Unclassified
Report pursuant to the Fighting Against Forced Labour and Child Labour in Supply Chains Act, SC 2023, c 9 for the fiscal year 2025-2026
Actions Taken in 2025-2026
In 2025–2026, CATSA further embedded child labour and forced labour considerations into its Third Party Risk Management (TPRM) Framework by introducing an explicit forced labour / child labour risk consideration within the Compliance risk category of its standardized TPRM Checklist, to be applied during procurement planning and risk assessment activities.
Structure, Activities, and Supply Chains
CATSA is a parent Crown corporation listed on Schedule III of the Financial Administration Act. CATSA’s mandate is to take actions, either directly or through a screening contractor, for the effective and efficient screening of persons who access aircraft or restricted areas through screening points, the property in their possession or control and the belongings or baggage that they give to an air carrier for transport. CATSA delivers the mandate of security screening at 89 designated airports across the country through a third-party screening contractor model. CATSA is governed by a Board of Directors with its operations directed by a Senior Management Team.
In support of its mandate, CATSA publicly tenders most of its requirements for goods and/or services, which generally consists of commercially available finished goods and professional services. These requirements may include: office administration needs (e.g., office supplies, furniture, audio visual equipment, etc.), information technology infrastructure (e.g., networking equipment, data centre equipment, end user computing hardware and software, etc.), specialized security screening equipment (e.g. explosive detection systems, metal detectors, security cameras), and front line operations tools (e.g., uniforms, personal protective equipment, access and identification systems, etc.). CATSA does not manufacture or produce any goods, and its supply chain therefore does not include the sourcing or storage of any raw materials.
Policies and Due Diligence Processes
CATSA has embedded responsible business conduct into policies and management systems through the Contractor Code of Conduct.
This Contractor Code of Conduct, which is mandatory for all entities with whom CATSA does business, requires, among other things, that “Contractors must ensure that, in their workplaces […] forced/compulsory labour and child labour are not used […]”. Additionally, CATSA is beginning to implement more stringent terms in its contracts with suppliers who are deemed to be “higher risk” in relation to the possibility of forced/compulsory labour or child labour existing in their labour or supply chain.
These requirements are complemented by CATSA’s TPRM Framework, which includes structured compliance based risk screening, including child labour and forced labour considerations, during procurement planning. Where the application of CATSA’s TPRM Checklist identifies an elevated risk of forced labour or child labour, procurement personnel are directed to apply enhanced due diligence measures, including the use of supplemental contractual clauses in Statements of Work and targeted supplier due diligence questions, proportionate to the nature of the goods or services and the supplier’s role in the supply chain.
Areas at Greatest Risk and Actions Taken to Assess and Manage That Risk
CATSA has identified commodities with a higher risk, but there are still gaps in our assessment. The identification of higher risk goods and services is now supported by CATSA’s TPRM Checklist, which includes child labour and forced labour as an explicit compliance risk consideration. CATSA has identified the following aspects of its activities and supply chains to likely be the greatest source of potential risk: the types of products it sources, tier two suppliers, and the use of outsourced, contracted, or subcontracted labour. The following sectors or industries are considered, by CATSA, to be the highest risk for forced or child labour: manufacturing, wholesale trade, and transportation and warehousing.
CATSA has identified that the risk of such labour is highest in its procurement of uniforms for its Screening Officers, who carry out CATSA’s mandate through the third-party service model, though CATSA notes that it has not, as of the date of this report, discovered any evidence to suggest that actual forced or child labour exists in this, or any, contract, in its supply chain. Regardless, this contract is subject to the CATSA Contractor Code of Conduct, and new language has been inserted into the contract for uniforms that was awarded in 2024-2025, which requires the following:
i) keep proper records with respect to the origin of raw materials, uniform items, and services provided to CATSA;
ii) prohibit the use of child labour or forced labour in the manufacture of uniform items (or any part thereof) and requires that the contractor’s resources involved in the manufacture of uniform items (or any part thereof): (a) be paid wages and benefits for a standard working week that, at a minimum, meet national legal standards or industry benchmark standards, whichever is higher; (b) meet or exceed basic needs by local standards; and (c) receive equal pay and fair employment practices for all employees doing equal or comparable work for the same period of time;
iii) employees and other individuals involved in the manufacture of uniform items (or any part thereof) not: (a) be subject to physical, sexual, psychological abuse or harassment, verbal abuse, or any other form of abuse; (b) be subject to discrimination of any kind, including on the basis of age, race, caste, national origin, religion, disability, gender, marital status, sexual orientation, union membership, or political affiliation; (c) be forced to work excessive hours; (d) be subjected to unsafe or unhealthy working conditions; (e) be denied the freedom of association and the right to collective bargaining; and/or (f) be subject to the forced use of contraceptives or pregnancy testing; and
iv) the contractor must ensure (and ensures that its supply chain) provides a safe and healthy workplace that protects human health and the environment.
Similar language will also be leveraged and utilized in subsequent contracts with a supplier providing a product deemed to be at “higher risk” of such practices.
Remediation Measures
While CATSA has identified the above risk areas it has not, to date, identified any actual forced labour or child labour in its activities or supply chains. Because of this, CATSA has not identified any loss of income to vulnerable families resulting in measures taken to eliminate the use of forced labour or child labour in CATSA’s activities and supply chains.
Training
While CATSA does not currently provide standalone training on forced labour or child labour, awareness of these risks is addressed through procurement documentation, contractual requirements, and the application of the TPRM Checklist.
Effectiveness Assessment
CATSA has not identified any major areas of concern where forced or child labour may be present in its supply chain. In 2025–2026, the integration of child labour and forced labour considerations into CATSA’s standardized TPRM Checklist further supports the consistent identification and management of these risks. Even in areas of its supply chain where it may be more vulnerable than others, it has not, to-date, identified any actual forced or child labour in its supply chain. That said, CATSA has established contractual clauses and a Contractor Code of Conduct to signal to suppliers that it takes this matter seriously and expects them to do the same. To date, CATSA does not have any evidence that these measures are ineffective and thus it assesses its effectiveness, given the industries in which it operates, to be relatively high.