mila-ai4h/AIMS.au huggingface dataset:
[SID_236] Training and Awareness Highwood is committed to improving the training and awareness of our Staff to understand, identify and manage the risks of forced labour and child labour in our operations and across our supply chains
[SID_236] Staff at all levels are required to adhere to Highwoods Code of Business Conduct and Ethics policies and ensure it is understood and properly applied to their daily activities
[SID_236] Every new staff member of Highwood must review and sign that they have read, understand and will abide by the Code of Business Conduct and Ethics
[SID_236] All staff are also informed of how to report wrongdoing under the Whistleblower policy and are encouraged to take initiative in reporting any concerns or suspicions of wrongdoing
[SID_236] We also commit to providing our staff with ongoing training opportunities to ensure our staff have the sufficient knowledge
[SID_236] Assessing our Effectiveness Based on our review of our existing policies, practices, business activities, and areas we operate in, we believe the risk of forced labour or child labour in our operations or supply chain is low
[SID_236] We monitor compliance with our corporate policies on an ongoing basis
[SID_236] While we have not had any significant concerns or complaints identified to date, we commit to reviewing and addressing any concerns or complaints that are potentially identified
[SID_236] Approval and Attestation This Report was approved by Highwoods Board of Directors on May 21, 2024 and has been submitted to the Minister of Public Safety and Emergency Preparedness in Canada
[SID_236] This Report is also available on our website at www.highwoodmgmt.com 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
[SID_236] 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 2023
[SID_236] I have the authority to bind Highwood Asset Management Ltd
[SID_236] Greg Macdonald President & CEO Date: May 15, 2024
[SID_236] Advisories
[SID_236] Forward-Looking Information
[SID_236] Certain statements contained in this report include statements which contain words such as anticipate, could, should, expect, seek, may, intend, likely, will, believe and similar expressions, statements relating to matters that are not historical facts, and such statements of our beliefs, intentions and expectations about development, results and events which will or may occur in the future, constitute forward-looking information within the meaning of applicable Canadian securities legislation and are based on certain assumptions and analysis made by us derived from our experience and perceptions
[SID_236] Forward-looking information in this report includes, but is not limited to: the steps taken to prevent and reduce risks of forced and child labour; the implementation of policies in relation to forced labour and child labour; training provided to employees in respect of forced labour and child labour; business strategy and outlook; remediation measures in respect of forced labour or child labour; maintenance of existing supplier and partner relationships; supply channels; and other such matters
[SID_236] The foregoing factors are not exhaustive
[SID_236] Actual results, performance, or achievements could differ materially from those expressed in, or implied by, this forward-looking information and, accordingly, no assurance can be given that any of the events anticipated by the forward-looking information will transpire or occur, or if any of them do so, what benefits will be derived there from
[SID_236] Except as required by law, Highwood disclaims any intention or obligation to update or revise any forward-looking information, whether as a result of new information, future events or otherwise
[SID_236] The forward-looking information contained herein is expressly qualified by this cautionary statement
[SID_240] 2023 Supply Chains Act Annual Report This report constitutes the inaugural annual report (the Report) of Evans Adhesives Canada Inc (Evans, we, us or our) filed and published pursuant to the Fighting Against Forced Labour and Child Labour in Supply Chains Act (Canada) (the Supply Chains Act or the Act) for the twelve-month financial year ended December 31, 2023 (the Reporting Period)
[SID_240] Our Structure, Operations and Supply Chains Evans is incorporated under the Canada Business Corporations Act
[SID_240] It is a subsidiary of Evans Adhesives Corporation, based in Columbus, Ohio, United States, itself part of the Meridian Adhesives Group, with headquarters in Charlotte, North Carolina, United States (Meridian)
[SID_240] Evans only operates in Canada from its single Industrial Packaging Division site located in Saint- Eustache, Quebec, Canada
[SID_240] Evans employs over 30 people
[SID_240] Evans sells goods in Canada or abroad, distributes goods in Canada or abroad, or imports into Canada goods produced outside of Canada
[SID_240] We formulate, manufacture and distribute industrial adhesives focused on the packaging market
[SID_240] We offer water-based, hot melt, and pressure-sensitive adhesives that can perform under extreme conditions
[SID_240] Our client base is comprised of players in the general product and food packaging, paper converting, construction and millwork industries
[SID_240] We source the majority of our material from the United States
[SID_240] Out of our ten largest suppliers nine are based in Canada or the United States and one is located in China
[SID_240] The Steps We Have Taken during the Reporting Period to Prevent and Reduce the Risk of Forced Labour and Child Labour Evans current Code of Ethics (the Code) was adopted by our ultimate parent company, Meridian, and is applicable to Evans
[SID_240] During the Reporting Period, we continued to implement our Code of Ethics discussed in section 3(a) of this Report
[SID_240] Except from the continued implementation of the Code no additional steps were taken during the Reporting Period to prevent and reduce the risk of forced labour and child labour in our operations and supply chains
[SID_240] Policies, Due Diligence and Controls The Code which governs at a high-level issues related to business practices, employee relationships, customer relationships, community and the environment applies to all Meridians subsidiaries, including Evans
[SID_240] (a) Code of Ethics The statements set forth in the Code must be upheld by all our employees and representatives
[SID_240] They owe a duty to Meridian, its customers and community to act in a way that will merit the continued trust and confidence of our community and those with which we do business
[SID_240] Evans, its employees and representatives must ensure that there is no forced labour, including prison labour, indentured labour, bonded labour or other forms of forced labour used in our activities
[SID_240] #NAME?
[SID_240] Our workers cannot be younger than 16 years old or the compulsory age to be in school in the jurisdiction in which they live
[SID_240] We will not partner with entities, including suppliers, who use child labour in any of their facilities
[SID_240] We comply and follow all applicable local, provincial and federal laws relating to employment, wage and work hours
[SID_240] We uphold true and fair employment practices
[SID_240] Beyond the statements established in our Code, it is our policy to comply with all laws, rules and regulations applicable to the business and countries in which we operate
[SID_240] In the case of Evans, this includes laws relating to forced labour an child labour applicable in Quebec, Canada
[SID_240] Risk Assessment Methodology and Results of Assessment During the Reporting Period, we did not make any assessment of the potential risk related to forced labour and child labour in our operations and supply chains
[SID_240] In the future, we plan to roll- out a compliance program which may include a questionnaire designed to specifically address the issue of forced labour and child labour which we initially plan to send to our Tier 1 (direct) suppliers
[SID_240] Risks of Forced Labour and Child Labour in our Operations and Supply Chains To our knowledge, during the Reporting Period we have not identified risks of forced labour and child labour in our operations and supply chains, although we recognize that this assessment was performed on a preliminary basis without recourse to the risk assessment tools that a robust compliance program could provide us with
[SID_240] Remedial Action Taken during the Reporting Period Since we have not identified any forced labour or child labour in our activities and supply chains during the Reporting Period, we have not taken any remediation measures during the Reporting Period
[SID_240] Our remediation processes All our employees are instructed and encouraged to report any violation to our Code and to, more generally, our commitment to true and fair financial, business and employment practices which would include denunciation of occurrences of forced labour and child labour in our operations or supply chains
[SID_240] They should report these potential violations to their manager or other management personnel without fear of retribution
[SID_240] Remediation actions for the loss of income to the most vulnerable families that results from any measure taken to eliminate forced labour and child labour from our operations and supply chains Not applicable, we have not identified any loss of income to vulnerable families resulting from measures taken to eliminate the use of forced labour or child labour in our activities and supply chains during the Reporting Period
[SID_240] Our training We have no director, officer or staff training in place at the moment dealing with forced labour and child labour in our operations and supply chains
[SID_240] -10
[SID_240] Assessing our effectiveness No assessment of our effectiveness to prevent and reduce the occurrence of forced labour and child labour in our operations and supply chains was conducted during the Reporting Period and until we put in place a compliance program to address this issue we are not contemplating performing an annual assessment of our effectiveness with regards to our action to prevent and reduce forced labour and child labour in our operations and supply chains
[SID_240] We expect to roll-out our initial assessment process in 2024
[SID_240] Our consultation and governance process In preparing this Report, Evans consulted with key areas of our organization, including Procurement, Human Resources, the Legal Department and our external legal counsel
[SID_240] These teams operate across our enterprise
[SID_240] This consultation process has supported our enterprise- wide approach to forced labour and child labour
[SID_240] Approval This Report was approved by the board of directors of Evans Adhesives Canada Inc pursuant to section 11(4)(a) of the Act on May 21, 2024
[SID_240] Conclusion Evans is committed to preventing forced labour and child labour from taking place in its operations and in its supply chain
[SID_240] Accordingly, we expect to improve and/or develop policies, procedures and practices to address these value chain risks in the future
[SID_240] Attestation 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 or entities listed above
[SID_240] 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 listed above
[SID_240] Dated this 24th day of May, 2024 Evans Adhesives Canada Inc
[SID_240] Per: Wayne Byrne, Director, I have the authority to bind Evans Adhesives Canada Inc
[SID_240] Draft 2023 Modern Slavery Statement (final version).DOCX DocuSign Envelope ID: 32621DD2-F986-4A3B-BA3D-BE26E6FBCBBB
[SID_243] Modern Slavery Act Report 2023
[SID_243] Introduction
[SID_243] At SJC, we do not tolerate modern slavery or any unethical behaviours that violate human rights
[SID_243] Modern slavery, which includes forced labour and child labour, is a global concern and one that goes against our core beliefs and values, including Respect Every Individual as Equal
[SID_243] If we become aware of any unethical or illicit behaviours that we and the law consider to be unacceptable by our employees, freelancers, suppliers, or anyone we do business with, we will immediately address the situation and proceed in a way that minimizes harm to those affected
[SID_243] We maintain a strong commitment to growth and continue to adapt, develop, and implement new policies and procedures to better protect our vulnerable communities and people
[SID_243] In our 2023 reporting year, we took a number of steps to better address and prevent forced and child labour in our operations and those of our suppliers
[SID_243] Weve mapped our activities and supply chains as well as completed an internal risk assessment to prioritize the most severe areas of risk
[SID_243] Additionally, we have maintained internal controls to guarantee workers are recruited voluntarily and we are developing training related to modern slavery
[SID_243] Using our risk assessments and the information gathered from the supply chain mapping, we were able to develop an action plan and due diligence policies and processes to address modern slavery and protect children and labourers
[SID_243] In the coming year, we will continue to develop, improve, and implement these policies and controls and will continue to work towards maintaining a supply chain with very minimal risk of modern slavery
[SID_243] Structure, Activities, and Supply Chains St Joseph Printing Limited (SJPL), which operates under the name St
[SID_243] Joseph Communications (SJC), is the entity that contains our Print division
[SID_243] Ontario
[SID_243] Limited, which operates under the names SJC Content and SJC Media, is a wholly owned subsidiary of SJPL
[SID_243] Both entities are located in Canada
[SID_243] SJC and its subsidiaries are involved in numerous business activities, including producing goods in Canada, selling goods in and outside Canada, distributing goods in and outside Canada, importing goods into Canada, and controlling an entity or entities engaged in any of the previously mentioned activities
[SID_243] Our supply chains involve several vendors and suppliers, the greater part of which are located and operating in North America
[SID_243] Our Print divisions largest vendors are North American paper suppliers
[SID_243] For SJC Content and SJC Media, creative work is either produced in-house or sourced through highly skilled freelancers that are primarily located in North America
[SID_243] Risks
[SID_243] As the vast majority of our vendors and suppliers are located and operating in North America, risk exposure to Canadian and American labour law violations is relatively low
[SID_243] Our Print manufacturing is also entirely in house, enabling us to guarantee proper conduct and practices
[SID_243] We have identified and recognize risks related to some of the products we purchase, raw materials or commodities used in our supply chains, tier three and beyond suppliers, and the use of outsourced labour
[SID_243] Though we source predominantly from North America and can be reasonably sure that our tier one and two suppliers are not engaging in any modern slavery or unethical behaviours and practices, we acknowledge that those in tier three and beyond of our supply chain may be sourcing or operating in higher risk locations or industries
[SID_243] We also recognize that the following sectors and industries related to our supply chain carry risk; Electronics/technology Forestry
[SID_243] Manufacturing Transportation and warehousing We maintain the commitment to further evaluate and identify areas of risk in our supply chains and improve our policies and procedures to address them
[SID_243] Our Policies Our SJC policies and procedures align with human rights and provincial employment standards legislation, as well as all Canadian labour laws
[SID_243] Our associate handbook sets out to ensure all employees, visitors, contractors, and customers of our company and its subsidiaries are respected and treated fairly in accordance with their human rights
[SID_243] The handbook outlines specific behaviours and practices that are unacceptable for those who are a part of SJC and represent the company
[SID_243] Additionally, we have a code of ethics that outlines our commitment to honest and ethical conduct in all areas of our organization
[SID_243] Relating to our paper suppliers and forestry risks, we have embedded responsible business conduct in our policies, as the large majority of our paper is Forest Stewardship Council (FSC) certified
[SID_243] This ensures the trees used to make the paper has been ethically sourced in a way that protects biological diversity and benefits the lives of local people and labourers
[SID_243] For our creative freelancers located outside North America, we have existing policies in place to ensure they are in compliance with our internal policies and procedures, which includes avoidance of forced or child labour
[SID_243] While these policies do work toward keeping our business practices and partners within our standards and ethical code, we are in the process of implementing vendor qualification questionnaires and due diligence processes to better ensure labour laws specifically are being respected across our entire supply chain
[SID_243] Remediation
[SID_243] As per our associate handbook, our Open Door Policy promotes the fostering of open communication and trust between employees and their supervisor, Human Resources, or any company manager
[SID_243] We strongly encourage all employees to discuss any problems or concerns promptly with a manager or Human Resources
[SID_243] This includes misconduct by employees or members of our supply chain
[SID_243] In any suspected case of modern slavery, we will immediately address our expectations and relationship, and work to promptly identify those affected by the wrongdoing and provide appropriate remediation
[SID_243] To date we have not identified or been advised of any forced or child labour use, nor any loss of income to vulnerable families as a result of measures we have taken to eliminate modern slavery
[SID_243] Training
[SID_243] Our employees are required to read and sign to acknowledge understanding of our associate handbook, which outlines our expectations of conduct as well as all of our internal policies
[SID_243] This includes expectations of ethical business practices and our right to take disciplinary action in cases of noncompliance
[SID_243] Additionally, we are continuing to develop training to specifically address forced and child labour to improve understanding of modern slavery, and reinforce that it is not an acceptable practice by SJC or our suppliers
[SID_243] Assessing Effectiveness
[SID_243] We have and will continue to review our policies and procedures as well as emerging laws and legislation to determine if there are any enhancements to be made
[SID_243] We intend to review our supplier questionnaire to establish continuous compliance, as well as
[SID_243] set key performance indicators where necessary to confirm our actions and risk management efforts are successful and serve to protect those most vulnerable
[SID_243] Conclusion SJC and its subsidiaries remain dedicated to sustained and earnest growth in all areas of our organization and business practices
[SID_243] This includes our assurance to maintain ethical conduct, fair treatment, and human rights policies and practices
[SID_243] We intend to review and revise our policies and due diligence processes to continue to best serve our communities and help prevent modern slavery
[SID_243] Approval and Attestation This report has been approved by the governing body of SJC
[SID_243] 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 or entities listed above
[SID_243] 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 listed above
[SID_243] Tony Gagliano Chief Executive Officer SJC May 22, 2024
[SID_252] Transparency in Supply Chain Statement Reporting for January through December 2023 Introduction The Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act (Supply Chains Act), California Transparency in Supply Chains Act (SB 657), and the United Kingdom Modern Slavery Act 2015 requires certain businesses to provide disclosures concerning their efforts to address the issues of forced labor and child labor in their supply chains, to provide consumers the ability to make better and more informed choices about the products they buy and companies they support
[SID_252] The business entity Columbia Sportswear Company (CSC) believes forced labor, child labor, modern slavery and human trafficking are egregious issues; we are committed to doing due diligence within our operations to minimize the risk and to remediate any found occurrence of these issues in our supply chain
[SID_252] Company Information CSC was founded in 1938 in Portland, Oregon, as a small, family-owned, regional hat distributor and incorporated in 1961
[SID_252] CSC is headquartered in Portland, Oregon USA
[SID_252] We connect active people with their passions by designing, developing, marketing, and distributing our outdoor, active and everyday lifestyle apparel, footwear, accessories and equipment products to meet the diverse needs of our customers and consumers under four primary brands: Columbia, SOREL, Mountain Hard Wear, and prAna
[SID_252] CSC is a commercial retailer
[SID_252] We sell our products in more than 100 countries and operate in four geographic segments: United States ("U.S."), Latin America and Asia Pacific ("LAAP"), Europe, Middle East, and Africa ("EMEA"), and Canada
[SID_252] We sell our products through a mix of distribution channels: wholesale distribution, international distributors, direct-to-consumer ("DTC") distribution, retail, and through licensing certain of our trademarks across a range of apparel, accessories, equipment, footwear, and home products
[SID_252] A list of our subsidiaries can be found in our 2024 Form 10-K, exhibit 21.1
[SID_252] CSCs annual, worldwide, gross receipts exceed $100M US and $40M CAN, and annual turnover exceeds 36M
[SID_252] Sourcing and Manufacturing CSC does not own, operate, or manage manufacturing facilities
[SID_252] The vast majority of our products are manufactured by contract manufacturers located outside the United States, and none in Canada
[SID_252] We seek to establish and maintain long-term relationships with key manufacturing partners who share our values
[SID_252] We manage our supply chain from a global and regional perspective and adjust as needed to changes in the global production environment, including political risks, factory capacity, import limitations and costs, raw material costs, availability and cost of labor, and transportation costs
[SID_252] In 2023, our apparel, accessories and equipment products for our wholesale and direct-to- consumer ("DTC") businesses were manufactured into finished goods in 15 countries
[SID_252] In 2023, finished goods manufacturers in Vietnam, Bangladesh, Indonesia, and India produced approximately 40%, 20%, 15% and 10%, respectively, of these products
[SID_252] Five of the largest contract finished goods manufacturers account for approximately 30% of our apparel, accessories and equipment production, with the largest manufacturer accounting for approximately 10%
[SID_252] In 2023, our footwear products for our wholesale and DTC businesses were manufactured into finished goods in five countries
[SID_252] In 2023, finished goods manufacturers in Vietnam and China produced approximately 75% and 20%, respectively, of these products