Annual Report on Anti-forced labour and child labour in the Department of Justice Canada’s Supply Chains fiscal year 2023-2024

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Part 1: Identifying information

Department of Justice Canada
Financial reporting year: April 1, 2023 to March 31, 2024

This is an original report.

Part 2: Report contents

2.1 Information on the government institution’s structure, activities and supply chains

The Department of Justice Canada supports the dual roles of the Minister of Justice and the Attorney General of Canada.

The Department of Justice Canada was officially established in 1868, when the Department of Justice Act was passed in Parliament. The Act sets out the roles and responsibilities of the Minister of Justice and Attorney General of Canada, as well as those of the Department.

The Department of Justice Canada fulfils three distinctive roles within the Government of Canada. It acts as:

With a workforce exceeding 5,000 full-time equivalent employees, approximately 66 percent of Justice Canada's personnel are situated in the National Capital Region. The remaining 34 percent contribute to a robust national presence through regional offices and sub-offices across the country.

At the Department of Justice Canada, approximately 95% of the annual value of our goods purchases are made through the use of PSPC and Shared Services Canada (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 of the department’s contracts for goods resulting from the use of these tools include clauses related to forced labour which set out, among other things, human rights and labour rights requirements. These clauses can be found in the policy notification 150 – Anti-forced labour requirements.

Provide additional information on the government institution’s structure, activities and supply chains.

For fiscal year 2023-2024, the Department of Justice Canada held a total contract value of $13.4 million for the purchase of goods, which were primarily sourced with Canadian vendors for mainly IT equipment and office furniture. Of the $13.4 million, a total of $12.7 million used either PSPC or SSC procurement tools.

2.2 Information on the steps taken 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 Department of Justice Canada has integrated Public Services and Procurement Canada’s (PSPC) updated General Conditions for goods contracts and PSPC’s Code of Conduct of Procurement in its purchasing activities.

In addition, to prevent and reduce the risk of forced labour or child labour in its procurements, the Department of Justice Canada has used the following list of PSPC tools:

While PSPC supports government institutions in their daily operations as the central purchasing agent for the Government of Canada, the Department of Justice Canada also undertakes activities under its own procurement authority.

During fiscal year 2023-2024, the Department of Justice Canada purchased goods under its own procurement authority in the following areas: office furniture and seating, office supplies, and IT equipment and accessories.

2.3 Information on the policies and due diligence processes in relation to forced labour and child labour

Does the government institution currently have policies and due diligence processes in place related to forced labour and/or child labour? (Yes or No)

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 these amendments, the Department of Justice has integrated the Code into its procurement practices, with a view to safeguarding federal procurement supply chains from forced labour and child labour. Contracts awarded by the Department of Justice include 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.

2.4 Information on the parts of its activities and supply chains that carry a risk of forced labour or child labour being used and the steps 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.

Procurement specialists at the Department of Justice have familiarized themselves with information on the risk assessment provided by PSPC, and are monitoring related actions, including the development of a Policy on Ethical Procurement.

Has the government institution identified forced labour or child labour risks in its activities and supply chains related to any of the following sectors and industries?

While the Department of Justice Canada has not yet identified forced labour or child labour risks in its activities and supply chains, the Department will engage with PSPC to determine any goods in its supply chains that represents highest risks.

2.5 Information on any measures taken to remediate any forced labour or child labour

Has the government institution taken any measures to remediate any forced labour or child labour in its activities and supply chains?

The Department of Justice Canada has not taken any measures beyond those previously identified in this report to remediate any forced labour or child labour in its activities and supply chains. The Department will start to explore options to remediate any force labour or child labour in its activities and supply chains by working with PSPC and other key stakeholders.

2.6 Information on any measures taken to remediate the loss of income to the most vulnerable families that results from any measure taken to eliminate the use of forced labour or child labour in the institution’s activities and supply chains

Has the government institution taken any measures to remediate the loss of income to the most vulnerable families that results from any measure taken to eliminate the use of forced or child labour in its activities and supply chains?

In the absence of information indicating concern with existing supply chains, the Department of Justice Canada has not yet taken any measures in this area. However, the Department will engage with PSPC to explore measures to be taken should this situation arise.

2.7 Information on the training provided to employees on forced labour and child labour

Does the government institution currently provide training to employees on forced labour and/or child labour? (Yes or No)

The Department of Justice Canada has not yet provided any training to employees on forced labour and/or child labour in the context of procurement. The Department will mandate related training for all procurement officers when it becomes available through PSPC or the Canada School of Public Service.

The Department is aware that PSPC is currently developing awareness-raising guidance materials (including risk mitigation strategies) for suppliers, targeted towards high-risk sectors. The Department is monitoring the development of these materials and will leverage these resources upon their publication.

2.8 Information on how the government institution assesses its effectiveness in ensuring that forced labour and child labour are not being used in its activities and supply chains

Does the government institution 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 activities and supply chains? (Yes or No)

At present, the Department of Justice Canada has no policies and procedures in place to assess its effectiveness in ensuring that forced labour and child labour are not being used in its activities and supply chains. The Department of Justice Canada will engage with PSPC to explore any policies and procedures to assess such effectiveness.