Anti-Forced Labour Requirements

Anti-forced labour requirements are procurement obligations intended to prevent goods or services from being produced using forced labour, human trafficking, or related exploitative practices. They reach suppliers through contract clauses, codes of conduct and due-diligence expectations, and they extend to subcontractors as well as prime contractors.

The term sits within responsible procurement and supply-chain management. It overlaps with human trafficking, forced or compulsory labour, forced child labour, modern slavery and supplier codes of conduct. In Canada it is tied to the prohibition on importing goods produced wholly or partly by forced or compulsory labour.

How NATO applies anti-forced labour requirements

NATO states that it will address trafficking in human beings through procurement processes and supply-chain due diligence, and that NATO funds must not support trafficking-related actions. Its policy on combatting trafficking in human beings sets this out.

NATO procurement contracts prohibit contractors and subcontractors from engaging in, supporting, or facilitating trafficking in human beings. Suppliers are also obliged to remediate wrongdoing. Where they fail to meet these obligations, NATO may terminate the contract and impose sanctions.

The NATO Communications and Information Agency goes further in its supplier code of conduct, which prohibits forced, bonded, indentured and involuntary prison labour.

PSPC clauses and when they were introduced

Public Services and Procurement Canada (PSPC) has added anti-forced-labour clauses to its contracts in stages. Since November 2021, all goods contracts it administers have included them. The clauses allow termination where credible information indicates that goods were produced wholly or partly by forced labour or human trafficking, as reported in the PSPC 2023-2024 annual report on preventing forced labour in supply chains.

Since November 20, 2023, PSPC standing offers and supply arrangements for goods have carried the same clauses when issued, amended or refreshed on behalf of PSPC or client departments. As of December 2024, the 2024-2025 report confirms that PSPC requires the clauses in all new or amended contracts for goods and services, and in new or amended standing offers and supply arrangements.

Other federal organizations that use PSPC procurement tools can receive contracts containing these clauses. The Treasury Board of Canada Secretariat states that contracts for goods resulting from these tools include forced-labour clauses setting out human-rights and labour-rights requirements.

The Code of Conduct for Procurement

The federal Code of Conduct for Procurement applies to contractors and subcontractors responding to bid solicitations. It prohibits practices involving human trafficking, forced labour and child labour. It also requires compliance with Canada's prohibition on importing goods produced wholly or partly by forced or compulsory labour, including forced child labour, regardless of country of origin. This requirement is described in the Public Health Agency of Canada's report under the Fighting Against Forced Labour and Child Labour in Supply Chains Act.

Consequences for suppliers

The remedy depends on the instrument. According to PSPC's 2025-2026 report, the clauses can permit contract termination, setting aside a standing offer, or suspending or cancelling a supply arrangement. The trigger is credible information that supplied goods involve forced labour or human trafficking.

What it means for a supplier bidding on Canadian public contracts

Expect the clauses in any PSPC contract for goods or services, and in standing offers and supply arrangements. Bid teams should read the Code of Conduct for Procurement before responding, and confirm that subcontractors accept the same obligations. Suppliers should be able to trace where goods come from, regardless of country of origin, because credible information about forced labour in a supply chain can end a contract or arrangement. On NATO-funded work, add remediation duties and possible sanctions to that risk.