A strategy cannot be used to create a criminal law provision. It is up to Parliament to draft a criminal law provision that imposes a penalty. Even then, the penalty might be along the lines of a prohibition against dealing with agencies or corporations that do not comply with the targets.
From what I can see, the bill does not provide for criminal law sanctions, such as prohibitions or penalties for non-compliance. That would alter the substance of the bill. In pith and substance, this bill applies to federal institutions.