Agriculture and Agri-Food Canada 2025 annual report — Fighting Against Forced Labour and Child Labour in Supply Chains Act

2025 fiscal year

The Fighting Against Forced Labour and Child Labour in Supply Chains Act (Act) came into force on January 1, 2024.

Throughout the 2025 fiscal year, Agriculture and Agri-Food Canada (AAFC) has taken the steps identified in this report to prevent and reduce the risk that forced labour or child labour is present in our supply chain.

Structure, activities and supply chains

AAFC provides leadership in the growth and development of a competitive, innovative and sustainable Canadian agriculture and agri-food sector. The department supports the sector from the farmer to the consumer, from the farm to global markets, through all phases of producing, processing and marketing of farm, food and bio-based products. Agriculture is also a shared jurisdiction in Canada, and the department works closely with provincial and territorial governments in the development and delivery of policies and programs.

AAFC employs approximately 5,000 employees and is organized into 8 different branches. AAFC has research and development centres in all 10 provinces as well as regional offices.

AAFC's 3 core responsibilities, Domestic and International Markets, Science and Innovation, and Sector Risk, represent the enduring functions of the department's mandate. AAFC is involved in the growing of crops within Canada (including manufacturing, extracting, growing and processing), purchasing goods domestically and internationally (for example United States, United Kingdom, Denmark), as well as distributing goods in Canada. The tables below provide departmental procurement activity data for fiscal year 2024–25.

Furthermore, AAFC and the Canadian Food Inspection Agency (CFIA) combine their expertise to implement sector trade priorities, as follows:

• regulatory and technical import-export functions (CFIA only)
• market access, advocacy and trade policy (AAFC and CFIA)
• market development and diversification (AAFC only)
• engagement with stakeholders in Canada and abroad (AAFC and CFIA).

In fiscal year 2024–25, International Affairs Branch (IAB), one of AAFC's Branches purchased promotional materials (in Canada) for use at international and domestic tradeshows and the Indo-Pacific Agriculture and Agri-Food Office (IPAAO) in the Philippines. These include banners, service cards and brochures. Additionally, funding was provided through the Agriculture and Food Trade Commissioner Service fund for the purchase of eligible job-related supplies (outside of Canada) for the new IPAAO. This included promotional materials and services such as electronics (for example, monitors, iPads), banners, shirts, and the delivery of a series of workshops in partnership with the Canada-Association of Southeast Asian Nations Business Council (CABC).

AAFC has integrated Public Service and Procurement Canada's (PSPC) General Conditions for goods contracts and the Code of Conduct for Procurement into its purchasing activities. To help prevent and reduce the risk of forced labour or child labour in its procurements, AAFC also uses the following PSPC tools:

• standing offers
• supply arrangements
• anti-forced labour contract clauses

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

In fiscal year 2024–25, AAFC's Corporate Management Branch implemented a new Procurement File Checklist as part of its efforts to strengthen procurement oversight and compliance. This tool was put into effect by integrating it into existing procurement processes, procedures and guidance documents. It was also actively promoted to the procurement community through targeted communications, including training sessions, and updates to internal resources. This checklist is designed to support the act by ensuring that suppliers are verified against the Government-wide Integrity Regime, managed by PSPC. This verification process alerts federal departments when a supplier has been deemed ineligible to do business with the Government of Canada, due to conviction related to forced or child labour.

At AAFC, approximately 28% of the annual value of our goods purchases were made through the use of PSPC tools such as standing offers and supply arrangements. This percentage does not include transactions via departmental acquisition card.

Since its introduction in November 2021, PSPC's anti-forced labour clause, originally applicable only to goods, has been expanded to cover all commodity types. This clause allows Canada to terminate contracts where there is credible information that goods have been produced in whole or in part by forced labour or human trafficking. Additionally, since November 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 AAFC contracts for goods resulting from the use of these tools include clauses relating to forced labour which set out, among other things, human rights and labour rights requirements.

Policies and due diligence process

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.

Our department has integrated the Code into our procurement processes, 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.

Additionally, AAFC's due diligence includes the use of a procurement file checklist, which documents the validation process against the Integrity Verification Services (IVS) program managed by PSPC. The IVS program notifies federal departments if companies have been identified as having issues including forced and/or child labour convictions. The Director of Procurement and Materiel Management is the lead for AAFC.

Risk identification and actions

In May 2021, a risk analysis of PSPC's supply chains was completed by Rights Lab, of the University of Nottingham (United Kingdom), 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.

AAFC is aware of the risk assessment conducted by PSPC and is monitoring related follow-up action, including PSPC's development of a policy on ethical procurement.

Measures to remediate any forced labour or child labour

AAFC has an established procurement framework, aligned with the overarching frameworks of PSPC and Treasury Board Secretariat, and supported by defined practices, procedures and processes, that advance the Government of Canada's mandate and priorities. This includes a process to address and remediate any cases of forced labour or child labour.

To date, AAFC has not encountered any cases of forced labour or child labour within its activities or supply chains.

Measures to remediate loss of income

AAFC 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 our activities and supply chains and therefore has not taken any remediation measures.

Employee training

AAFC is actively monitoring and will leverage any awareness-raising guidance materials (including risk mitigation strategies) for suppliers, targeted towards high-risk sectors resources accordingly once published by PSPC.

Assessing effectiveness

AAFC has a process to address forced labour or child labour cases; however, the department has yet to encounter a case to assess the process' effectiveness.

The department does conduct an assessment of its procurement practices, procedures and processes annually, as well as on an ad hoc basis when deemed necessary, to ensure AAFC remains current and aligned with the Government of Canada's procurement objectives and expected results.

Original signed by:

Lawrence Hanson
Deputy Head, Agriculture and Agri-Food Canada

Annex: Key definitions

Definitions are from Section 2 of the Fighting Against Forced Labour and Child Labour in Supply Chains Act.

Child labour

Labour or services provided or offered to be provided by persons under the age of 18 years and that

• are provided or offered to be provided in Canada under circumstances that are contrary to the laws applicable in Canada;
• are provided or offered to be provided under circumstances that are mentally, physically, socially or morally dangerous to them;
• interfere with their schooling by depriving them of the opportunity to attend school, obliging them to leave school prematurely or requiring them to attempt to combine school attendance with excessively long and heavy work; or
• constitute the worst forms of child labour as defined in article 3 of the Worst Forms of Child Labour Convention, 1999, adopted at Geneva on June 17, 1999.

Forced labour

Labour or service provided or offered to be provided by a person under circumstances that

• could reasonably be expected to cause the person to believe their safety or the safety of a person known to them would be threatened if they failed to provide or offer to provide the labour or service;
• constitute forced or compulsory labour as defined in article 2 of the Forced Labour Convention, 1930, adopted at Geneva on June 28, 1930.

Production of goods

Includes the manufacturing, growing, extracting and processing of goods