Natural Resources Canada Forced Labour and Supply Chain Integrity Report – Fiscal Year 2024-2025

Part 1: Submission Information

Name of government institution: This report is submitted on behalf of Natural Resources Canada (NRCan) and covers activities from April 1, 2024, to March 31, 2025.

Reporting Period: 2025 reporting period (May 31, 2025, deadline).

Indicate if this is a report produced by a federal Crown corporation or a subsidiary of a federal Crown corporation: Not applicable

Part 2: Annual Report

Structure, activities and supply chains

Indicate which of the following describes your government institution’s structure:

  • Federal department or agency
  • parent Crown corporation
  • wholly owned subsidiary
  • other institution, body or office listed in Schedule I of the Access to Information Act

NRCan is a federal department.

Describe how your government institution engages in the following activities:

  • Producing goods (including manufacturing, extracting, growing and processing)
  • Purchasing goods
  • Distributing goods

NRCan purchases goods in and outside of Canada.

What are the main types of goods the government institution produces, purchases or distributes (e.g., professional services, office furniture, IT equipment, etc.)?

During fiscal year 2024-2025, the main type of goods procured for or by NRCan are as listed below based on the Goods and Services Code (GSIN) identified in the Purchase Order:

  • 36 % of NRCan’s contracts are under GSIN N66 Instruments and Laboratory Equipment (Goods).
  • 31% of NRCan’s contracts are under GSIN N70 General Purpose Automatic Data Processing. Equipment (including Firmware), Software, Supplies and Support Equipment.
  • 7% of NRCan’s contracts are under GSIN N99 Miscellaneous Goods.
  • 7% of NRCan’s contracts are under GSIN N61 Electric Wire and Power and Distribution Equipment.
  • 3% of NRCan’s contracts are under GSIN N23 Ground Effect Vehicles, Motor Vehicles, Trailers, and Cycles.
  • 2% of NRCan’s contracts are under GSIN N58 Communication, Detection, and Coherent Radiation Equipment.
  • 2% of NRCan’s contracts are under GSIN N71 Furniture.
  • The remaining 12% of NRCan’s purchases are individually insignificant and have not been broken out for brevity.

In what volumes does the government institution produce, purchase or distribute these goods?

During fiscal year 2024-2025, there was a total of 1224 contracts for goods procured for or by NRCan.

What is the total number or value of contracts awarded within the previous financial year, and/or the total cost of goods produced, purchased or distributed?

NRCan procured $46.2 million in goods requirements for fiscal year 2024-2025. Of that, ≈ 88% was procured via PSPC or Shared Services Canada (call ups against standing offers, contracts against supply arrangements or contracts issued on behalf of NRCan), while ≈ 12% of NRCan’s purchases of goods in fiscal year 2024-2025 were procured under its own authority.

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

NRCan works to improve the quality of life of Canadians by ensuring that our natural resources are developed sustainably, providing a source of jobs, prosperity and opportunity, while preserving our environment and respecting our communities and Indigenous peoples. (source: Raison d’être, mandate and role: who we are and what we do).

The structure of NRCan includes 12 sectors and has offices and laboratories across the country. About 70% of employees are located in the National Capital Region, with the remainder working in regional offices: Atlantic Canada, Quebec, Ontario, the Western and Pacific Regions and Northern Canada.

NRCan’s mandate is as follows: The Minister of Natural Resources has responsibilities in relation to more than 30 acts of Parliament. The Minister’s core powers, duties and functions are set forth in the Department of Natural Resources Act, the Resources and Technical Surveys Act, and the Forestry Act. Other Acts set out the terms for the management of resources in Federal Crown lands and of Canada’s natural resource policies.

The Department also works in areas of shared responsibilities with provinces, which includes the environment, public safety, economic development, science and technology, and consultations with Indigenous peoples. To fulfil its responsibilities, NRCan relies on a number of instruments (e.g., legislation, policy, regulation, statutory transfers, grants and contributions) and key activities (e.g., science and technology, partnerships and communications). (source)

At NRCan, approximately 65% of the annual value of our purchases were made through the use of PSPC 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 our contracts for goods resulting from the use of these tools include clauses relating 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.

At NRCan, approximately 23% of the annual value of our purchases were made through the use of Shared Services Canada (SSC) tools such as Standing Offers and Supply Arrangements.

Since November 2021, SSC has 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. Furthermore, as of November 20, 2023, all SSC Standing Offers and Supply Arrangements that have been issued, amended, or refreshed include anti-forced labour clauses as part of the general conditions for goods.

As such, all of our contracts for goods resulting from the use of SSC’s tools include PSPC’s clauses relating to forced labour, which outline, among other things, human rights and labour rights requirements.

Steps to prevent and reduce risks of forced labour and child labour

Describe the steps your government institution has taken in 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.

NRCan has integrated PSPC’s Standard Contract Clauses including PSPC’s Code of Conduct for Procurement and anti-forced labour clauses in our purchasing activities.

In addition, to prevent and reduce the risk of forced labour or child labour in our procurements, NRCan has used the following list of PSPC’s tools:

  • Standing Offers
  • Supply Arrangements
  • Anti-forced labour contract clauses

PSPC has developed awareness-raising guidance materials (including risk mitigation strategies) for suppliers, targeted towards high-risk sectors. The materials are progressively becoming available on the canada.ca website.

NRCan has used PSPC’s awareness materials to guide our suppliers and safeguard our supply chains from forced labour and child labour.

Furthermore, we are referring our procurement personnel to these materials for awareness.

The April 1, 2023 amendments to the Treasury Board Directive on the Management of Procurement required several contracting authorities to incorporate the Code of Conduct for Procurement (“the Code”) into their procurements. In compliance with these amendments, SSC has integrated the Code into its procurements.

To prevent and reduce the risk of forced labour or child labour in our procurements, NRCan has used the following list of SSC’s tools to which the Code applies:

  • Standing Offers
  • Supply Arrangements
  • Contracts

As a common service provider, SSC is responsible for ensuring that government departments have access to reliable, secure, and cost-effective IT infrastructure and solutions, including shared services related to networks and network security, data centres and Cloud offerings, digital communications, and IT tools.

NRCan also undertakes activities under its own procurement authority, independently of the aforementioned SSC tools.

During fiscal year 2024-2025, NRCan purchased goods under its own departmental procurement authority (outside of tools put in place by PSPC or SSC) representing roughly $5.9 million of overall goods purchases as listed below based on the Goods and Services Identification Number (GSIN) identified in the Purchase Order:

  • ADP central processing unit (CPU, computer) analog
  • ADP central processing unit (CPU, computer) digital
  • ADP central processing unit (CPU, computer) hybrid
  • ADP components
  • ADP input-output and storage devices
  • ADP software
  • ADP support equipment
  • Advertising displays
  • Analyzers, gas (includes NOx, co, co2, so2, o2) excludes hazard type
  • Antennas, waveguides and related equipment
  • Automatic data processing equipment, system configuration
  • Aviation fuel
  • Batteries, primary
  • Batteries, rechargeable
  • Books (printing products publications)
  • Books and pamphlets
  • Boots, safety
  • Box, shipping
  • Boxes, cartons and crates
  • Buildings, prefabricated, metal
  • Cabinets, laboratory storage (includes wood, metal, plastic)
  • Cabinets, lockers, bins and shelving
  • Cabinets, security, flammable and combustible liquids
  • Calibration and test specimens
  • Cameras, motion picture, aircraft cameras and accessories
  • Chemical analysis instruments
  • Chemicals
  • Chemicals and chemical products
  • Cleaning Equipment and Supplies
  • Collectors’ items
  • Combination and miscellaneous instruments
  • Communications security equipment and components
  • Computer software for technology assisted training
  • Computer software, acquisition/processing of analog/digital, signals (audio, video, seismic, etc.) incl. mach. vision, voice recogn. Inst. signals, robotics, num. mach. cont. etc.-other than microcomputer
  • Computer software, building construction, facility/property management - other than microcomputers
  • Computer software, data communications, including modem/line control, protocol, conversion, terminal emulation, voice and or data network management, etc.- other than microcomputers
  • Computer software, engineering, scientific, mathematical, statistical, modeling, simulation, emulation, energy - microcomputers only
  • Computer software, engineering, scientific, mathematical, statistical, modeling, simulation, emulation, energy - other than microcomputers
  • Computer software, laboratory and scientific
  • Computer software, library systems, records management, cataloguing, correspondence control - other than microcomputers
  • Computer software, materiel management, inventory control - microcomputers only
  • Computer software, materiel management, inventory control - other than microcomputers
  • Computer software, other (not elsewhere listed) - microcomputers only
  • Computers, micro, laptops
  • Construction and building materials
  • Containers, cargo handling, metal non-refrigerated (for container shipping method)
  • Control Panels, Electric, Electronic, Hydraulic and Pneumatic
  • Converters, electrical, nonrotating
  • Data loggers
  • Diesel engines and components, not elsewhere specified, marine
  • Doors, steel
  • Drafting, surveying and mapping instruments
  • Drawings and specifications
  • Drums and cans
  • Electrical hardware and supplies
  • Electrical work
  • Environmental chambers and related equipment
  • Fencing, fences, gates and components
  • Filter
  • First aid kit, general purpose
  • Floats – marine
  • Floor polishers and vacuum cleaning equipment
  • Footwear, men's
  • Fuel cell power units, components, and accessories
  • Fuels, lubricants,
  • Furniture
  • Gas, nitrogen
  • Gas, propane
  • Gases, compressed and liquified
  • Generators and generator sets, electrical
  • Groceries, miscellaneous
  • Hand tools
  • Hardware, commercial
  • Headsets, handsets, microphones and speakers
  • Heating and air circulating ductwork and accessories
  • Inspection gages and precision layout tools
  • Instruments and controls, sewage treatment plants
  • Instruments and Laboratory Equipment
  • Laboratory equipment and supplies
  • Laundry and dry-cleaning equipment
  • Laundry supplies (not elsewhere specified.)
  • Liquid and gas flow, liquid level and mechanical motion measuring instruments
  • Live animals
  • Maintenance and Repair Shop Equipment
  • Marker, cone shape, magnetic base
  • Materials handling equipment, miscellaneous
  • Medical, Dental, and Veterinary Equipment and Supplies
  • Metal screening
  • Milling machines
  • Mini and microcomputer control devices
  • Miscellaneous battery retaining fixtures, liners and ancillary items
  • Miscellaneous items
  • Miscellaneous office machines
  • Motor vehicle maintenance and repair shop specialized equipment
  • Motorcycles, motor scooters and bicycles
  • Office devices and accessories
  • Office furniture
  • Office supplies
  • Office supplies and Devices
  • Optical instruments, test equipment, components and accessories
  • Packing materials, all types (except spec and aircraft)
  • Photocopying machines and accessories
  • Photographic equipment and accessories
  • Physical properties testing equipment
  • Planters
  • Plaques
  • Plotters, autographic instrument
  • Plumbing contractor services
  • Pressure, temperature and humidity measuring and controlling instruments
  • Printers, page, laser
  • Pumps and compressors
  • Punching and shearing machines
  • Radio transceivers and transmitter - receiver, ultra-high frequency (except airborne)
  • Refrigeration equipment
  • Remote monitoring and control systems, radar equipment, except airborne
  • Road clearing and cleaning equipment
  • Rolling mills and drawing machines
  • Safety and rescue equipment
  • Satellite navigation equipment (except airborne)
  • Scales and balances
  • Service and Trade Equipment
  • Sets, kits, and outfits of hand tools
  • Ship and marine miscellaneous equipment
  • Space and water heating equipment
  • Stands, audio visual projectors
  • Stone, crushed (quarry rock)
  • Storage and memory devices, militarized, ruggedized
  • Storage devices, add in memory, electronic data processing
  • Surveying equipment or instruments
  • Telephone systems, sound powered
  • Thermocouples, all types
  • Toiletry paper products
  • Toner, cartridge, virgin, for various types of printers and facsimile machines
  • Tradesman and special tasks tools
  • Trailers
  • Valves
  • Vehicle accessory, box cap for light trucks (fiberglass or aluminum)
  • Vehicles, all terrain, ATV, wheeled (except military configuration)
  • Vehicular equipment Components
  • Waste disposal equipment

Of the purchases made under NRCan’s authority, only 2.47% ($145.1K) were purchased against the top ten GSIN codes identified by PSPC at highest risk of human trafficking, forced labour, and child labour.

Policies and due diligence processes in relation to forced labour and child labour

Indicate whether your government institution has policies and/or due diligence processes in place related to forced labour and/or child labour and, if applicable, describe these policies and/or processes.

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.

The Code requires that vendors, providing goods 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.

Pursuant to the aforementioned amendments, NRCan has continued to integrate the Code into our procurements, with a view to safeguarding federal procurement supply chains from forced labour and child labour. Contracts that our organization has awarded included the Code through the General Conditions for goods.

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.

Identifying parts of your institution’s activities and supply chains that carry a risk of forced labour or child labour being used and the steps taken to assess and manage those risks

Indicate in your report whether your government institution has identified the parts of its activities and supply chains that carry a risk of forced labour or child labour being used.

NRCan has not started the process of identifying risks for procurements issued under its own authority, outside of the available PSPC or SSC standing offers and supply arrangements.

NRCan procures much of its goods via PSPC standing offers, SSC Standing Offers, PSPC issued contracts on behalf of NRCan, and SSC issued contracts on behalf of NRCan, therefore NRCan is reliant on central agencies to identify the parts of the activities and supply chains that carry a risk of forced labour or child labour being used.

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.

We took note of the findings and recommendations of this risk analysis, and are monitoring related follow-action, including the implementation of the Policy on Ethical Procurement and the development of a human rights due diligence framework.

SSC is committed to ongoing risk identification, promotion and development of mitigation practices, and ongoing activities to raise awareness within its procurement community and engage with industry and strategic partners.

Indicate the aspects of your activities and/or supply chains that have been identified as carrying forced labour or child labour risks.

NRCan has not identified any forced labour or child labour in our activities and supply chains; and NRCan references the Code of Conduct for Procurement in all its contracts which includes a section on human rights and labour standards.

Indicate whether your government institution identified forced labour or child labour risks in its activities and supply chains related to any of the following sectors and industries:

  • Agriculture, forestry, fishing and hunting
  • Mining, quarrying, and oil and gas extraction
  • Utilities
  • Construction
  • Manufacturing
  • Wholesale trade
  • Retail trade
  • Transportation and warehousing
  • Information and cultural industries
  • Finance and insurance
  • Real estate and rental and leasing
  • Professional, scientific and technical services
  • Management of companies and enterprises
  • Administrative and support, waste management and remediation services
  • Educational services
  • Health care and social assistance
  • Arts, entertainment and recreation
  • Accommodation and food services
  • Other services (except public administration)
  • Public administration
  • None of the above
  • Other, please specify

NRCan has not identified any forced labour or child labour in our activities and supply chains; however, NRCan includes incorporation by reference to the Code of Conduct for Procurement in all its resulting contracts which includes a section on human rights and labour standards.

Measures taken to remediate any forced labour or child labour

Indicate whether your government institution has taken any measures to remediate any forced labour or child labour in its activities and supply chains.

No, NRCan has not yet identified any forced labour or child labour in our activities and supply chains.

If you have taken remediation measures, describe them.

NRCan has not identified any forced labour or child labour in our activities and supply chains; however, NRCan includes incorporation by reference to the Code of Conduct for Procurement in all its resulting contracts which includes a section on human rights and labour standards.

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

Indicate in your report whether your government institution has 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.

NRCan has not identified any loss of income to vulnerable families resulting from measures taken to eliminate the use of forced labour or child labour in our activities and supply chains.

If applicable, describe any measures the government institution has 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.

Not applicable.

Training provided to employees on forced labour and child labour

Indicate whether your government institution currently provides training to employees on forced labour and/or child labour.

We are aware that PSPC has developed and is currently piloting a course for procurement officers. We will leverage the course upon its publication for use across the Government of Canada.

SSC is committed to ongoing risk identification, promotion and development of mitigation practices, and ongoing activities to raise awareness within its procurement community and engage with industry and strategic partners.

Assessing effectiveness in ensuring that forced labour and child labour are not being used in activities and supply chains

Indicate whether your government institution currently has 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. If applicable, describe the methods used by your government institution to assess its effectiveness.

NRCan does not 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.

NRCan procures much of its goods via PSPC standing offers, SSC Standing Offers, PSPC issued contracts on behalf of NRCan, and SSC issued contracts on behalf of NRCan, therefore NRCan is reliant on central agencies to identify the parts of the activities and supply chains that carry a risk of forced labour or child labour being used.