mila-ai4h/AIMS.au huggingface dataset:
[SID_260] It is published by Cap America, Inc (the Company) in compliance with Canadas Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Act)
[SID_260] This report highlights the key activities the Company has undertaken during the last financial year to prevent and reduce the risk that forced labour or child labour be used at any step of the production of goods in Canada or elsewhere by the Company or of goods imported into Canada by the Company
[SID_260] References in this report to Cap America, we, our and similar terms are to the Company
[SID_260] PREVENTING AND REDUCING RISKS OF FORCED LABOUR AND CHILD LABOUR Cap America strives to be a leader within our industry and our community
[SID_260] From investing in local educational programs to reducing our carbon footprint, Cap America works to make a difference at the local, national, and global levels
[SID_260] We believe it is in our interest to conduct our business in an honest and honorable fashion in order to create a sustainable work environment for the future of our workers and the Company
[SID_260] In line with our commitment to ethical employment practices, we are committed to respecting human rights in everything we do and we have a zero-tolerance approach to forced labour and child labour
[SID_260] During our last financial year, we have taken various steps to prevent and reduce the risk that forced labour or child labour be used in our activities and supply chains, including the following
[SID_260] We have mapped our organizations cotton supply chain and verified high risk areas with isotope testing
[SID_260] We initiated an internal risk assessment of forced labour and child labour in our organizations activities and supply chain based on the information and resources provided by the American Apparel & Footwear Association (AAFA) to make informed decisions
[SID_260] We only worked with Tier 1 suppliers who had recently been audited by reputable third party auditors and ensured none of our suppliers transact business with Xinjiang Production and Construction Corps (XPCC)
[SID_260] We implemented our Code of Conduct throughout our supply chain by requiring all our Tier 1 suppliers to sign it and included a contractual clause to our purchase orders which provides that by accepting the purchase order, the supplier agrees to comply with our Code of Conduct
[SID_260] We continued monitoring our suppliers in China and Vietnam through our Shanghai office
[SID_260] Details of the above actions are set out in this report
[SID_260] ABOUT US & OUR SUPPLY CHAIN Cap America is a privately held manufacturing and wholesale company based in Fredericktown in the state of Missouri in the United States
[SID_260] We sell headwear exclusively to distributors of promotional products and advertising specialties
[SID_260] Our blank caps and knits are delivered to our Missouri facility which we then decorate with embroidery or patches based on our clients custom orders and then import them into Canada, among other countries, for sale
[SID_260] We generally source our blank garments from third party manufacturers based in Asia, including China, Vietnam, Bangladesh, and Myanmar
[SID_260] Since cotton is traded as a commodity, achieving full traceability to farm level can be difficult, especially when a farms output changes every season dependent various factors such as climate, yield, staple length, colour, quality, etc
[SID_260] Nonetheless, we have been able to confirm through isotope testing on selected cotton samples that the cotton used by our higher risk manufacturers does not originate from the Xinjiang region in China
[SID_260] POLICIES AND DUE DILIGENCE PROCESSES As we continue to strengthen our processes to reduce risks related to forced and child labour, our policies and due diligence practices are aligned with the risks involved in our activities, our supply chains and our business relationships in a manner conducive to responsible conduct
[SID_260] Our Code of Conduct Our Code of Conduct is the foundation of our human rights risk management approach
[SID_260] It sets out the values and principles that guide our relationship with our suppliers, their subcontractors, and their workers
[SID_260] Notably, the Code of Conduct provides for
[SID_260] A prohibition from engaging in any form of forced labour and child labour requiring suppliers to obtain and keep on record documentation to legally prove the date of birth of their workers
[SID_260] The obligation to operate in full compliance with the laws, rules and regulations of the countries of operation
[SID_260] The protection of workers rights, freedom of association, and a safe and healthy working environment
[SID_260] During the last financial year, we implemented our Code of Conduct throughout our supply chain by requiring all our Tier 1 suppliers to sign it
[SID_260] We also developed a contractual clause in our purchase orders which provides that by accepting the purchase order, the supplier agrees to comply with our Code of Conduct, violations of which may be grounds for the nullification of the purchase order
[SID_260] The code also adds that Cap America may, at its sole discretion, terminate business with any vendor upon a reasonable belief that the vendor uses or promotes the use of forced, convict, or child labour
[SID_260] Due Diligence Processes The informal internal risk assessment we conducted on a preliminary basis allowed us to monitor current and prospective Tier 1 suppliers as well as to identify, assess and mitigate any adverse impacts in our operations, supply chains and business relationships
[SID_260] When initiating collaboration with Tier 1 suppliers, we ensure transparency and accountability by requesting that they provide information on the latest audit conducted at their facilities and that they agree to be bound by our Code of Conduct
[SID_260] To meet our standards, the audits of our suppliers must have been conducted by reputable third-party auditors such as Worldwide Responsible Accredited Production (WRAP) association and the Sedex Members Ethical Trade Audit (SMETA) association of accredited auditors
[SID_260] These audits confirm, among other things, that the workers employed in our Tier 1 suppliers factories were recruited voluntarily
[SID_260] We then collaborate with the factories to ensure corrective action plans and any remediation measures are taken based on the audit recommendations, and we communicate with them on how impacts can be addressed
[SID_260] We track suppliers compliance with our Code of Conduct and social audit recommendations through periodic site visits conducted by our head office or Shanghai office
[SID_260] Together, these steps allow us to embed responsible business conduct into our organisation and to track implementation and results, as required
[SID_260] We have no tolerance for suppliers transacting business with high-risk partners, such as the XPCC which has been placed on the U.S
[SID_260] Department of Treasurys Office of Foreign Assets Controls Specially Designated Nationals List
[SID_260] Our suppliers are required to fill out and sign a questionnaire to confirm that XPCC is not among their business partners
[SID_260] In addition, our Tier 1 and Tier 2 suppliers were vetted by legal counsel to ensure they had no affiliation with XPCC and they do not figure on United States or European Union sanctions lists
[SID_260] When faced with signs of human rights abuses, we seek to mitigate and cease any negative impact by engaging with our suppliers to remediate the issue, as is further explained below
[SID_260] RISK ASSESSMENT In the context of our internal risk assessment, we have identified certain parts of our activities and supply chains which carry risks of forced labour and child labour using the List of Goods Produced by Child Labour or Forced Labour list published by the Bureau of International Labour Affairs
[SID_260] The risks identified are primarily related to the types of goods we produce, sell, distribute and import, the locations of our activities and operations, the type of product we source, the use of migrant labour, and the raw materials or commodities used in our supply chains
[SID_260] We also understand that the risk of forced labour and child labour in the textile supply chain exists and that textile supply chains that extend into certain foreign countries potentially face greater risk of forced labour and child labour
[SID_260] Although we have strong oversight on our Tier 1 manufacturers, we recognize that they are located in areas where there may be higher prevalence of labour rights abuses
[SID_260] We also acknowledge that our suppliers have their own value chains that may extend into high-risk countries and on which we have limited visibility
[SID_260] To mitigate the risks associated with suppliers further upstream in the production chain, we have mapped our supply chains and verified high risk areas with isotope testing
[SID_260] We require our suppliers to provide shipping records and invoicing from the farm to the end product to show traceability and for the higher risk manufacturers, we have started using isotope testing
[SID_260] The testing conducted confirms that the cotton we use is not from the Xinjiang region in China
[SID_260] Cap America believes that human rights risk assessments play a vital role in promoting ethical sourcing, cultivating sustainable supply chains, and demonstrating responsible due diligence, which ultimately safeguards our business interests and reinforces our commitment to ethical practices
[SID_260] Cap America continues to prioritize understanding human rights risks within our supply chain, with a focus on forced labour and child labour, and will continue to strive to identify emerging risks
[SID_260] ACTING ON IDENTIFIED RISKS & IMPACTS Together with partners, we engage in programmes, industry initiatives and activities to address identified risks and impacts
[SID_260] Our initiatives to remediate any forced labour or child labour include engaging with the Workers Right Consortium as a representative for the workers who are at risk of forced labour and child labour in our suppliers factories
[SID_260] During our last financial year, we were made aware of a situation in one of our Myanmar factories, where unpaid overtime claims were filed
[SID_260] As a result, we have taken substantial remediation measures by starting to work with the Workers Right Consortium and other brands to remediate alleged unpaid work and will continue to identify and address any gaps in our response
[SID_260] We are monitoring this situation closely and will consider any reasonable action to remediate human rights risks in this factory
[SID_260] TRAINING AND CAPABILITY BUILDING Our AAFA membership allows our workforce to increase its level of understanding of the risks of forced labour and child labour in our business and supply chains
[SID_260] As members of the AAFA, our compliance team keeps abreast of best practices to decrease the risks of forced labour and child labour in our supply chain by regularly attending AAFA seminars, webinars and conferences addressing critical industry supply chain issues
[SID_260] We routinely use AAFA information and resources to assess and monitor our Tier 1 suppliers social compliance
[SID_260] We have implemented their CSR Guidance on Assessing Prospective New Supplier social compliance through various measures, Commitment to Responsible Recruitment of employees, and Eradicating Forced Labour policies in our management processes
[SID_260] Most importantly, our compliance team participates in a biweekly social responsibility consultation with the AAFA Senior vice president of Policy
[SID_260] ASSESSING THE EFFECTIVENESS OF OUR APPROACH Ensuring that forced labour and child labour practices are not taking place in our business and supply chains is and will always be a work in progress
[SID_260] In order to assess the effectiveness of the measures we have taken to reduce human rights risks, we conduct regular review and audit of our policies and procedures related to forced labour and child labour to ensure their scope and scale are proportionate to the human right risks our organization and supply chain may face
[SID_260] LOOKING AHEAD As we are committed to further strengthening our efforts in combating human rights abuses, we will continue expanding our cotton isotope testing and we intend to undertake a thorough risk assessment of our supply chains conducted by a recognized provider of inspection and certification services
[SID_260] *** This report was approved by the Board of Directors of the Company on April 24, 2024 pursuant to paragraph 11(4)(a) of the Act and constitutes our report for the financial year ending December 31, 2023
[SID_260] In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for the entity listed above
[SID_260] Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year indicated above
[SID_260] I have the authority to bind Cap America, Inc
[SID_260] Full name: Mark Gammon Title: CEO Date: April 24, 2024
[SID_268] 2024 MODERN SLAVERY REPORT Introduction This Report constitutes the first report of Uranium Royalty Corp ("Uranium Royalty" or the "Company") pursuant to Section 11 of Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act (the "Act") and sets out the steps taken to prevent and reduce the risk that forced labour or child labour is used at any step of the production of goods in Canada or elsewhere or of goods imported into Canada by the Company ("Modern Slavery Risks")
[SID_268] This Report has been prepared for the Company's fiscal year ended April 30, 2024 (the Reporting Period)
[SID_268] Who We Are The Company is committed to ensuring that forced labour and child labour are not used in its supply chains
[SID_268] Uranium Royalty is a pure-play uranium royalty company focused on gaining exposure to uranium prices by making strategic investments in uranium interests, including royalties, streams, debt and equity investments in uranium companies, as well as through engaging in physical uranium transactions
[SID_268] At the end of the Reporting Period, the Companys growing portfolio included 20 interests on 18 development, advanced, permitted and producing uranium projects in multiple jurisdictions, including royalties on the McArthur River and Cigar Lake mines, each located in Saskatchewan
[SID_268] The Company interests in uranium projects and properties are usually limited to receiving payment under its royalties and other interests, which are customarily in cash or through the delivery of physical uranium
[SID_268] The Company is incorporated under the Canada Business Corporations Act and has two wholly-owned subsidiaries, Uranium Royalty (USA) Corp, a corporation incorporated under the laws of Delaware on October 24, 2018, and Reserve Minerals, LLC, a limited liability company existing under the laws of Delaware
[SID_268] The Company's head office is located in Vancouver, British Columbia
[SID_268] For further information regarding the Company and its assets, please refer to its most recent Annual Information Form, a copy of which is available on its website at www.uraniumroyalty.com
[SID_268] Our Supply Chain The Company's operations are focused on acquiring royalties, streams and other interests in the uranium sector, along with engaging in transactions in physical uranium
[SID_268] As such, the
[SID_268] Page 2 Company's physical supply chain is generally limited to: (i) the acquisition of uranium; and (ii) to a lesser extent, sourcing goods and services for its head office operations, such as office equipment, computer equipment, accounting, legal and other advisory or consulting services and other miscellaneous office supplies
[SID_268] The latter are substantially all sourced within Canada and the United States
[SID_268] The Company's supply chain for acquiring physical uranium includes the following
[SID_268] existing uranium royalty or stream arrangements with operators of uranium mines, whereby physical uranium may be delivered as payment to the Company by the operator of the underlying uranium mine
[SID_268] Currently, all of the Company's such interests in producing mines are mines located in Saskatchewan, Canada; and
[SID_268] purchases of physical uranium in market-based purchases through brokers, dealers and other counterparties, including pursuant to long term delivery contracts
[SID_268] During the Reporting Period, the Company sourced uranium through primarily market-based purchases and an existing royalty agreement with a Canadian mine
[SID_268] How We Work to Ensure Our Supply Chains Are Free of Forced Labour and Child Labour Governance Risk oversight is the responsibility of the Company's board of directors
[SID_268] The Company's Sustainability Policy, which addresses Modern Slavery Risks and is described below, is overseen by the Company's board of directors
[SID_268] The Company's board of directors has delegated to its Audit Committee the responsibility to review and monitor its risk management policies and practices generally and reviewing compliance with the Company's Code of Business Conduct and Ethics (the "Code")
[SID_268] In addition, the Company has appointed a Vice President of Environmental, Social and Governance (ESG), who is accountable to ensure the implementation of programs and processes that support its Sustainability Policy, including the management and mitigation of Modern Slavery Risks
[SID_268] The Company has established and maintains a number of policies, internal controls and procedures relating to the procurement of goods and services, including physical uranium, that are intended to help manage risk and comply with applicable laws and regulatory requirements in the jurisdictions in which we operate or source supplies
[SID_268] Policies Code of Business Conduct and Ethics: Uranium Royalty is committed to the highest ethical standards for conducting its business
[SID_268] The Companys Code establishes standards across the
[SID_268] Page 3 organization for honest and ethical conduct, fostering a culture of integrity
[SID_268] The Code also requires Company personnel to at all times obey and comply with all federal, provincial, state and local laws, including those relating to forced labour and child labour
[SID_268] Whistleblower Policy: Uranium Royalty has a Whistleblower Policy that provides a formal framework for employees to report any violations of the Code anonymously and confidentially
[SID_268] The Company encourages employees to report any situation that appears to involve any breach of the Code, or ethical or legal obligations
[SID_268] The Whistleblower Policy also provides that the Company will not tolerate an attempt on the part of anyone to apply any sanction or detriment to any person who has reported to the Company a serious and genuine concern that they may have about any apparent wrongdoing
[SID_268] Sustainability Policy: The Companys Sustainability Policy outlines its ESG related values
[SID_268] The policy is designed to ensure that sustainability-related risks, including Modern Slavery risks, and opportunities facing the Company, its third-party operators and suppliers are assessed appropriately as a part of its risk management processes
[SID_268] The policy provides that the Company adheres to the following human rights related principles
[SID_268] Respect internationally recognized human rights as proclaimed by the Universal Declaration of Human Rights, and the International Labor Organizations Declaration on Fundamental Principles and Rights at Work
[SID_268] This means that we are committed to and seek to align our actions with the United Nations Guiding Principles on Business and Human Rights
[SID_268] Respect the rights of all people, upholding human rights, and acting with integrity and transparency throughout all of our actions, communications and stakeholder engagement
[SID_268] Prohibit the use of any form of forced or compulsory labor, including child labor, both within our operations, and by those with which we enter into any business dealing
[SID_268] We have zero tolerance for such human rights violations committed by our employees, or any third parties entered into business dealings with the Company
[SID_268] We will take appropriate action if a human rights violation is reported
[SID_268] Procedures Due diligence: When entering into new royalty, streaming or similar agreements with third parties, the Company conducts specific due diligence on Modern Slavery Risks to ensure that we transact with third parties who share and upholds the values outlined in our Code, as well as our Sustainability Policy
[SID_268] In evaluating such potential transactions, the Company utilizes a disciplined approach to, among others, safeguard against human rights abuses
[SID_268] When entering into a royalty agreement or other financial arrangement, the Company carefully screens and seeks to select
[SID_268] Page 4 operators who share our principles of responsible environmental and social stewardship
[SID_268] This process includes reviewing publicly available information, conducting jurisdiction-based reviews and risk assessments and, where available, reviewing the third party's internal policies, procedures and records relating to Modern Slavery Risks
[SID_268] The Company also regularly reviews sanctions and other lists compiled by governmental and non-governmental organizations to identify jurisdictions and entities that have heightened Modern Slavery Risks
[SID_268] In the case of market-based transactions, due to the nature of uranium as a fungible commodity, the Company has limited access to information to diligence the mine source and related supply chain in each transaction
[SID_268] However, the Company does have access to information regarding the country of origin underlying each uranium acquisition
[SID_268] Uranium is not listed as a product where there is a risk of modern slavery on the Global Slavery Index.1 Further, due to the heavily regulated nature of the industry globally, the Company believes there is a low risk of forced labour and child labour in our supply chain
[SID_268] Given the regulated nature of uranium mining activities globally and the technical nature of such activities, the Company believes Modern Slavery Risks are generally low in relation to its market-based purchases
[SID_268] In order to further mitigate risks related to market-based purchases, the Company also seeks to deal only with reputable brokers and dealers
[SID_268] During the Reporting Period, the Company took the following steps to prevent and reduce Modern Slavery Risks in its business and supply chains
[SID_268] Reviewed its existing policies and procedures to ensure they remained up to date and applicable
[SID_268] In compliance with its policies and procedures, continued conducting due diligence of potential royalty and stream partners and other counterparties before entering into agreements; and
[SID_268] Conducted a management-led assessment of Modern Slavery Risks in the Company's supply chain
[SID_268] Assessment of Modern Slavery Risks in our Supply Chains The Company recognizes that Modern Slavery Risks vary by industry and jurisdiction
[SID_268] Walk Free The Global Slavery Index 2023 (https://cdn.walkfree.org/content/uploads/2023/05/17114737/GlobalSlavery-Index-2023.pdf)
[SID_268] Page 5 The Company does not consider that any of its operations carry Modern Slavery Risks, given its limited operations and business model
[SID_268] Additionally, due to the heavily regulated nature of the industry the risk is further mitigated
[SID_268] Finally, as outlined above, the Company has a number of internal policies and controls designed to safeguard the rights of its employees along with its commitment to respecting and observing human rights in accordance with applicable law and the principles set forth in applicable international standards described herein