When Canada’s Procurement Strategy for Aboriginal Business and the wider federal supplier diversity framework incorporated enforcement of the Women’s Empowerment Principles (WEPs) reporting requirements in 2022, it represented a quiet but significant shift in the landscape of supply-chain accountability. These principles, adopted back in 2017 and often seen as aspirational guidelines, took on a more binding character once linked to federal procurement eligibility. The result is that suppliers vying for government contracts now find themselves grappling with a level of gender-disaggregated transparency that, frankly, few had anticipated being asked to produce at this scale or granularity.
What’s particularly interesting—and perhaps a little challenging—is the focus on Tier 2 suppliers and beyond. Many companies have, over the years, become accustomed to disclosing gender representation within their own operations, or at least at the primary contractor level. But now the scrutiny extends further down the chain, to workshops and subcontractors that often sit at some remove from the prime supplier. This expansion of focus has left more than a few compliance officers and procurement managers wondering where to begin. After all, Tier 2 workshops, particularly in sectors like manufacturing, textiles, or logistics, aren’t always accustomed to providing detailed demographic breakdowns, let alone to external clients or government agencies.
That said, the government has provided some tools to support this transition, though perhaps not in as coordinated a fashion as suppliers might have hoped. The open labor market data published by Employment and Social Development Canada (ESDC) offers a useful starting point. By cross-referencing this data with supplier declarations and workshop site data, suppliers can begin mapping labor force gender distributions in a systematic way. Admittedly, the ESDC datasets don’t provide disaggregation at the individual workshop level. They’re aggregated at sectoral and regional levels. Still, they can help suppliers identify likely patterns, flag potential problem areas, and justify estimates where direct data isn’t yet available.
The process of mapping these demographics isn’t straightforward. Suppliers will need to start by cataloging their Tier 2 relationships in full—not just the names on the contract ledger, but the actual sites performing work, where possible down to the plant or facility level. That alone, for some large federal contractors, is a daunting task. Once that mapping is in place, the next challenge is securing cooperation from those partners. Many Tier 2 entities, particularly small workshops, will have no formal HR systems capable of generating gender data at the push of a button. Some may be unfamiliar with the very concept of gender equity scoring. It will fall to the prime suppliers to provide templates, guidance, and—if they are wise—capacity-building support.
Here is where federal suppliers might consider borrowing a page from the social auditing playbook. Structured site surveys, worker interviews, and anonymized demographic questionnaires can all form part of the data-gathering toolkit. And while that sounds resource-intensive, it need not be prohibitively so. Many large suppliers already conduct periodic site visits or quality audits; layering gender-demographic data collection onto these existing touchpoints could, with careful planning, yield meaningful data without drastically increasing costs. And let’s be honest: given the clear direction of federal policy, the cost of inaction may, in the medium term, prove far higher.
Once collected, the data will need to be synthesized into a form suitable for publication. Suppliers are being encouraged, if not quite formally required, to publish gender-equity scores directly on government tender portals as part of their bid documentation. The exact format of these scores is not rigidly defined—there is, at least for now, some room for interpretation. But it’s clear that the expectation is for a metric or narrative that goes beyond a simple headcount. Factors like gender distribution across job grades, pay equity indicators, and the presence (or absence) of gender-sensitive workplace policies will almost certainly come under scrutiny. The goal, from the government’s perspective, is not just to tally numbers, but to foster a more substantive understanding of gender dynamics in supply chains.
In practice, this could mean publishing a short report alongside each tender submission, perhaps as a PDF annex or via a link to a supplier-maintained portal. The report might detail the methodology used, highlight key findings, and outline any improvement plans where gaps are identified. Some suppliers are likely to see this as an opportunity to differentiate themselves competitively. Others may, initially at least, treat it as a compliance hurdle. The tone and framing of these early reports will be telling.
There’s also an underlying ambiguity that suppliers will have to navigate. While the government has laid out clear expectations around gender transparency, it has left certain details—such as precise scoring rubrics—open-ended, presumably to allow flexibility across sectors and business models. This openness can be both a blessing and a curse. It gives suppliers room to tailor their reporting to their realities, but it also leaves space for inconsistency. No doubt, over time, best practices will emerge, shaped in part by what the government chooses to reward or penalize in tender evaluations.
The push for gender-disaggregated supply-chain reporting is, of course, part of a broader trend. ESG reporting frameworks globally are shifting toward deeper, more granular data demands. Canada’s Procurement Strategy may simply be ahead of the curve in translating these into enforceable requirements. The coming years will reveal how effectively suppliers adapt, and how far the principles of gender equity can be embedded into the practical mechanics of federal contracting.