Annual Report on the Application of the Fighting Against Forced Labour and Child Labour in the Supply Chains Act, 2025-2026
About this report
The Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Act) came into force on January 1, 2024, imposing reporting obligations on government institutions producing, purchasing or distributing goods in Canada or elsewhere. The Act also requires the report be made available to the public.
Forced labour can be found in every country and all economic sectors. The International Labour Organization has estimated that approximately 27.6 million victims of forced labour exist worldwide. It is rooted in poverty, discrimination and lack of social protection. It also disrupts fair competition between businesses.
The Canadian Centre for Occupational Health and Safety (CCOHS) is providing its second annual report, covering the period April 1, 2025, to March 31, 2026, pursuant to the Act.
About the Canadian Centre for Occupational Health and Safety (CCOHS)
CCOHS is a federal departmental corporation that serves Canadians with credible and relevant tools and resources to improve workplace health and safety. We believe that all Canadians have a fundamental right to a healthy and safe working environment. Through our programs, services, knowledge, commitment and action, CCOHS continues its efforts to advance health and safety in the workplace.
CCOHS procurement activities relate to the purchasing and distributing of goods within Canada. Specifically, the purchasing of goods is primarily related to internal business operations. The majority of purchases include IT software and hardware for business operations (e.g., Microsoft products, cloud services, laptops, tablets, monitors, keyboards and other peripheral IT equipment).
In addition, CCOHS distributes publication materials across Canada in the form of physical and digital assets. Physical assets are developed internally and printed and shipped using local print and logistics vendors in Ontario.
Structure, activities and Supply Chains
CCOHS annual expenditures on goods for 2025-26 were approximately $95,000. Of this amount, IT hardware accounted for roughly 61%, while printed materials represented approximately 25%.
CCOHS relies on Public Services and Procurement Canada (PSPC) and shared Services Canada (SSC) to procure goods through established procurement instruments, including standing offers and supply arrangements. Leveraging these instruments enables CCOHS to rely on the due diligence embedded in federal procurement processes, including requirements for suppliers to adhere to the Government of Canada’s Code of Conduct for Procurement and related obligations under the Act.
Steps to prevent and reduce the risk of forced or child labour
Given the recent coming into force date of the Act, CCOHS does not yet have formal policies and due diligence processes specifically addressing forced labour and/or child labour, but is currently reviewing and updating its internal policies accordingly.
In light of CCOHS’s limited procurement of goods (less than $100,000 annually) and its reliance on Public Services and Procurement Canada (PSPC) and Shared Services Canada (SSC) procurement instruments (such as standing offers and supply arrangements) which incorporate federal due diligence and supplier compliance requirements, the risk of forced labour and child labour in its supply chains is considered minimal. No measures were required to remediate forced labour or child labour, as CCOHS has not identified any instances of forced labour or child labour within its activities or supply chains.
No measures were necessary to remediate loss of income to vulnerable families, as CCOHS has not identified any such impacts arising from measures taken to prevent or eliminate forced labour or child labour in its activities or supply chains.
Policies and processes
CCOHS relies on PSPC and SSC efforts for the majority of CCOHS procurement activities across the organization.
PSPC includes 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. As well, Standing Offers and Supply Arrangements for goods requires suppliers to comply with international labour standards which prohibit forced and child labour.
PSPC General Conditions clauses are included in solicitation and contractual documents integrating the PSPC Code of Conduct for Procurement (the "Code"). The Code outlines expectations and obligations for contractors and their subcontractors who respond to bid solicitations and prohibits them from engaging in practices related to human trafficking, forced labour and child labour. CCOHS is reviewing relevant clauses for on-going contracts to include warrants in the fight against forced labour and child labour.
CCOHS does not currently have policies and procedures in place to assess its effectiveness in ensuring that forced labour and child labour are not being used in its supply chains.
Training
CCOHS does not currently provide formal training to employees on forced labour and/or child labour. Given the limited number of personnel involved in procurement and the centralized oversight of all purchasing activities by the procurement function, which is aware of the Act’s requirements, CCOHS plans to incorporate relevant information about the Act into training and awareness materials for procurement personnel in 2026–27.
Moving forward
Going forward, CCOHS is committed to exploring provincial, territorial and international government best practices to better understand key areas of risk of forced labour and child labour in our supply chains and implement processes to mitigate these practices. CCOHS recognizes the responsibility to ensure that the use of forced labour and child labour practices are eliminated from our supply chains
