Regula Supply Chain Regulation Compliance S-211 Bill
Forced Labour and Child Labour Report 2024
1. About This Report This report relates to the financial year ending December 31, 2024. It is published by Brault & Bouthillier Ltée (the “Company”) in compliance with Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “Act”), on behalf of itself and the following entities, each a wholly-owned subsidiary of the Company: Demco EnCouleurs Inc., Avron Foods Limited, Avron School & Day Care Supplies Inc., Avron Distribution Inc., Ilot 307 Inc. and Les Jouets Boom Inc. (hereinafter collectively referred to as the ”Company”, “B&B”, “we” or “our”). This report provides an overview of the steps taken by the Company within its last financial year to prevent and reduce the risk of forced labour or child labour in its activities and supply chain.
2. Preventing and reducing risks of forced labour and child labour
B&B strives to contribute to the learning and global development of children through our products and services. We are also dedicated to fostering a supportive and inclusive work environment where everyone can thrive, both professionally and personally. We expect our suppliers’ values to align with ours and we are committed to improving our practices to combat forced labour and child labour, involving our suppliers in this journey when appropriate. During the last financial year, we have taken steps to prevent and reduce risks that forced labour or child labour be used at any step of our production of goods in Canada or elsewhere or of goods imported into Canada by us, including the following: • we adopted and implemented a supplier code of conduct, a sustainability policy and a code of ethics applicable to employees, consultants and directors to ensure that we continue to uphold high human rights standards and responsible sourcing practices; • we developed a new supplier questionnaire as part of our due diligence and risk assessment process to identify potential risks of forced labour and child labour and to take appropriate action where necessary; • we put in place a supplier on-boarding and vetting process to ensure that potential suppliers meet B&B’s strict operational, ethical, and compliance standards; • we continued to gather information on worker recruitment and maintaining internal controls to ensure that all workers at B&B are recruited voluntarily and treated fairly; and • we maintained access to grievance mechanisms which enable employees to report any concerns or complaints they may have, which may include any forced labour or child labour issues. In 2025, the entire procurement team has been informed of the new policies and procedures in place, ensuring that all relevant personnel are aware and equipped to adhere to these enhanced guidelines.
Details of the above actions, amongst others, are set forth in this report.
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3. About Us & Our Supply Chain
Founded in 1944, B&B contributes to the learning and global development of children by providing a fun and educational collection of quality products and by offering training and consulting services to educators and parents who wish to see children achieve their full potential. With offices in Quebec and Ontario, our educational materials are distributed and sold to schools, day cares, hospitals, community services, resellers as well as parents. We provide a wide range of products, carefully selected from around the world and tested by our specialists, to ensure that they meet all aspects of quality, safety and relevance to the different educational programs in Canada and we partner with a number of not-for-profit organizations centered around the wellbeing of children. Our goods include educational and curriculum-based games, arts & crafts and creative material, science, technology, robotics, toys and games, furniture and layout planning, motor skills and physical education equipment, teaching support material, school supplies, etc. While most of these products are imported by us into Canada, we also have a manufacturing facility in Quebec that produces acrylic and poster paint which we sell to our customers. B&B sources its products from a variety of suppliers established in Canada (52.7%), in the USA (25%), in Europe (16.4%) and in Asia (5.9%). While we have limited visibility on our suppliers’ sourcing, we limit our risks by fostering long-lasting relationships with well-established and renown suppliers of the industry.
4. Policies and Due Diligence Processes
In our ongoing efforts to enhance diligence and mitigate risks associated with forced labour and child labour, the Company is actively incorporating responsible business practices into its policies. This proactive approach, which was reinforced in 2024, aims to address human rights risks within our operations and supply chains.
Employee Manuals and Code of Ethics
On their first day as an employee of B&B, all our employees meet with a human resources representative and are provided with a copy of the employee manual applicable to their workplace to further our commitment to establishing and maintaining a work environment where all individuals are treated with dignity and respect and are afforded fair and equitable treatment. These manuals include policies on health and safety, discrimination, conflicts of interest and corruption and explanations regarding the relevant employee grievance mechanism. Our manuals also provide for grievance mechanisms to effectively address any concerns or complaints that may arise, while protecting confidentiality of the whistleblower. The severity of each complaint is assessed by our human resources department and more serious cases are escalated to the Senior Leadership Team and trigger outside legal counsel involvement.
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In the context of the Act coming into force, we have initiated the review of our various employee manuals to integrate by reference our Code of Ethics adopted in 2024. The Code of Ethics includes guidance and policies on matters such as conflicts of interest, corruption and bribery, discrimination and harassment in the workplace, health and safety, human rights (including a strong stance against forced labour and child labour) and environmental responsibility.
Recruitment Process
B&B follows a rigorous recruitment process led by an accredited human resources professional.
We ensure that our workers are recruited voluntarily by posting job openings on publicly accessible platforms, allowing candidates to apply without any restrictions. Furthermore, we conduct interviews for all available positions and prioritize direct employment rather than relying on agency workers. In the rare instances that we are required to partner with employment agencies, such agencies are well-established service providers located and operating in Canada that exercise their activities in accordance with human rights. As of the date of this report, B&B does not employ foreign workers.
Employee Training
At B&B, we are strongly committed to acting ethically and with integrity and we expect the same of our staff. While we provide many resources to our workforce, including employee manuals, a Sustainability Policy and a Code of Ethics, to which our employees can refer to guide their decisions and ensure they align with our values, we have not yet been providing formal training to our staff with regards to their content and, more specifically, human rights issues. However, in 2025, all members of the procurement team have been provided with our updated policies and procedures with respect to forced labour and child labour risks, ensuring that our sourcing practices comply with the new standards.
Sustainability Policy
B&B is committed to doing business in a way that meets the needs of the present while contributing to an environmentally, socially, and economically sustainable future, which is why we recently adopted a Sustainability Policy. Our Sustainability Policy highlights our commitment to respect human rights, including by: • providing a healthy, safe and respectful working environment; • setting individual diversity, equity and inclusion goals to foster diverse representation and an inclusive environment within our workforce, executives and board of directors, fostering an inclusive, diverse and equitable corporate culture, and combating discrimination and prejudice in all its forms by deploying and supporting comprehensive programs to these ends; • ensuring that employment-related decisions are free from discrimination on grounds of race, ethnicity, gender, gender identity, sexual orientation, age, social class, disability, religious beliefs, nationality and political beliefs; • ensuring an environment of psychological security in which people have the freedom to be themselves; • promoting healthy lifestyle habits and physical and mental wellbeing in employees and communities; and • supporting our local communities.
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Supplier Code of Conduct
To reinforce our dedication to ethical business practices and promote the same values among our business partners, we recently adopted a Supplier Code of Conduct. The code outlines minimum standards that we expect our suppliers to follow in relation to social, environmental and ethical issues to ensure that working conditions at our suppliers and subcontractors are safe, that workers are treated with respect and dignity, that manufacturing processes or similar activities are environmentally responsible, and that business is done in a legal and ethical way. The Supplier Code of Conduct applies to all actors of the chain of suppliers of B&B and its affiliated companies and specifies that any breach of the code shall be considered a breach of contract with B&B. To reinforce this, we have revised our purchase orders to explicitly state that suppliers are required to adhere to the Supplier Code of Conduct. We intend to monitor the compliance of our suppliers with this code and take appropriate measures to address any non-compliance, where appropriate.
Due Diligence Processes
In the context of the Act coming into force, we engaged with our suppliers to know more about their human rights practices. By fostering open and ongoing dialogue, we have sought to gather information about the measures and policies our suppliers have in place to safeguard and promote human rights within their operations. In 2025, we distributed a new questionnaire to our new international suppliers and to those whose answers to the initial questionnaire sent in 2024 were deemed insufficient or incomplete. This new questionnaire was distributed to suppliers who collectively represented over 80% of our imports in the fiscal year 2024 across all business segments. Additionally, to ensure comprehensive coverage, we sent a questionnaire to international suppliers representing over 80% of our imports for each individual business segment. If the initial responses were deemed insufficient, required further clarification for an accurate assessment, or presented a risk that needed further investigation, a supplementary questionnaire was issued. The primary aim of these questionnaires is to identify potential risks of forced labour and child labour and to take appropriate action where necessary. Based on our initial survey and responses provided by our suppliers at the date of this report, we were able to confirm that the majority of our main business partners have adopted a supplier code of ethics and/ or conduct emphasizing the obligation to comply with all applicable laws and to encourage ethical and fair dealings in all aspects of their business. In 2025 and beyond, we intend to perform on-site visits to any supplier that has been identified as having material risks of forced labour and child labour risks through our supplier questionnaire.
5. Risk Assessment & Remediation Measures
We have started the process of identifying risks of forced and child labour in our supply chains, but the process remains ongoing. Many of our suppliers are renowned companies with which B&B has had regular and close dealings over a long period, and these suppliers are generally committed to high human rights standards and have procurement policies in place that discourage the use of forced and child labour, obtained ethics-related certifications or conducted audits of their own suppliers.
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However, we acknowledge our lack of visibility on our supply chain and our supplier’s sourcing and the fact that the risk of forced labour and child labour in the industry exists, given that our supply chain, including those of suppliers, extends into regions potentially facing greater risk of forced labour and child labour. To date, we have not been made aware of specific instances of forced labour or child labour and as such, no remediation measures were necessary to remediate any forced labour or child labour or to remediate any loss of income to vulnerable families resulting from any such measures. As evidenced by our Code of Ethics and in accordance with our strong commitment to conduct business with integrity and fairness, any allegations, disclosures or discoveries of forced labour or work involving children in supply chains in contravention of Canadian laws will be taken very seriously by B&B and we will ensure that an investigation is conducted as soon as possible. In such a case and where required, we will apply appropriate corrective measures to remediate any identified risk.
6. Assessing the Effectiveness of our Approach
We continue working on our efforts to identify, assess, and address forced labour and child labour risks within our operations and supply chain. As such and in accordance with our Sustainability Policy, we have tasked the Senior Leadership Team with the oversight of the application of the Sustainability Policy, as well as reporting to the Board of Directors with regards to the Company performance on sustainability priorities. Alongside the work of the Senior Leadership Team, we plan to continue to review our statements, policies, procedures, and practices periodically to determine whether any enhancements should be made to reinforce our commitment to prevent forced labour and child labour from taking place in our business and in any of our supply chains.
7. Approval and Attestation
This report was approved by the Board of Directors of Brault & Bouthillier Ltée on May 30, 2025 pursuant to paragraph 11(4)(b)(ii) of the Act and constitutes the joint report for the entities listed in the first section of this report for the financial year ending December 31, 2024. 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 Company. 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.
I have the authority to bind Brault & Bouthillier Ltée
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Full name: _____________________________________________________________________ Title: _____________________________________________________________________ Date: _____________________________________________________________________ Paul Le Brun Director May 30, 2025
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