-The-Shelf (COTS) products. Additionally, 11% of our annual value was purchased under our own procurement authority.
In accordance with the act, CSE is continuing to assess, monitor, and report on any suppliers that may pose a risk regarding the use of forced labour and child labour. CSE, as an agency subject to the Financial Administration Act (except for the Canada Revenue Agency) and to commissions established under the Inquiries Act, is required to incorporate the Code of Conduct for Procurement (the code) into its procurement processes.
As per these amendments, CSE has integrated the code into all procurement activities, aiming to safeguard the federal procurement supply chain from forced labour and child labour. Contracts awarded by our organization include the code through the General Conditions for goods.
The code mandates that vendors supplying goods and services to the Government of Canada and their subcontractors, comply with all applicable laws and regulations. Additionally, the code requires that vendors and their subcontractors adhere to Canada’s prohibition on the importation of goods produced, either wholly or partially, by forced or compulsory labour. This includes both forced labour and child labour, and applies to all goods, regardless of their country of origin.
The prohibition on the importation of goods produced using forced labour came into force under the Customs Tariff on July 1, 2020. This amendment was implemented as part of Canada’s commitment in the Labour Chapter of the Canada-United States-Mexico Agreement (CUSMA) and applies to all imports, regardless of their origin.
Furthermore, in accordance with the act, CSE has been closely monitoring and reviewing our procurement processes to effectively mitigate risks related to forced labour and child labour. CSE continues to evaluate, refine, and strengthen its due diligence efforts to fully comply with the act’s requirements for assessing, preventing, and addressing forced and child labour in our supply chains.
Policies and due diligence processes
In May 2021, Rights Lab at the University of Nottingham (U.K.) completed a risk analysis of PSPC’s supply. The analysis determined which goods were at the highest risk of exposure to human trafficking, forced labour and child labour. The subsequent report outlined key strategies for PSPC to leverage public spending power to raise awareness of forced labour in supply chains. CSE noted the findings and recommendations of this risk analysis and are monitoring related follow-up actions. These include the implementation of the Policy on Ethical Procurement and the development of a human rights due diligence framework.
SSC is committed to ongoing risk identification, promoting and developing mitigation practices, and raising awareness within its procurement community while engaging with industry and strategic partners.
CSE recognizes the risks of forced labour and child labour within global supply chains. This is particularly relevant in electronics and IT equipment procurement, where upstream sourcing may involve regions with weaker labour protections or enforcement. While CSE currently does not have formal risk assessments or internal policies on these issues, steps are underway to align with federal efforts and enhance awareness.
Forced labour and child labour risks
CSE procures goods and services both domestically and internationally, including IT hardware and specialized equipment. These categories have been identified across government as carrying elevated risk for exposure to forced or child labour in upstream supply chains.
Assessment and risk management steps
- Third-party verification through the Canadian Centre for Cyber Security (Cyber Centre): CSE’s IT-related procurement requirements are supported by SSC and PSPC. These contracts are subject to Supply Chain Integrity (SCI) verification conducted by the the the Cyber Centre. This process reviews suppliers from a national security standpoint, including risks related to integrity and foreign interference. While not explicitly focused on labour violations, this process contributes to overall supply chain risk management.
- Use of PSPC and SSC procurement channels: CSE primarily relies on PSPC and SSC procurement tools, such as SOs and SAs, which include anti-forced labour clauses where applicable. However, CSE contracts issued under its own procurement authority do not yet include specific clauses addressing forced or child labour. These will be integrated once PSPC provides standardized contract language.
- Guidance and awareness: CSE has not yet developed a formal internal policy on forced or child labour but has issued internal guidance on the topic. In addition, CSE references these issues within its broader procurement training on social procurement, and an awareness one-pager is available internally to support staff in understanding the Government of Canada’s expectations.
- Planned improvements: CSE is monitoring PSPC’s release of standardized contract clauses and training materials to update procurement templates and internal practices accordingly. As guidance evolves, CSE will continue to assess opportunities to strengthen its due diligence framework.
Remediation measures for forced and child labour
Following our internal review and supply chain assessments during the reporting period, CSE did not identify any instances of forced labour or child labour in its procurement activities or supply chains. As such, no remediation measures were required, and this section is not applicable at this time.
CSE remains committed to ongoing monitoring and will implement appropriate remediation measures should any future concerns arise.
Remediation measures for vulnerable families' income loss
During the reporting period, CSE did not identify any instances of forced labour or child labour in its procurement activities or supply chains. As a result, no actions were taken that could have caused income loss for vulnerable families, and no remediation measures were required. This section is therefore not applicable at this time.
CSE will continue to monitor developments and ensure appropriate mitigation or remediation measures are considered should future actions result in such impacts.
Training
As of the latest reporting period, CSE does not provide specific training to employees on forced labour and child labour. However, CSE is aware that PSPC is currently developing awareness-raising guidance materials, including risk mitigation strategies, targeted towards high-risk sectors. CSE is monitoring the development of these materials and plans to leverage these resources into its internal training and awareness efforts once they become available.
Assessing effectiveness
CSE does not currently have formalized policies or procedures to assess the effectiveness of measures aimed at preventing forced labour and child labour in procurement. However, general guidance is included in procurement practices, and labour risks are referenced in internal training related to social procurement. CSE is actively monitoring PSPC’s development of standardized clauses, training materials and risk mitigation guidance for future integration into procurement templates and processes. In the interim, procurements conducted through PSPC and SSC benefit from established anti-forced labour measures and SCI reviews by the Cyber Centre.
CSE uses PSPC for 68% of goods and 23% of services, and SSC for 29% of goods and 32% of services of their purchases. Both PSPC and SSC are monitoring related follow-up actions, including the development of a Policy on Ethical Procurement.