The Canadian government spends more than $100 million on clothes annually. Do the garments come from an ethical supply chain?

The Canadian government spends more than $100 million on clothes annually. Do the garments come from an ethical supply chain?
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Every year, the federal government purchases more than $100 million worth of clothing — from bike shirts for RCMP officers to extreme cold weather parkas for northern scientists to stab-resistant vests for prison guards.

Last year, officials added a specific apparel item to their shopping lists: hundreds of thousands of cloth masks to help protect staff from COVID-19.

But who makes those items, where, and under what conditions?

In 2018, the Canadian government adopted a policy to require suppliers to certify that the items they were providing had been made without the use of forced or child labour, and with access to safe and fair working conditions. The change was part of an effort to “address concerns regarding human and labour rights violations within the federal procurement supply chain” and set a “minimum level of expected ethical behaviour amongst suppliers.”

Since then, suppliers on 51 Canadian government contracts worth a total of $77.3 million publicly declared that neither they, nor their first-tier subcontractor, commit human rights abuses, including forced labour and child labour, in the production of garments to be worn by federal workers.

“PSPC has not received complaints or credible evidence of a potential issue with apparel contracts. As such, we have not had to validate compliance,” the PSPC spokesperson said.

The government says that self-certification is subject to verification at any time, based on complaints or evidence of “potential issues.” But it hasn’t received any complaints or evidence, and so has not investigated any of the contracts signed since the ethical procurement policy was put in place, according to the statement.

The ministry said the policy dovetails with efforts by the Canada Border Services Agency to keep goods produced “wholly or in part by forced labour” from entering the country, and with those by Employment and Social Development Canada, which researches “potentially problematic supply chains.”

The procurement ministry’s lack of ongoing and proactive verification undermines a policy designed to protect workers from labour violations, say academics and advocates. And, even if the declarations are true, they fail to address the lower tiers of production — from the workers collecting cotton to those who dye and cut the fabric for our clothing — where exploitation is most common.

“Companies who understand the due diligence process recognize that most of the risk lies in those bottom tiers,” says Bonnie Nixon, a supply chain expert who teaches sustainability at the University of California, Los Angeles.

Industries like apparel are a multi-tier operation. The very top is the brand, which hires a tier-one factory to manufacture or sew the garment. Tier two might be a different factory, which takes care of embroidery or cutting. Tier three is where the cotton is woven and dyed. Tier four is the production and picking of the cotton itself. Within the tiers, factories may subcontract officially or unofficially, depending on their workload. Buttons, thread, beads and other decorative accents are sourced from entirely different suppliers.

“Forced labour and child labour issues tend to be several tiers below and closer to the resource extraction stage or resource processing stage of many supply chains,” said Greg Distelhorst, who researches the garment industry at the University of Toronto. “It seems like if you’re serious about those issues, that has to go deeper than the first layer.”

One-fifth of the world’s cotton is picked in Xinjiang, China, where concerns have grown about the Uyghur people being used as forced labour. A garment supplier could rightly claim that both it and its first-tier subcontractor are free of human rights abuses despite sourcing cotton from Xinjiang.

Canada’s recently amended Customs Tariff could block the company from importing any goods believed to be produced using forced labour in Xinjiang, but a not a single shipment had been blocked from entering the country under the new rules.

This isn’t solely a government problem. The private sector faces challenges with the lower levels of supply chains, too, said Simon Lewchuk, senior policy director for World Vision Canada.



“Most companies haven’t been or begun…to get beyond the first tier with their audits or with their thinking, generally,” Lewchuk said.

Public Services and Procurement Canada also said it is committed to updating its code of conduct to “outline expectations for suppliers regarding human and labour rights which extend to the entire supply chain,” and is undergoing a review of where the risks are in government supply chains for human rights abuses.
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