2025 Annual Report to Parliament on the Fighting Against Forced Labour and Child Labour in Supply Chains Act
Table of contents
- Introduction
- Data and Analysis
- About the analysis
- Overview of reports received by Public Safety Canada
- Summary of activities that carry a risk of forced labour and child labour
- Efforts to assess and manage risks of forced labour and child labour
- Efforts to remediate forced labour and child labour
- Corrective measures, offences and punishments
- Annex A: Definitions and Legislative Requirements
- Annex B: Data tables
Introduction
The 2025 annual report is tabled in Parliament in accordance with subsection 24(1) of the Fighting Against Forced Labour and Child Labour in Supply Chains Act (Supply Chains Act), under the direction of the Minister of Public Safety, and covers the second reporting period of the Supply Chains Act. This report provides an overview of the risks of forced labour and child labour that reporting entities and government institutions have identified in their activities and supply chains, as well as the steps these organizations have taken to address the risks.
About the Supply Chains Act
The Supply Chains Act came into force on January 1, 2024, and requires certain government institutions and entities to report on their efforts to prevent and reduce risks of forced labour or child labour in their supply chains. Reports must be submitted on or before May 31 of each year and must include, among other things, the activities undertaken by the government institution or entity in its previous financial year.
The purpose of the legislation is to contribute to the fight against forced labour and child labour, through the imposition of reporting obligations on:
- government institutions producing, purchasing or distributing goods in Canada or elsewhere; and
- entities producing goods in Canada or elsewhere or importing goods produced outside Canada.
Additional details regarding definitions and legal requirements are provided in Annex A.
Publication of reports
Reports submitted to Public Safety Canada are made publicly available in a searchable online catalogue on the Public Safety Canada website in accordance with section 22 of the Supply Chains Act.
The online catalogue is updated on a regular basis. Note that reports are only published in the catalogue if they pass a quality assurance check. For example, a report is not published if it does not contain information relevant to the Supply Chains Act or the reporting requirements.
Reporting government institutions and entities must also make their annual report available to the public, including by publishing it in a prominent place on the government institution or entity's website, as stipulated by section 8 and subsection 13(1) of the Supply Chains Act.
Online questionnaire
To submit their annual report, entities and government institutions must complete an online questionnaire which collects information that responds to the reporting requirements. This questionnaire is the mechanism for submitting an annual report to Public Safety Canada. The data collected allows the department to develop this report to Parliament and to measure progress year over year.
Requirements for reporting to Parliament
The Minister of Public Safety Canada is required to table a report to Parliament on the Supply Chains Act on or before September 30 of each year. The report must contain:
- a general summary of the activities of government institutions and entities that provided a report under the Supply Chains Act for their previous financial year that carry a risk of forced labour or child labour being used;
- the steps that government institutions and entities have taken to assess and manage that risk;
- if applicable, measures taken by government institutions and entities to remediate any forced labour or child labour;
- a copy of any order made pursuant to section 18; and
- the particulars of any charge laid against a person or entity under section 19.
Public Safety Canada's implementation progress
Public Safety Canada is responsible for ensuring coordination across all federal departments and agencies responsible for national security and the safety of Canadians. The Supply Chains Act names the Minister of Public Safety as the Minister responsible for administering and overseeing the annual reporting obligation. As a government institution, Public Safety Canada is also required to submit its own annual report under the Supply Chains Act.
Implementation Year One
Following Royal Assent in May 2023, Public Safety Canada worked diligently to implement the Supply Chains Act reporting regime and to support entities and government institutions to understand and fulfill their obligations.
| Timeline | Activity |
|---|---|
| Fall 2023 |
|
| Winter 2023 |
|
| Spring to Summer 2024 |
|
| Fall 2024 |
|
| Winter 2024 | Launched the second reporting cycle |
Implementation Year Two
In the second year of implementation, Public Safety Canada focused its efforts on conducting stakeholder engagement, refining the report intake process, expanding outreach and issuing updated guidance to support reporting government institutions and entities.
Stakeholder engagement
Throughout the summer of 2024, the department conducted a range of stakeholder engagements, including a public survey, hosting working sessions with industry groups and trade associations, and consultations with representatives from leading law firms. Public Safety Canada continues to manage an inbox dedicated to public inquiries and has responded to over 1,500 inquiries over the course of the reporting period. Furthermore, in July 2024, the department began distributing a quarterly newsletter to share updates and additional guidance regarding the reporting process and reporting requirements.
This engagement collectively provided a forum for Public Safety Canada to understand and address the concerns of a broad range of stakeholders, which led to the development of refined guidance in advance of the second reporting cycle.
Updated Reporting Guidance
On November 15, 2024, Public Safety Canada published updated guidance which provided important clarification and greater certainty to organizations regarding the scope and administration of the reporting requirement.
These updates clarified key aspects of the reporting regime, including:
- How to determine if an organization is a reporting entity under the Act
- Which business activities trigger a reporting obligation
- The meaning of key terms such as goods, assets and control
- How to determine if an entity is importing goods into Canada
- Factors to consider when assessing an entity's business presence in Canada
- How to complete the online questionnaire when submitting a joint report
In January 2025, the department hosted a series of information sessions which were attended by over 1000 participants, to explain the updates to the guidance, to share best practices and to discuss lessons learned from the first year of filing.
Public Safety Canada continues to work with entities and government institutions to increase awareness of the requirements, to promote compliance and improve the quality of the reported information.
Data and Analysis
About the analysis
This report was developed using data collected through an online questionnaire which provides an overview of the outcomes of the 2025 reporting cycle.
Public Safety Canada conducted a quality assurance review of all reports submitted by the May 31 deadline to determine which reports met the minimum standards for inclusion in the analysis for this report. This process removed from the final dataset duplicates, test submissions, as well as reports that, for example, did not include information addressing the requirements outlined in the Supply Chains Act.
The accuracy of the findings presented in this report is contingent on the quality and completeness of the information submitted to Public Safety Canada by government institutions and entities, as well as their understanding of the reporting requirements. Some questions in the online questionnaire allowed multiple responses; therefore, totals may exceed the number of respondents.
In addition to the quantitative analysis conducted on submissions received before the May 31 deadline, qualitative analysis was conducted to provide additional details and insight into responses that could not be presented quantitatively (e.g., descriptions of the types of risks and mitigation strategies shared by organizations). This analysis reflects a data sample and is not representative of all submissions.
Overview of reports received by Public Safety Canada
In 2025, Public Safety Canada received a total of 4,313 reports on or before the May 31 reporting deadline. Of these, 135 were submitted on behalf of government institutions and 4,178 were submitted on behalf of entities.
The 4,313 submissions that were analyzed for this report represent only those reports that were submitted on or before May 31, 2025, and that also passed the quality assurance review conducted by Public Safety Canada.
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96.9 percent of reports were submitted by entities and 3.1 percent were submitted by government institutions.
Joint reports
Entities are permitted to submit a joint report, which could cover, for example, a parent company and its subsidiaries or multiple entities belonging to the same corporate group.
In 2025, Public Safety Canada received 1,652 joint reports before the deadline, representing 40% of entity submissions. This represents a higher proportion of joint reports submitted to Public Safety Canada compared to joint reports submitted in 2024 (37% of reporting entities submitted joint reports in 2024).
Revised reports
Organizations may submit a revised report in order to make corrections or add additional information to their original submission. When submitting a revised report, organizations are required to state the date of revision and describe the changes made to the original report.
In 2025, 149 revised reports were submitted before the May 31 deadline. Note that in cases where an organization submitted a revised version of their annual report before the deadline, only their revised report was counted and considered for the development of this report.
Late submissions
To encourage transparency, Public Safety Canada continued to allow submissions after May 31, 2025, for publication in the online catalogue. By July 31, 2025, the department had received a total of 5,176 submissions for this reporting cycle and continues to receive reports. Submissions are added to the online catalogue on an ongoing basis, with a note to identify those reports that were filed late.
Public Safety Canada received 863 reports between May 31, 2025, and July 31, 2025. This represents an increase in late submissions (between May 31 and July 31) compared to last year where 508 reports were submitted during that timeframe. For the purposes of this report, only the 4,313 reports submitted before the reporting deadline were analyzed.
Entities subject to supply chain legislation in multiple jurisdictions
Recognizing that many reporting entities operate internationally, respondents were asked to indicate whether they are subject to reporting requirements under modern slavery or supply chain legislation in other jurisdictions. Responses to this question are presented below.
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Of the total 4,178 respondents, 3,469 (or 83.03 percent) indicated that they were not subject to other legislation. A total of 708 respondents (16.95 percent) reported being subject to other legislation, while one respondent (0.02 percent) did not provide a response.
Of the 708 respondents that were subject to other legislations, 499 were subject to the United Kingdom's Modern Slavery Act 2015; 433 were subject to California's Transparency in Supply Chains Act (United States); 280 were subject to Australia's Modern Slavery Act 2018; and 208 were subject to other legislations.
Breakdown of reporting government institutions
The Supply Chains Act applies to a range of federal departments and agencies, as well as federal Crown corporations and wholly-owned subsidiaries thereof. Of the 135 reports from government institutions in 2025, 40% were submitted on behalf of federal Crown corporations or wholly-owned subsidiaries.
Breakdown of reporting entities
Reports were submitted on behalf of entities based in Canada and around the world representing a wide range of sectors and industries. Among reporting entities, 79.5% indicated they are headquartered or principally located in Canada, and 20.5% indicated they are headquartered or principally located in another country. (see Table 3 in Annex B).
Among reporting entities, the following sectors were the most commonly represented:
The top 5 sectors in 2025:
- Manufacturing (24.9% of entities)
- Wholesale Trade (11.8% of entities)
- Retail Trade (8.9% of entities)
- Mining, quarrying, and oil and gas extraction (6.5% of entities)
- Transportation and warehousing (5.8% of entities)
Summary of activities that carry a risk of forced labour and child labour
This section responds to the requirement outlined in subsection 24(1)(a) to include in the report to Parliament "a general summary of the activities of government institutions and entities that provided a report under [the Supply Chains Act ] for their previous financial year that carry a risk of forced labour or child labour being used."
The Supply Chains Act requires government institutions and entities to report on the parts of their activities or business and their supply chains that carry a risk of forced labour or child labour being used (paragraphs 6(2)(c) and 11(3)(c)).
Gaining visibility into a complex supply chain can be difficult, and mapping possible risk areas is an ongoing process for any organization. Identifying a risk means it was determined there is some possibility that forced labour or child labour might be used at some point within the supply chain, but does not indicate that forced labour or child labour is certainly being used.
In the online questionnaire, entities and government institutions, collectively referred to as 'organizations' in this report, were asked whether they had identified parts of their activities or business and supply chains that carry a risk of forced labour or child labour being used and the types of risk areas they had identified, if any. They were also given an opportunity to provide additional information, if desired.
82% of all reporting organizations indicated that they had identified parts of their activities and supply chains that carry a risk of forced labour or child labour being used.
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In 2024, 77 percent of organizations had identified risk/started the process, while 23 percent had not started the process. In 2025, 82.3 percent had identified risks/started the process, while 17.7 percent had not started the process.
When government institutions were asked about their efforts to identify risks of forced labour or child labour in their supply chains:
- 47.4% indicated they had identified parts of their activities and supply chains that carry a risk of forced labour or child labour being used; and
- 52.6% indicated that they had not started the process of identifying risks.
Government institutions that had started identifying risks most commonly identified the following aspects of their activities and supply chains as being at risk of forced labour and child labour (see Table 5a in Annex B):
- The types of products it sources (51.6%);
- Tier twoFootnote 1 suppliers (21.9%);
- Tier one (direct) suppliers (20.3%);
- The sector or industry it operates in (17.2%); and
- Suppliers further down the supply chain than tier three (15.6%).
Entities reported varying levels of progress with respect to their risk identification efforts:
- 44.2% of entities indicated that they had identified parts of their activities and supply chains that carry a risk of forced labour or child labour being used;
- 39.2% had started the process of identifying risks but highlighted there were still gaps in their assessments; and
- 16.6% had not started the process of identifying risks.
Reporting entities that have started identifying risks most commonly identified forced labour or child labour risks related to the following aspects of their activities and supply chains (see Table 5b in Annex B):
- The raw materials or commodities used in its supply chains (34.1%);
- The sectors or industries it operates in (30.4%);
- Tier one (direct) suppliers (29.7%);
- The location of its activities, operations or factories (29.6%); and
- The types of products it sources (28.5%).
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In descending order of frequency, the most commonly identified risk factor was the raw materials or commodities used in supply chains, accounting for 34.1 percent. This was followed by the sector or industry of operation (30.4 percent), tier one (direct) suppliers (29.7 percent), and the locations of activities, operations, or factories (29.6 percent). Other identified risks included the types of products produced or imported (28.5 percent), the types of products sourced (27.9 percent), and tier two suppliers (20.1 percent). Additional factors were the use of outsourced, contracted, or subcontracted labour (16.8 percent), tier three suppliers (16.2 percent), and suppliers beyond tier three (15.1 percent). Less frequently cited risks included the use of migrant labour (11.1 percent), forced labour (10.8 percent), and child labour (10.1 percent).
Several organizations identified risks of forced labour and child labour related to specific goods, sectors or industries, as highlighted in the following statements.
- "[Entity] has identified an inherent risk of child labour and forced labour within its industry of operation (manufacturing)."
- "[Entity] procures goods and services from industries or sectors that may carry a risk of modern slavery. According to external sources these sectors may include manufacturing, transportation, industrial wholesale and distribution, technology and electronics manufacturing, construction, and automotive."
Some organizations noted that in their supply chains, there were unknown levels of risk due to a lack of visibility into the practices of indirect suppliers and subcontractors.
- "Our use of third-party manufacturers also adds to our risk profile, as we have less visibility over their hiring and labour practices."
- "We acknowledge that our suppliers have their own value chains on which we have limited visibility, and which may extend to higher risk countries and that our suppliers may source a very minor portion of the substrates or supplies we purchase from China."
- "We recognize, however, that we may be exposed to risks of forced labour or child labour through our suppliers and suppliers' suppliers, as we have no visibility over the conditions of employment of workers in our supply chain."
- "We recognize that the most significant risks of modern slavery may be present at tier 2 or below in our supply chain, where we have less visibility of working conditions and sub-supplier practices."
Some organizations acknowledged heightened risks of forced labour and child labour when temporary or migrant workers are employed, especially due to these workers' vulnerable position in society.
- "Some report sourcing materials or components from countries identified as carrying elevated modern slavery risks. According to the 2023 Global Slavery Index, these identified countries are associated with risk factors such as weak enforcement of labour standards, the presence of vulnerable migrant worker populations, and limited oversight in supply chain practices."
- "We determined that potential risks are especially high with temporary workers and contract workers who are foreign nationals engaged in production."
- "We recognize the increased challenges of ensuring ethical labour practices when working with placement and staffing agencies that are not under our control, particularly those that may supply employees to work in production at our facilities (e.g. machine operators, packagers). We collaborate with such suppliers to understand their recruitment and employment practices for foreign workers. In turn, we require these suppliers to comply with relevant Canadian labour laws, including those related to minimum age for employment, work permits, and any other applicable regulations."
Efforts to assess and manage risks of forced labour and child labour
This section responds to paragraph 24(1)(b) of the Supply Chains Act, which requires that the annual report include a description of "the steps that government institutions and entities have taken to assess and manage [risks of forced labour and child labour]."
Steps taken to prevent and reduce forced labour and child labour risks
Organizations that report having identified risks of forced labour or child labour are asked to describe the steps they have taken to assess and address those risks. However, regardless of whether they have identified risks in their activities or supply chains, respondents must describe any preventative measures they have in place, including:
- their policies and due diligence processes in relation to forced labour and child labour;
- the training they provide to employees on forced labour and child labour; and
- their methods for assessing their effectiveness in ensuring that forced labour and child labour are not used in their activities or business and their supply chains.
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In order from most to least frequent, embedding responsible business conduct into policies and management systems was reported by 96.9 percent of organizations. This was followed by identifying and assessing potential and actual adverse impacts in operations, supply chains, and business relationships (49.8 percent), ceasing, preventing, or mitigating those impacts (34.3 percent), tracking implementation and results (29.3 percent), providing for or cooperating in remediation when appropriate (25.7 percent), and communicating how impacts are addressed (22.9 percent).
Policies and due diligence processes
83% of all reporting organizations having policies and due diligence processes in place related to forced labor and/or child labour.
- 65.2% of government institutions reported having policies and due diligence processes in place related to forced labour and/or child labour.
- 84.1% of entities reported having policies and due diligence processes in place related to forced labour and/or child labour.
Training provided to employees
61% of all organizations reported having training on forced labour or child labour for their employees.
When asked if they currently provide training to employees on forced labour and/or child labour:
- 44.4% of government institutions responded that they did provide training.
- 61.7% of entities responded that they did provide training.
Organizations that indicated that they provide training on forced labour and/or child labour were asked who is offered the training and whether the training is mandatory.
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In 2024, 39.5 percent of organizations reported training was mandatory for all employees, 29.1 percent was mandatory for some employees, 22.9 percent was mandatory specifically for employees involved in contracting or purchasing decisions, and 8.6 percent was voluntary.
In 2025, the proportions shifted slightly: 37.8 percent of organizations reported training was mandatory for all employees, 29.6 percent was mandatory for some employees, 25.4 percent was mandatory for employees making contracting or purchasing decisions, and 7.2 percent was voluntary.
Below are the sectors in which entities had the highest proportion of respondents noting that they provide training to their employees on forced labour and child labour:
- 67.2% from the manufacturing sector;
- 66.2% representing professional, scientific and technical services;
- 65.7% representing finance and insurance;
- 65.0% from wholesale trade; and
- 64.9% from the utilities sector.
For a complete breakdown by sector of organizations that provide training, see Table 8 in Annex B.
Assessing effectiveness in preventing the use of forced labour and child labour
50% of organizations confirmed they have policies and procedures in place to assess their effectiveness in ensuring that forced labour and child labour are not being used in their activities and supply chains.
When asked if they have policies and procedures in place to assess their effectiveness in ensuring that forced labour and child labour are not being used in their activities and supply chains:
- 15.6% of government institutions indicated they did and 84.4% indicated they did not.
- 51.2% of entities indicated they did and 48.8% indicated they did not.
The most common steps taken by government institutions to assess their effectiveness in ensuring that forced labour and child labour are not being used in their activities include:
- Setting up a regular review or audit of the government institution's policies and procedures related to forced labour and child labour (66.7%);
- Tracking relevant performance indicators, such as levels of employee awareness, numbers of cases reported and solved through grievance mechanisms and numbers of contracts with anti-forced labour and -child labour clauses (28.6%);
- Working with suppliers to measure the effectiveness of their actions to address forced labour and child labour, including by tracking relevant performance indicators (23.8%); and
- Partnering with an external organization to conduct an independent review or audit of the government institution's actions (8%).
The most common steps taken by entities to assess their effectiveness in ensuring that forced labour and child labour are not being used in their activities include:
- Setting up a regular review or audit of the entity's policies and procedures related to forced labour and child labour (76.0%);
- Tracking relevant performance indicators, such as levels of employee awareness, numbers of cases reported and solved through grievance mechanisms and numbers of contracts with anti-forced labour and -child labour clauses (37.4%);
- Working with suppliers to measure the effectiveness of their actions to address forced labour and child labour, including by tracking relevant performance indicators (36.6%); and
- Partnering with an external organization to conduct an independent review or audit of the entity's actions (23.9%).
For additional information on the methods that organizations used to assess effectiveness, see Table 9 in Annex B.
Some entities reported that they require vendors and partners to comply with related policies & standards. Many stated that they have implemented codes of conduct within their contracting language.
- "[Entity]'s significant suppliers have implemented Business Ethics Policies, Supplier Codes of Conduct, and/or Human Rights Policies that explicitly prohibit forced labour and human trafficking."
- "[Entity] implemented anti-forced labour clauses in all good 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."
When asked about strategies to reduce risks of forced labour and child labour when choosing their supply chain partners, entities reported the following actions:
- "[Entity] has implemented processes with supply chain partners to address issues of forced labour and/or child labour, including the Supplier Code of Conduct and Whistle Blower policies."
- "We are continuing to engage in risk mapping of our supply chain, a process that is ongoing. To address the risk, [entity] has a Procurement Policy to ensure that apparel are purchased from responsible apparel manufacturers."
- "How we address the risk – Policies, due diligence, training, and assessing effectiveness. [Entity] has a mandatory Code of Conduct policy for all staff which includes Contracting and Procurement. This section includes the following requirement '[Entity] seeks to work with contractors and suppliers who contribute to sustainable development, meet health and safety standards and legislation, and are economically, environmentally, and socially responsible'."
Many reported having ethical employment practices. Some mentioned that they have supply chain due diligence.
- "In addition to a low jurisdictional risk, at [entity] we maintain employment practices consistent with Canadian labour and employment laws, which helps prevent and reduce the risk of child and forced labour in its operations. All our employees are above the legal minimum employment age in Canada and are recruited and provided working conditions and the payment of wages and benefits that comply with provincial and federal laws and regulations."
- "To prevent and mitigate the risk of forced labor or child labor in any stage of our product production within our supply chain, [entity] has implemented rigorous policies and due diligence processes for supplier qualification. Additionally, we have established clear policies to ensure all suppliers adhere to social compliance standards and regulations. To monitor compliance, external social audits are conducted on an annual basis."
- "[Entity] conducts due diligence processes to assess and mitigate the risk of modern slavery within its supply chain. This includes regular supplier audits, supplier certification requirements, and ongoing monitoring to identify any potential issues."
Some entities also mentioned the use of working groups, committees, stakeholder engagements and engagements with unions as vehicles to address forced labour and child labour issues.
- "We engage with all our clients, suppliers, and contractors to raise awareness about the importance of eradicating forced labour and/or child labour in our activities and supply chain."
- "Special supplier attestation letter was created to ask suppliers to learn about and comply with the Canadian legislation, as well as actively engage with us to fight slavery in the supply chain (i.e. engaged with supply chain partners on the issue of addressing forced labour and/or child labour)."
Efforts to remediate forced labour and child labour
This section responds to the requirement in paragraph 24(1)(c) of the Supply Chains Act to include, if applicable, a description of "measures taken by government institutions and entities to remediate any forced labour or child labour."
The Supply Chains Act requires government institutions and entities to report on any measures they have taken to remediate any forced labour or child labour in their activities and supply chains (paragraphs 6(2)(d) and 11(3)(d)).
91% of organizations indicated that questions relating to their efforts to remediate instances of forced labour and child labour did not apply to them as they had not identified any instances of forced labour or child labour in their supply chains.
Measures taken to remediate instances of forced labour or child labour
The majority of organizations (91%) that submitted a report to Public Safety Canada indicated that questions relating to their efforts to remediate instances of forced labour and child labour did not apply as they had not identified any forced labour or child labour in their activities and supply chains.
5.0% of organizations that submitted a report to Public Safety Canada indicated they have taken measures to remediate instances of forced labour or child labour. Of those, 211 were entities and 3 were government institutions. When asked to specify what actions were taken to remedy instances of forced labour or child labour, those organizations identified the following:
- 86.9% identified actions to prevent forced labour or child labour and associated harms from reoccurring;
- 64.5% identified grievance mechanisms;
- 16.4% said compensation for victims of forced labour or child labour and/or their families;
- 11.2% said actions to support victims of forced labour or child labour and/or their families, such as workforce reintegration and psychosocial support; and
- 0.5% said formal apologies.
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In descending order of frequency, 86.9 percent of organizations reported taking actions to prevent the reoccurrence of forced labour or child labour and associated harms. This was followed by the implementation of grievance mechanisms (64.5 percent), compensation for victims and/or their families (16.4 percent), support for victims and/or their families, such as workforce reintegration and psychosocial services (11.2 percent), and formal apologies (0.5 percent).
For a breakdown by sector of the organizations that have taken remediation measures, see Table 11 in Annex B.
Measures taken to remediate the loss of income to the most vulnerable families
When an organization amends or terminates its activities to avoid the use of forced labour or child labour (for example, ending a relationship with a supplier or pulling operations out of a country), there may be unintended consequences that contribute to lost income for workers and families.
If applicable, organizations must also report on any measures they have 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.
When asked if they had taken any measures to remediate the loss of income to the most vulnerable families that results from any measures taken to eliminate the use of forced labour or child labour in their activities and supply chains:
- 1.0% of organizations confirmed they had taken remediation measures and will continue to identify and address any gaps;
- 4.1% of organizations said they had not taken any remediation measures; and
- 94.8% of organizations said this question was not applicable.
Corrective measures, offences and punishments
This section responds to the requirements in subsection 24(1) paragraphs (d) and (e) to include "a copy of any order made pursuant to section 18" and "the particulars of any charge laid against a person or entity under section 19."
The Minister may designate persons or classes of persons for the purposes of the administration and enforcement of the Supply Chains Act. Sections 15 and 16 provide a designated person with the authority to verify compliance with the Supply Chains Act. Section 17 requires that a person must not obstruct or hinder a designated person who is exercising powers or performing duties under the Supply Chains Act.
Under section 18, where the Minister is of the opinion that an entity is not in compliance with section 11 or 13, based on information obtained under section 15, the Minister may require the entity to take any measures that the Minister considers necessary to ensure compliance with those provisions.
Section 19 provides that a person or entity that fails to comply with section 11 or 13, subsection 15(4) or an order made under section 18, or that contravenes section 17, is guilty of an offence punishable on summary conviction and liable to a fine of not more than $250,000.
In the second year of reporting, recognizing that the goal of the Supply Chains Act is to continue increasing industry awareness and transparency about risks of forced labour and child labour, Public Safety Canada prioritized raising awareness of the reporting requirements to encourage meaningful action.
In 2025, no orders were made pursuant to section 18 and no charges were laid against any person or entity under section 19.
Annex A: Definitions and Legislative Requirements
Under the Supply Chains Act, a government institution has the same meaning as in section 3 of the Access to Information Act (AIA):
- any department or ministry of state of the Government of Canada, or any body or office, listed in Schedule I of the AIA; and
- any parent Crown corporation, and any wholly-owned subsidiary of such a corporation, within the meaning of section 83 of the Financial Administration Act.
An entity means a corporation or a trust, partnership or other unincorporated organization that:
- is listed on a stock exchange in Canada;
- has a place of business in Canada, does business in Canada or has assets in Canada and that, based on its consolidated financial statements, meets at least two of the following conditions for at least one of its two most recent financial years:
- it has at least $20 million in assets,
- it has generated at least $40 million in revenue, and
- it employs an average of at least 250 employees; or
- is prescribed by regulations.
Reporting requirements for government institutions and entities
Subsections 6(1) and 11(1) of the Supply Chains Act provide that:
- 6(1) The head of every government institution must, on or before May 31 of each year, report to the Minister [of Public Safety] on the steps the government institution has taken during its previous financial year 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.
- 11(1) Every entity must, on or before May 31 of each year, report to the Minister [of Public Safety] on the steps the entity has taken during its previous financial year to prevent and reduce the risk that forced labour or child labour is used at any step of the production of goods in Canada or elsewhere by the entity or of goods imported into Canada by the entity.
Additionally, subsections 6(2) and 11(3) require that each report provided by a government institution or entity includes the following information:
- its structure, activities and supply chains;
- its policies and due diligence processes in relation to forced labour and child labour;
- the parts of its activities or business and supply chains that carry a risk of forced labour or child labour being used and the steps it has taken to assess and manage that risk;
- any measures taken to remediate any forced labour or child labour;
- 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 its activities and supply chains;
- the training provided to employees on forced labour and child labour; and
- how the government institution or entity assesses its effectiveness in ensuring that forced labour and child labour are not being used in its activities or business and supply chains
Annex B: Data tables
Note about the data tables: Respondents were allowed to select multiple responses for some questions in the online questionnaire, so totals may add up to more than 100%.
Table 1: Reports submitted by government institutions and entities
| Reports submitted | Entities | Government Institutions | Total |
|---|---|---|---|
| Count | 4,178 | 135 | 4,313 |
| Percentage | 96.9% | 3.1% | 100.0% |
Table 2a: Reports by entities subject to supply chain legislation in multiple jurisdictions
| Reports by entities subject to multiple legislation | Yes | No | No response |
|---|---|---|---|
| Count | 708 | 3,469 | 1 |
| Percentage | 16.9% | 83.0% | 0.0% |
Table 2b: Reports by entities subject to supply chain legislation in multiple jurisdictions
| (If "Yes") Other applicable legislation | Count | Percentage |
|---|---|---|
| United Kingdom's Modern Slavery Act 2015 | 499 | 70.5% |
| California's Transparency in Supply Chains Act (United States) | 433 | 61.2% |
| Australia's Modern Slavery Act 2018 | 280 | 39.5% |
| Other | 208 | 29.4% |
| Note: The percentages do not add up to 100% due to respondents being able to select multiple responses. | ||
Table 3: Entity location – Canada, United States and other countries
| Entity reports | Canada | United States | All others | Total others (all except Canada) |
|---|---|---|---|---|
| Count | 3,320 | 642 | 216 | 858 |
| Percentage | 79.5% | 15.4% | 5.2% | 20.5% |
Table 4: Identifying risks of forced labour and child labour in activities and supply chains
| Response to risk identification question | Year | Entities | Government Institutions | Total Organizations |
|---|---|---|---|---|
| We have identified risks/Started the process | 2025 | 3,485 (83.4%) | 64 (47.4%) | 3,549 (82.3%) |
| We have identified risks/Started the process | 2024 | 4,381 (77.6%) | 80 (55.2%) | 4,461 (77.0%) |
| Not started the process | 2025 | 692 (16.6%) | 71 (52.6%) | 763 (17.7%) |
| Not started the process | 2024 | 1,268 (22.4%) | 65 (44.8%) | 1,333 (23.0%) |
Table 5a: Aspects of activities and supply chains identified as being at risk of forced labour or child labour – Government institutions
| Aspect of activities and supply chains | Count | Percent |
|---|---|---|
| The types of products it sources | 33 | 51.6% |
| Tier two suppliers | 14 | 21.9% |
| Tier 1 (direct) suppliers | 13 | 20.3% |
| The sector or industry it operates in | 11 | 17.2% |
| Suppliers further down the supply chain than tier 3 | 11 | 15.6% |
| The raw materials or commodities used in its supply chains | 10 | 15.6% |
| Tier 3 suppliers | 10 | 15.6% |
| The use of outsourced, contracted or subcontracted labour | 8 | 12.5% |
| The use of forced labour | 8 | 12.5% |
| The use of child labour | 8 | 12.5% |
| The use of migrant labour | 4 | 6.3% |
| The locations of its activities, operations or factories | 3 | 4.7% |
| Note: The percentages do not add up to 100% due to respondents being able to select multiple responses. | ||
Table 5b: Aspects of activities and supply chains identified as being at risk of forced labour or child labour – Entities
| Aspect of activities and supply chains | Count | Percent |
|---|---|---|
| The raw materials or commodities used in its supply chains | 1,187 | 34.1% |
| The sector or industry it operates in | 1,059 | 30.4% |
| Tier 1 (direct) suppliers | 1,036 | 29.7% |
| The locations of its activities, operations or factories | 1,033 | 29.6% |
| The types of products it produces, or imports | 993 | 28.5% |
| The types of products it sources | 972 | 27.9% |
| Tier 2 suppliers | 699 | 20.1% |
| The use of outsourced, contracted or subcontracted labour | 584 | 16.8% |
| Tier 3 suppliers | 566 | 16.2% |
| Suppliers further down the supply chain than tier 3 | 526 | 15.1% |
| The use of migrant labour | 386 | 11.1% |
| The use of forced labour | 376 | 10.8% |
| The use of child labour | 352 | 10.1% |
| Note: The percentages do not add up to 100% due to respondents being able to select multiple responses. | ||
Table 6: Steps taken by organizations to prevent and reduce risks of forced labour or child labour
| Step taken to reduce risks of forced labour and child labour | Count | Percent |
|---|---|---|
| Embedding responsible business conduct into policies and management systems | 3,479 | 96.6% |
| Identifying and assessing potential and actual adverse impacts in operations, supply chains and business relationships | 1,794 | 49.8% |
| Ceasing, preventing or mitigating potential and actual adverse impacts | 1,233 | 34.3% |
| Tracking implementation and results | 1,055 | 29.3% |
| Providing for or cooperating in remediation when appropriate | 926 | 25.7% |
| Communicating how impacts are addressed | 825 | 22.9% |
| Note: The percentages do not add up to 100% due to respondents being able to select multiple responses. | ||
Table 7: Mandatory training provided by organizations
| Training provided | 2025 | 2024 | ||
|---|---|---|---|---|
| Count | Percent | Count | Percent | |
| Yes, the training is mandatory for all employees. | 996 | 37.8% | 999 | 39.5% |
| Yes, the training is mandatory for some employees. | 780 | 29.6% | 736 | 29.1% |
| Yes, the training is mandatory for employees making contracting or purchasing decisions. | 669 | 25.4% | 579 | 22.9% |
| No, the training is voluntary. | 191 | 7.2% | 217 | 8.6% |
| Not Applicable | 1 | 0.0% | 0Footnote * | 0.0% |
Table 8: Mandatory training provided by organizations, by top sectors
| Sector | Yes | |
|---|---|---|
| Count | Percent of total sector | |
| Manufacturing | 1,207 | 67.2% |
| Professional, scientific and technical services | 180 | 66.2% |
| Finance and insurance | 44 | 65.7% |
| Wholesale trade | 616 | 65.0% |
| Utilities | 72 | 64.9% |
| Administrative and support, waste management and remediation services | 25 | 64.1% |
| Retail trade | 470 | 63.9% |
| Transportation and warehousing | 235 | 63.5% |
| Other | 473 | 62.6% |
| Other services (except public administration) | 32 | 60.4% |
| Information and cultural industries | 32 | 58.2% |
| Mining, quarrying, and oil and gas extraction | 252 | 57.8% |
| Educational services | 49 | 57.0% |
| Accommodation and food services | 52 | 55.3% |
| Health care and social assistance | 63 | 55.3% |
| Food | 52 | 54.7% |
| Management of companies and enterprises | 62 | 54.4% |
| Real estate and rental and leasing | 61 | 52.6% |
| Agriculture, forestry, fishing and hunting | 176 | 51.8% |
| Public administration | 38 | 51.4% |
| Construction | 175 | 50.4% |
| Arts, entertainment and recreation | 26 | 44.1% |
Table 9: Methods used by organizations to assess their effectiveness in ensuring forced labour and child labour are not being used
| Method for assessing effectiveness | Count | Percent |
|---|---|---|
| Setting up a regular review or audit of the organization's policies and procedures related to forced labour and child labour | 1,638 | 75.9% |
| Tracking relevant performance indicators, such as levels of employee awareness, numbers of cases reported and solved through grievance mechanisms and numbers of contracts with anti-forced labour and -child labour clauses | 805 | 37.3% |
| Working with suppliers to measure the effectiveness of their actions to address forced labour and child labour, including by tracking relevant performance indicators | 787 | 36.5% |
| Partnering with an external organization to conduct an independent review or audit of the organization's actions | 515 | 23.9% |
| Not applicable | 3 | 0.1% |
Table 10: Measures taken to remediate instances of forced labour or child labour
| Remediation measure | Count | Percent |
|---|---|---|
| Actions to prevent forced labour or child labour and associated harms from reoccurring | 186 | 86.9% |
| Grievance mechanisms | 138 | 64.5% |
| Compensation for victims of forced labour or child labour and/or their families | 35 | 16.4% |
| Actions to support victims of forced labour or child labour and/or their families, such as workforce reintegration and psychosocial support | 24 | 11.2% |
| Formal apologies | 1 | 0.5% |
Table 11: Reporting organizations that have taken measures to remediate forced labour or child labour, by top sectors
| Sector | Yes | |
|---|---|---|
| Count | Percent of total sector | |
| Finance and insurance | 4 | 100.0% |
| Retail trade | 75 | 74.3% |
| Other | 44 | 73.3% |
| Transportation and warehousing | 21 | 70.0% |
| Professional, scientific and technical services | 15 | 68.2% |
| Information and cultural industries | 4 | 66.7% |
| Wholesale trade | 70 | 65.4% |
| Manufacturing | 104 | 63.0% |
| Management of companies and enterprises | 5 | 62.5% |
| Other services (except public administration) | 2 | 50.0% |
| Administrative and support, waste management and remediation services | 1 | 50.0% |
| Mining, quarrying, and oil and gas extraction | 9 | 45.0% |
| Oil and gas extraction | 9 | 45.0% |
| Food | 6 | 42.9% |
| Accommodation and food services | 6 | 42.9% |
| Utilities | 3 | 42.9% |
| Real estate and rental and leasing | 5 | 38.5% |
| Construction | 8 | 38.1% |
| Agriculture, forestry, fishing and hunting | 12 | 37.5% |
| Educational services | 3 | 23.1% |
| Health care and social assistance | 4 | 20.0% |
| Social assistance | 4 | 20.0% |
| Public administration | 2 | 20.0% |
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