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

Submission information

This report is submitted on behalf of the Office of the Superintendent of Financial Institutions (OSFI) for the 2026 reporting period and covers the period from April 1, 2025, to March 31, 2026.

Annual report

This report describes the measures that OSFI has taken during the reporting period to prevent and reduce risks that forced labour or child labour is used in its activities or supply chains.

a) Structure, activities and supply chains

OSFI was established in 1987 under the Office of the Superintendent of Financial Institutions Act. It is an independent agency of the Government of Canada and reports to Parliament through the Minister of Finance.

OSFI supervises and regulates banks and federal credit unions in Canada and all federally incorporated or registered trust and loan companies, insurance companies, fraternal benefit societies and private pension plans. The Superintendent is responsible for exercising OSFI’s statutory authorities and is required to report to the Minister of Finance on the administration of federal financial institutions’ legislation.

The Office of the Chief Actuary (OCA), which is an independent unit within OSFI, provides actuarial valuation and advisory services for the Canada Pension Plan, the Old Age Security program, the Canada Student Financial Assistance and Employment Insurance Programs and other public sector pension and benefit plans.

OSFI’s activities include purchasing goods in Canada and outside of Canada. In 2025-2026, OSFI’s procured approximately $16.3M of goods which consisted primarily of IT hardware, software and furniture.

Approximately 99% of OSFI’s goods purchases was conducted using Public Services and Procurement Canada (PSPC) and Shared Services Canada (SSC) tools such as standing offers and supply arrangements, and contracts where PSPC or SSC acted as the contracting authority. Accordingly, all of our contracts for goods include clauses relating to forced labour that establish human rights and labour rights requirements. These clauses can be found in the policy notification 150 – Anti-forced labour requirements.

b) Steps taken to prevent and reduce risks of forced labour and child labour

OSFI has implemented the following measures to mitigate risks:

• Reliance on PSPC and SSC procurement instruments, which incorporate anti–forced labour safeguards
• Application of anti–forced labour contractual clauses through PSPC and SSC agreements
• Integration of PSPC’s General Conditions for goods contracts and the Code of Conduct for Procurement

OSFI prioritizes the use of federal procurement tools as a key risk mitigation strategy, ensuring alignment with government-wide due diligence practices.

While OSFI has limited independent procurement activity, it applies equivalent requirements—including contractual safeguards and ethical procurement standards—to procurements conducted under its own authority.

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

OSFI integrates responsible business conduct into our procurement policies and practices.

Effective April 1, 2023, OSFI implemented the Treasury Board Directive requiring the incorporation of the Code of Conduct for Procurement (“the Code”) into all procurements with a view to safeguarding federal procurement supply chains from forced labour and child labour.

The Code requires that vendors 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 labour, including child labour.

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.

OSFI incorporates the Code into contracts through standard terms and conditions, reinforcing supply chain accountability.

d) 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

OSFI has initiated risk identification activities focused on the types of goods it procures.

Given that the majority of procurement is conducted through PSPC and SSC, OSFI is reliant on these departments’ supply chain risk assessments and mitigation measures.

OSFI has reviewed findings from PSPC’s 2021 supply chain risk analysis completed by Rights Lab (University of Nottingham), which identified high-risk sectors and provided strategies to address forced labour risk.

OSFI continues to monitor federal initiatives, including the development of an Ethical Procurement Policy.

Based on its current assessment, OSFI has not identified specific instances or high-risk exposures within its own activities and supply chains.

e) Measures taken to remediate any forced labour or child labour

OSFI has not identified any instances of forced labour or child labour in its activities and supply chains during the reporting period. As a preventive measure, OSFI ensures that all contracts incorporate the Code of Conduct for Procurement which includes a section on human rights and labour standards and supports remediation through contractual enforcement where required.

f) 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

OSFI 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. Accordingly, no remediation measures were required during the reporting period.

g) Training provided to employees on forced labour and child labour

OSFI does not currently provide dedicated internal training to employees on forced labour and/or child labour risks.

However, OSFI is leveraging federal training initiatives. PSPC has developed the course “Introduction to Ethical Procurement", available through the Canada School of Public Service’s since November 2025. OSFI plans to require all procurement personnel to complete this training during the 2026–2027 fiscal year to strengthen internal awareness and capacity.

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

OSFI assesses its effectiveness through the reliance on federally managed procurement instruments and the proportion of good acquired through them.

During the reporting period:

• Approximately 99% of goods procurement was conducted through PSPC and SSC tools
• These tools incorporate standardized safeguards against forced and child labour

For procurements conducted outside these tools, OSFI applies equivalent contractual provisions, including the Code of Conduct for Procurement and updated general conditions.

This dual approach—leveraging centralized procurement controls while applying consistent internal standards—supports OSFI’s confidence in the effectiveness of its measures to mitigate forced labour and child labour risks.