Natural Resources Canada Forced Labour and Supply Chain Integrity Report – Fiscal Year 2025-2026

Part 1: Submission Information

Reporting government institution's name: This report is submitted on behalf of Natural Resources Canada (NRCan).

Financial reporting year: The report covers activities from April 1, 2025, to March 31, 2026.

Whether the report is submitted on behalf of a federal Crown corporation: Not applicable

Whether it is submitted on behalf of a wholly owned subsidiary: Not applicable

Sector/industry: Not applicable

Part 2: Annual Report

Description of the government institution’s 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.

Structure refers to the government institution's legal and organizational form. When reporting on structure, government institutions may include the following details:

  • Organizational structure (i.e., departmentation, chain of command, etc.)
  • Organizational mandate or role
  • Number of employees, both in Canada and outside Canada

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 2025-2026, 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:

  • 34% of NRCan’s contracts are under GSIN N66 Instruments and Laboratory Equipment (Goods).
  • 29% of NRCan’s contracts are under GSIN N70 General Purpose Automatic Data Processing, Equipment (including Firmware), Software, Supplies and Support Equipment.
  • 9% of NRCan’s contracts are under GSIN N99 Miscellaneous Goods.
  • 3% of NRCan’s contracts are under GSIN N44 Furnaces, Steam Plant, and Drying Equipment and Nuclear Reactors.
  • 3% of NRCan’s contracts are under GSIN N58 Communication, Detection, and Coherent Radiation Equipment.
  • 3% of NRCan’s contracts are under GSIN N30 Mechanical Power Transmission Equipment.
  • 2% of NRCan’s contracts are under GSIN N23 Ground Effect Vehicles, Motor Vehicles, Trailers, and Cycles.
  • 2% of NRCan’s contracts are under GSIN N45 Plumbing, Heating and Sanitation Equipment.
  • 2% of NRCan’s contracts are under GSIN N71 Furniture.
  • 2% of NRCan’s contracts are under GSIN N34 Metalworking Machinery.
  • 2% of NRCan’s contracts are under GSIN N91 Fuels, Lubricants, Oils and Waxes.
  • 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 2025-2026, there was a total of 1411 contracts for goods procured for or by NRCan.

Are these goods sourced from inside or outside Canada?

NRCan is unable to determine if the goods purchased from contractors are originally sourced from inside or outside of Canada.

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 $36.8 million in goods requirements for fiscal year 2025-2026. Of that, ≈ 85% of the $36.8M was procured via Public Services and Procurement Canada (PSPC) or Shared Services Canada (SSC) call ups against standing offers, contracts against supply arrangements or contracts issued on behalf of NRCan, while ≈ 15% of NRCan’s purchases of goods in fiscal year 2025-2026 were procured under its own authority.

Under what authority were goods procured?

During this reporting period we purchased goods under our own procurement authority in the following instances:

Table 1
GSIN Group GSIN Group Title
N23 Ground Effect Vehicles, Motor Vehicles, Trailers, and Cycles
N25 Vehicular Equipment Components
N29 Engine Accessories
N30 Mechanical Power Transmission Equipment
N34 Metalworking Machinery
N35 Service and Trade Equipment
N36 Special Industry Machinery
N37 Agriculture Machinery and Equipment
N38 Construction, Mining, Excavating and Highway Maintenance Equipment
N39 Materials Handling Equipment
N41 Refrigeration, Air Conditioning, and air Circulating Equipment
N42 Fire Fighting, Rescue, and Safety Equipment; and Environmental Protection Equipment and materials
N43 Pumps and Compressors
N44 Furnaces, Steam Plant, and Drying Equipment and Nuclear Reactors
N45 Plumbing, Heating, and Sanitation Equipment
N46 Water Purification and Sewage Treatment Equipment
N47 Pipe, Tubing, Hose and Fittings
N48 Valves
N49 Maintenance and Repair Shop Equipment
N51 Hand Tools
N52 Measuring Tools
N53 Hardware and Abrasives
N55 Lumber, Millwork, Plywood and Veneer
N56 Construction and Building Materials
N58 Communication, Detection, and Coherent Radiation Equipment
N59 Electrical and Electronic Equipment Components
N61 Electric Wire and Power and Distribution Equipment
N62 Lighting Fixtures and Lampos
N63 Alarm, Signal and Security Detection Systems
N65 Medical, Dental, and Veterinary Equipment and Supplies
N66 Instruments and Laboratory Equipment
N67 Photographic Equipment
N68 Chemicals and Chemical Products
N69 Training Aids and Devices
N70 General Purpose Automatic Data Processing Equipment (Including Firmware), Software, Supplies and Support Equipment
N71 Furniture
N72 Household and Commercial Furnishings and Appliances.
N73 Food Preparation and Serving Equipment
N74 Office Machines, Text Processing Systems and Visible Record Equipment
N75 Office Supplies and Devices
N76 Books, Maps and Other Publications
N79 Cleaning Equipment and Supplies
N81 Containers, Packaging and Packing Supplies
N83 Textiles, Leather, Furs, Apparel and Shoe Findings, Tents and Flags
N84 Clothing, Individual Equipment and Insignia
N87 Agriculture Supplies
N89 Subsistence
N91 Fuels, Lubricants, Oils and Waxes
N93 Non-metallic Fabricated Materials
N94 Non-metallic Crude Materials
N96 Ores, Minerals, and Their Primary Products
N99 Miscellaneous

At NRCan approximately 22% 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 add a requirement for contractors to not deliver or sell goods to Canada manufactured wholly or in part by forced labour. The clauses ensure that Canada 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. The buyer portal provide guidance about anti-forced labor requirements: Anti-forced labour requirements | CanadaBuys.

At NRCan, approximately 6% of the annual value of our purchases were made through the use of 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

Government institutions should describe the steps taken to prevent and reduce risks of forced labour and child labour in their supply chains.

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
  • In addition, NRCan uses PSPC standard clauses in our contracts

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 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 through the General Conditions for goods.

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 2025-2026, NRCan purchased goods under its own departmental procurement authority (outside of tools put in place by PSPC or SSC) representing roughly $5.4 million of overall goods purchases as listed in Table 1 based on the Goods and Services Identification Number (GSIN) identified in the Purchase Order.

Of the purchases made under NRCan’s authority, only 4% ($217.6) 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

Government institutions should describe the policies and/or due diligence processes in place related to forced labour and/or child labour.

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

Government institutions should describe whether they have identified parts of their activities and supply chains that carry risk, and explain their assessment process.

1. State whether risks have been identified

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.

2. Identify the activities and supply chains that carry 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 any particular sectors and/or industries were identified as having risks of forced labour or child labour. For example, 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 remediation measures have been taken, describe the actions implemented:

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.

PSPC has developed an online self-paced course for procurement officers titled “Introduction to Ethical Procurement". The course is available to federal public servants on the Canada School of Public Service’s learning platform as of November 2025. All the Purchasing Group employees from NRCan have completed this course. NRCan recommends that Purchasing Group (PG) employees, take the course within one year of being hired.

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.

 
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