2025-26 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

2025-26 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 (PDF Version)

• Copyright

  © His Majesty the King in Right of Canada, as represented by the Minister of Housing and Infrastructure, 2026.

  Catalogue No. T91-14E-PDF
  

  ISSN 2818-386X

On this page

• Background
• Structure and activities
• Supply chain
• Steps to prevent and reduce the risk of forced labour or child labour
  • Steps taken to prevent forced labour
  • Policies and due diligence processes in relation to forced labour and child labour
  • Parts of its activities and supply chains that carry a risk of forced labour or child labour being used and the steps it has taken to assess and manage that risk
  • Training provided to employees on forced labour and child labour
• Next steps

Background

This report has been developed as a response to the reporting obligations under the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Act) came into force on January 1, 2024.

The Act stipulates that any government institution producing, purchasing or distributing goods in Canada or elsewhere must, on or before May 31 of each year, make a report publicly available on its measures to reduce forced labour and child labour.

The purpose of Bill S‑211 is to reduce the use of forced labour and child labour in supply chains by increasing transparency in these supply chains.

The 2025-2026 report covers the financial year beginning on April 1, 2025, and ending on March 31, 2026.

Structure and activities

The department of Housing, Infrastructure & Communities Canada (HICC) consists of policy, program, and internal services groups working from our headquarters in Ottawa and regional offices across the country. HICC is led by our Deputy Minister and serves the Minister of Housing and Infrastructure, who is also responsible for Pacific Economic Development Canada.

The mission of HICC is to help communities thrive by making public infrastructure more sustainable, inclusive, and climate resilient, and housing more available and affordable. HICC works to build sustainable, inclusive, and climate‑resilient communities by investing in affordable housing, modern transit, resilient infrastructure, clean water, and accessible cultural spaces.

To achieve its mandate, the department invests in inclusive housing and infrastructure, works collaboratively with Indigenous partners, governments and the private sector to deliver major projects, and supports climate‑ready investments, research, and long‑term planning to build resilient, low‑carbon communities. In fiscal year 2025-26, the department had a total of 1,730 Full-Time Equivalents (FTEs) employees and had a total authority of $9,116.6 Million (figure 1).

The management of the supply chain and the procurement of goods related to HICC’s funding envelope is fairly limited from a departmental standpoint given that the vast majority of the funding is tied to Grants and Contributions (95%) for which HICC’s stakeholders are responsible for the management of the supply chain and procurement of goods. HICC has a total operating envelope of $413,2M of which $3.0M was for the purchases of goods done under its own authority and was predominantly tied to office supplies and furniture as well as information management and information technology to support the 1,730 HICC FTEs.

Supply chain

In fiscal year 2025-26 HICC signed a total of $3.0M worth of goods contracts primarily tied to the purchasing of computers, monitors, office furniture and an executive vehicle. All contracts—except three totalling $183K (7% of total purchasing), were purchased through Government of Canada-wide standing offer or supply arrangements managed by Public Services and Procurement Canada (PSPC) (Figure 2). These standing offers or supply arrangements enable potential suppliers to provide goods and/or services at pre-arranged prices, in accordance with established terms and conditions that include PSPC’s anti-forced labour provisions.

In addition to the contracts noted above, the department also procured a range of goods through departmental acquisition cards (up to a maximum of $10,000 per transaction). These purchases included office supplies, ergonomic equipment, and specialized IT equipment. While PSPC standing offers remain the preferred procurement vehicle, and the department prioritizes purchases from pre‑qualified, on‑tool suppliers where available, acquisition cardholders may procure goods through other authorized means when necessary.

Steps to prevent and reduce the risk of forced labour or child labour

Steps taken to prevent forced labour

HICC has integrated PSPC’s Standard Contract Clauses, including the Code of Conduct for Procurement and anti‑forced labour clauses, into its purchasing activities. Since November 2021, PSPC has implemented anti‑forced labour clauses in all goods contracts to ensure that contracts may be terminated where there is credible information that goods have been produced, in whole or in part, by forced labour or human trafficking. In addition, since November 20, 2023, all PSPC standing offers and supply arrangements for goods that are issued, amended, or refreshed include anti‑forced labour clauses. As a result, all HICC contracts for goods awarded through these PSPC tools include clauses addressing forced labour, human rights, and labour rights requirements, as set out in Policy Notification‑150 – Anti‑forced labour requirements.

To prevent and reduce the risk of forced labour or child labour in its procurements, HICC primarily relied on PSPC procurement tools, including standing offers, supply arrangements, and associated anti‑forced labour contract clauses. During the 2025–26 fiscal year, almost 94% of the total value of departmental goods purchases was made using these tools, which include established due‑diligence and risk‑mitigation mechanisms.

The remaining approximately $183K in goods contracts awarded outside of standing offers were limited in number and nature and were issued to established Government of Canada suppliers listed on CanadaBuys. In these instances, the specific goods required were not available through active standing offers at the time of purchase. The suppliers involved are reputable vendors with a demonstrated history of federal procurement, and the types of goods procured—primarily information technology equipment and office furniture—are considered to present a low inherent risk of forced labour or child labour. As such, HICC’s overall supply‑chain risk profile remains low and well managed.

In addition, PSPC has developed awareness‑raising guidance materials, including risk‑mitigation strategies for suppliers in higher‑risk sectors, which are progressively becoming available on the Canada.ca website. HICC continues to monitor the release of new and updated PSPC guidance and refers its procurement personnel to these materials for awareness. Where applicable, this guidance is also used to inform procurement decision‑making, acquisition card usage practices, and engagement with suppliers, further supporting efforts to safeguard supply chains from forced labour and child labour.

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

From a government-wide perspective, 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, HICC has continued to integrate the Code into our 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 subcontractors, comply with all applicable laws and regulations. In addition, the Code requires vendors and their subcontractors 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 Chapterof the Canada-United States-Mexico Agreement (CUSMA) and applies to all imports, regardless of origin.

Parts of its activities and supply chains that carry a risk of forced labour or child labour being used and the steps it has 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.

Though HICC does not procure a large amount of goods, the largest risk to HICC’s supply chain is related to the manufacturing of goods. HICC’s purchases are primarily linked to informatic equipment and office goods for which the department does recommend using the PSPC standing offers or supply arrangements but that decision remains at the manager's discretion.

We have familiarized ourselves with information on the risk assessment provided by PSPC, and are monitoring related follow actions, including the continued implementation of a human rights due diligence framework.

Training provided to employees on forced labour and child labour

During the 2025–26 fiscal year, HICC continued to provide awareness‑raising and guidance to employees involved in procurement and acquisition card usage, including ongoing training and updates on appropriate vendor selection, the use of Government of Canada standing offers, and supply‑chain risk considerations. While no employees completed the Canada School of Public Service (CSPS) course Introduction to Ethical Procurement during the reporting period, the department has included this training in its 2026–27 Procurement Training Plan and now recommends that all members of the Procurement Services team complete the course. In addition, the department continues to monitor new and updated guidance from PSPC and will incorporate relevant materials and best practices into its procurement and acquisition card training as they become available.

Next steps

HICC remains attentive to updated guidance on best practices regarding purchases of various information technology and information management and other goods, and for any additional resources made available to minimize procurement risks. As mentioned in the report, HICC’s procurement of goods is low risk with the majority of its purchases using pre-existing tools that already have a framework around mitigation measures to forced labour built around it. However, HICC acknowledges that there is always room for continuous improvement and an opportunity to de-risk purchases and will continue to leverage awareness and training.