National Strategy to Combat Human Trafficking (2019-2024)

The National Strategy to Combat Human Trafficking (2019-2024) was the Government of Canada's whole-of-government framework for preventing and addressing human trafficking. Public Safety Canada led it, and it brought federal efforts together under one strategic plan.

Canada launched the five-year strategy in September 2019. It complemented existing federal measures on gender-based violence and the safety of Indigenous peoples. For suppliers, its relevance is the commitment to develop and enhance government procurement activity so that human trafficking and forced labour are addressed in federal supply chains. The federal progress report on gender-based violence describes the launch and the Public Safety Canada lead.

The five pillars of the 2019 strategy

The strategy organized federal action around five pillars: empowerment, prevention, protection, prosecution and partnerships. Federal departments described their work under these headings, including the testimony Immigration, Refugees and Citizenship Canada gave on the conditions and vulnerabilities of temporary migrant workers.

Most of the pillars concern policing, victim services and public awareness. Procurement sits mainly within the prevention and partnerships work, where the federal government acts as a buyer of goods and services.

The procurement commitment and Public Services and Procurement Canada

The strategy included a commitment to develop and enhance government procurement activity. Public Services and Procurement Canada (PSPC) is the federal procurement authority, and its ethical procurement guidance on expectations ties this work to the strategy. The goal is to conduct procurements with suppliers whose supply chains are free of forced labour and human trafficking.

Related concepts include ethical procurement, human-rights due diligence, forced labour and human trafficking in supply chains, the Code of Conduct for Procurement, and the Fighting Against Forced Labour and Child Labour in Supply Chains Act.

Forced labour clauses by contract type

The procurement commitment has appeared in contract clauses introduced in stages. The Supply Manual annexes on CanadaBuys record the dates:

• Goods contracts: since November 4, 2021, clauses allow Canada to terminate a contract where goods were produced wholly or partly through forced labour or human trafficking.
• Standing offers and supply arrangements: since November 20, 2023, clauses allow Canada to set aside a standing offer, or to suspend or cancel a supply arrangement, where there are reasonable grounds to believe the offered goods were produced through forced labour.
• Services, research and development, and architecture and engineering contracts: from December 13, 2024, anti-forced-labour clauses were expanded to these contract types, allowing termination where the work was produced wholly or partly through forced labour.

CanadaBuys also publishes a page on the anti-forced labour requirements that sits within its ethical procurement material.

The Code of Conduct for Procurement

The strategy also prompted a commitment for PSPC to update the Code of Conduct for Procurement. The update was to set out human-rights expectations for suppliers and to develop tools that help vendors meet them. PSPC describes this work on its supplier conduct consultation page.

What it means for a supplier bidding on Canadian public contracts

There is no standalone certification called "compliance with the strategy." Suppliers must instead meet the human-rights, forced-labour and human-trafficking provisions in the solicitation, standing offer, supply arrangement or contract they are bidding on.

• Read the forced labour clauses in each solicitation and resulting contract, because they carry termination, suspension and cancellation consequences.
• Check your own supply chain for goods, or work, produced wholly or partly through forced labour or human trafficking.
• Review the Code of Conduct for Procurement and the related PSPC guidance before you submit.
• If you offer services, research and development, or architecture and engineering work, expect these clauses in contracts issued since December 13, 2024.