2025-2026 Annual Report under the Fighting Against Forced Labour and Child Labour in Supply Chains Act

1. Structure, Activities and Supply Chains

The Canada Energy Regulator (CER) is a departmental corporation and agent of the Crown established under the Canadian Energy Regulator Act. Its mandate is to regulate energy infrastructure to ensure safe and efficient energy delivery, protect people and the environment, respect Indigenous rights, and provide energy information to Canadians.

The CER’s procurement activity consists primarily of purchasing goods in Canada. Key categories include:

  • IT hardware and software
  • Data subscriptions
  • Office furniture and supplies

Approximately 93% of the CER’s goods procurement is conducted through Public Services and Procurement Canada (PSPC) and Shared Services Canada (SSC) tools, including Standing Offers and Supply Arrangements. The remaining procurement is conducted under the CER’s own contracting authority using PSPC solicitation and contract templates.

2. Steps to Prevent and Reduce Risk

The CER takes a layered approach to reducing the risk of forced labour and child labour in its supply chains, primarily through the use of government-wide contracting tools and clauses.

PSPC and SSC tools (covering ~93% of goods spend):

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

Since November 2021, PSPC has included anti-forced labour clauses in all goods contracts, enabling contract termination where credible evidence exists that goods were produced using forced labour or human trafficking. Since November 20, 2023, all PSPC and SSC Standing Offers and Supply Arrangements that are new, amended, or refreshed include these clauses as part of the General Conditions for goods.

Under the CER’s own procurement authority (covering the remaining ~7% of goods spend), the CER uses PSPC solicitation and contract templates, which incorporate the same anti-forced labour requirements.

PSPC has developed awareness-raising guidance materials, including risk mitigation strategies, for suppliers targeting high-risk sectors. These materials are being made available progressively on Canada.ca. The CER refers its procurement personnel to these materials and uses them to guide supplier expectations.

3. Policies and Due Diligence Processes

The CER incorporates the Code of Conduct for Procurement into all applicable contracts. This is consistent with the requirements of the April 1, 2023 amendments to the Treasury Board Directive on the Management of Procurement, which require contracting authorities listed under Schedules I, I.1, and II of the Financial Administration Act to integrate the Code.

The Code requires that vendors and their subcontractors:

  • Comply with all applicable laws and regulations
  • Comply with Canada’s prohibition on importing goods produced, in whole or in part, by forced or compulsory labour (including child labour), regardless of country of origin

This prohibition has been in force under the Customs Tariff since July 1, 2020, implementing Canada’s commitment under the Labour Chapter of the Canada–United States–Mexico Agreement (CUSMA).

For contracts exceeding $10,000 under the CER’s own procurement authority, vendor integrity is assessed using PSPC Integrity Regime tools. The CER does not maintain additional standalone forced labour policies beyond these Government of Canada frameworks.

4. Risk Identification in Activities and Supply Chains

The CER is in the early stages of supply chain risk identification and relies substantially on government-wide analysis to inform its approach.

In May 2021, Rights Lab at the University of Nottingham completed a risk analysis of PSPC’s supply chains to identify goods at highest risk of exposure to human trafficking, forced labour, and child labour. The CER has reviewed this analysis and is monitoring related follow-up actions, including PSPC’s development of a Policy on Ethical Procurement and a human rights due diligence framework.

The CER has not independently identified specific forced labour or child labour risks within its own activities and supply chains. Given the nature of the CER’s procurement (predominantly commercial off-the-shelf goods purchased through PSPC/SSC tools), the CER considers its exposure to be comparatively limited. However, the CER acknowledges that risks may exist in upstream supply chains for categories such as IT hardware.

Remediation Measures

The CER has not identified instances of forced labour or child labour in its activities or supply chains during the 2025–2026 reporting period. Accordingly, no remediation measures were taken and no vulnerable families were identified as experiencing income loss as a result of CER procurement actions.

Contractual safeguards are in place through PSPC and SSC anti-forced labour clauses, which include the right to terminate contracts where credible evidence of forced labour is found. Should instances be identified in the future, the CER will act in accordance with applicable Government of Canada guidance and processes established by PSPC and the Treasury Board of Canada Secretariat (TBS).

6. Employee Training

The CER does not currently deliver dedicated training on forced labour or child labour. Procurement personnel have access to the Procurement Fundamentals course offered by the Canada School of Public Service, which supports responsible purchasing decisions.

PSPC is currently piloting a procurement-specific course on forced labour for procurement officers across the Government of Canada. The CER intends to leverage this course for its procurement staff upon publication.

The CER subscribes to Public Safety Canada’s Supply Chains Act Bulletin for ongoing updates.

7. Assessing Effectiveness

The CER does not currently have internal policies or procedures to independently assess the effectiveness of its efforts to prevent forced labour and child labour in its supply chains. The CER relies on PSPC and SSC mechanisms, including the anti-forced labour contract clauses and the Code of Conduct for Procurement, as the primary means of managing this risk.

The CER will monitor Government of Canada frameworks as they mature and will align its practices accordingly, including any effectiveness assessment tools developed by PSPC or TBS for government-wide use.

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