Fighting Against Forced Labour and Child Labour in Supply Chains Act - 2023-24 Annual Report
PART 1: IDENTIFYING INFORMATION
Invest in Canada Hub (Invest in Canada, IIC)
April 1, 2023 to March 31, 2024
PART 2: REPORT CONTENTS
2.1 Information on the government institution’s structure, activities and supply chains
Which of the following accurately describes the government institution’s activities?
• Purchasing goods
◦ in Canada
If the government institution’s activities do not include any of the above, the government institution is not required to submit a report or complete the online questionnaire.
Provide additional information on the government institution’s structure, activities and supply chains.
Invest in Canada has a mandate to lead in the promotion, attraction, and facilitation of foreign direct investment (FDI) in Canada, and in the coordination of efforts across government entities, the private sector, and other stakeholders with respect to foreign direct investment in Canada. Its core responsibility is to lead the Government of Canada’s FDI attraction efforts by making Canada top-of mind for foreign investors and providing services in support of investor decisions to expand into Canada. Invest in Canada’s primary activities are promotion, investor services and providing support and intelligence to partners.
At Invest in Canada, approximately 1% of the annual value of purchases were made through the use of PSPC tools such as Standing Offers and Supply Arrangements.
Items like office chairs and desk converters are procured directly by Invest in Canada from suppliers that may be from a Standing Offer from the Government of Canada which means a competitive bidding process to select suppliers based on factors such as price, quality, and compliance with procurement regulations.
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 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.
Invest in Canada purchases goods, such as information technology (IT) equipment and other office supplies, to support the adequate function of its operations. With regard to its supply chain of purchased goods relating to IT, Invest in Canada is one of the government organizations that maintains its IT infrastructure through Shared Services Canada (SCC). SSC manages software licenses, hardware procurement, network services, and cybersecurity for Invest in Canada. This is included in the 1% of the annual value of our purchases as mentioned above. SSC negotiates vendor contracts for bulk deals to achieve cost savings and standardize technology solutions across government departments. Some other software licenses may be purchased directly through a supplier as only they can provide the services.
2.2 Information on the steps taken 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
Indicate steps taken in the 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.
• Other, please specify
SCC and its vendors are subject to the PSPC Code of Conduct for Procurement.
Note: Given the recent coming-into-force date of the Supply Chains Act, government institutions may not have measures to report on for some of the requirements. Government institutions may indicate in their report that no measures have been taken to remediate forced labour or child labour in their activities and supply chains, or that action plans have not yet been implemented, if that is the case. Doing so is sufficient to meet the government institution’s legal obligations.
2.3 Information on the policies and due diligence processes in relation to forced labour and child labour
Does the government institution currently have policies and due diligence processes in place related to forced labour and/or child labour? (Yes or No)
No, Invest in Canada has integrated the Code of Conduct for Procurement into procurements. 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.
Pursuant to the aforementioned amendments, Invest in Canada has integrated the Code into our procurements, with a view to safeguarding federal procurement supply chains from forced labour and child labour. Contracts that our organization have awarded included the Code through the General Conditions for goods.
The Code requires that vendors, providing goods and services 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.
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.
2.4 Information on the parts of its activities and supply chains that carry a risk of forced labour or child labour being used and the steps taken to assess and manage that risk
Has the government institution identified the parts of its activities and supply chains that carry a risk of forced labour or child labour being used?
• Yes, we have identified risks to the best of our knowledge and will continue to strive to identify emerging risks.
Invest in Canada did not identify any parts of its activities and supply chains that carry a risk of forced labour or child labour being used.
Has the 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
None of the above
2.5 Information on any measures taken to remediate any forced labour or child labour
Has the government institution taken any measures to remediate any forced labour or child labour in its activities and supply chains?
Not applicable, we have not identified any forced labour or child labour in our activities and supply chains.
2.6 Information on 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 the institution’s activities and supply chains
Has the government institution 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?
Not applicable, we have 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.
2.7 Information on the training provided to employees on forced labour and child labour
Does the government institution currently provide training to employees on forced labour and/or child labour? (Y/N)
• No.
Invest in Canada is aware that PSPC is currently developing awareness-raising guidance materials (including risk mitigation strategies) for suppliers, targeted towards high-risk sectors. We are monitoring the development of these materials and will leverage these resources upon their publication.
2.8 Information on how the government institution assesses its effectiveness in ensuring that forced labour and child labour are not being used in its activities and supply chains
Does the government institution 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? (Yes or No)
No.