Forced labour in government procurement means goods or services produced by people coerced into working against their will. If you're involved in federal contracting, you need to understand these requirements—they've expanded significantly since first appearing in 2021, and non-compliance can lead to contract termination.
How It Works
The federal government's anti-forced labour framework is set out in Supply Manual Annex 2.8, which Public Services and Procurement Canada (PSPC) first introduced for goods contracts in November 2021. These requirements didn't stay static. They expanded to standing offers and supply arrangements in November 2023, then made a major leap in December 2024 when they were applied to services contracts—including research and development, architecture, and engineering work.
When you bid on a federal contract now, you're attesting that your goods or services aren't produced using forced labour. This isn't just a checkbox exercise. The requirements tie directly to the Code of Conduct for Procurement, which became mandatory in April 2023 through amendments to the Treasury Board's Directive on the Management of Procurement. Contractors must confirm they understand and will comply with these standards throughout the contract period.
In practice, contracting authorities have real enforcement power behind these clauses. If Canada determines that goods were produced using forced labour, or if a contractor is convicted of human trafficking offences, the government can terminate the contract immediately. The Fighting Against Forced Labour and Child Labour in Supply Chains Act, which came into force January 1, 2024, strengthened the legislative backdrop for these procurement measures. Federal departments like the RCMP and CNSC now routinely include these clauses in their contracting documentation and report on compliance annually.
Key Considerations
- Scope keeps expanding: What started with goods contracts now covers virtually all federal procurement. Services contracts awarded after December 13, 2024? These requirements apply to you.
- Supply chain visibility matters: You're responsible for your entire supply chain, not just your direct operations. "Produced in whole or in part" means even a single component made using forced labour can put your contract at risk.
- Documentation requirements intersect: Anti-forced labour attestations work alongside other integrity provisions in federal contracting. You'll need systems to track and verify your supply chain practices.
- Consequences are real: Contract termination isn't the only risk. Violations can affect your standing as a supplier and impact future bidding opportunities across government.
Related Terms
Code of Conduct for Procurement, Integrity Provisions, Social Procurement, Supply Chain Management, Contract Termination
Sources
- Supply Manual Annex 2.8 – Anti-forced labour requirements
- Protecting human rights in federal procurement (canada.ca)
- RCMP Fighting Against Forced Labour and Child Labour in Supply Chains Act Annual Report 2024-2025
The regulatory landscape around forced labour continues to evolve, so check Supply Manual Annex 2.8 regularly for updates. Your procurement team should be integrating these requirements into vendor qualification processes now, not scrambling when a contract opportunity appears.