Fighting Against Forced Labour and Child Labour in Supply Chains Act
Annual Report

Questionnaire

Identifying information

Questions marked with an asterisk (*) are mandatory.

1. *This report is for which of the following?

  • Entity: Corporation

2. *Legal name of reporting entity or government institution:

  • Canada Bread Company, Limited/Boulangerie Canada Bread, Limitée

3. *Financial reporting year:

  • December 31, 2023

4. *Is this a revised version of a report already submitted this reporting year?

  • No

4.1 *If yes, identify the date the original report was submitted.

  • N/A

4.2 *Describe the changes made to the original report, including by listing the questions or sections that were revised (1,500 character limit).

  • N/A

5. For entities only: Business number(s):

  • 867 320 095

6. For entities only: *Is this a joint report?

  • Yes

6.1 *If yes, identify the legal name of each entity covered by this report.

  • Natural Bakery Inc.

6.2 Identify the business number(s) of each entity covered by this report (if applicable).

  • 103 838 819

7. For entities only: *Is the entity also subject to reporting requirements under supply chain legislation in another jurisdiction?

  • No

7.1 *If yes, indicate the applicable law(s). Select all that apply.

  • N/A

8. For entities only: *Which of the following categorizations applies to the entity? Select all that apply.

  • Canadian business presence (select all that apply):
    • ✓ Has a place of business in Canada
    • ✓ Does business in Canada
    • ✓ Has assets in Canada
  • Meets size-related thresholds (select all that apply):
    • ✓ Has at least $20 million in assets for at least one of its two most recent financial years
    • ✓ Has generated at least $40 million in revenue for at least one of its two most recent financial years
    • ✓ Employs an average of at least 250 employees for at least one of its two most recent financial years

9. For entities only: *Which of the following sectors or industries does the entity operate in? Select all that apply. (Required)

  • Manufacturing
  • Wholesale trade
  • Distributor

10. For entities only: *In which country is the entity headquartered or principally located?

  • Canada

10.1 If in Canada: *In which province or territory is the entity headquartered or principally located?

  • Ontario (for Canada Bread Company, Limited/Boulangerie Canada Bread, Limitée)
  • Manitoba (for Natural Bakery Inc.)

11. For government institutions only: *Is this a report for a federal Crown corporation or a subsidiary of a federal Crown corporation? (Required)

  • N/A

11.1 *If yes, which of the following sectors or industries does the Crown corporation or subsidiary operate in? Select all that apply. (Required)

  • N/A

11.2 *If yes, in which province or territory is the Crown corporation or subsidiary headquartered or principally located? (Required)

  • N/A

Annual Report

Reporting for entities

1. *What steps has the entity taken in the previous financial year 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 by the entity or of goods imported into Canada by the entity? Select all that apply. (Required)

  • Conducting an internal assessment of risks of forced labour and/or child labour in the organization's activities and supply chains
  • Developing and implementing an action plan for addressing forced labour and/or child labour
  • Gathering information on worker recruitment and maintaining internal controls to ensure that all workers are recruited voluntarily
  • Addressing practices in the organization's activities and supply chains that increase the risk of forced labour and/or child labour
  • Developing and implementing due diligence policies and processes for identifying, addressing and prohibiting the use of forced labour and/or child labour in the organization's activities and supply chains
  • Developing and implementing child protection policies and processes
  • Developing and implementing anti-forced labour and/or -child labour contractual clauses
  • Developing and implementing anti-forced labour and/or -child labour standards, codes of conduct and/or compliance checklists
  • Monitoring suppliers
  • Enacting measures to provide for, or cooperate in, remediation of forced labour and/or child labour
  • Developing and implementing grievance mechanisms
  • Engaging with supply chain partners on the issue of addressing forced labour and/or child labour

2. Please provide additional information describing the steps taken (if applicable) (1,500-character limit).

  • N/A

3. *Which of the following accurately describes the entity's structure? (Required)

  • Corporation

4. *Which of the following accurately describes the entity's activities? Select all that apply. (Required)

  • Producing goods (including manufacturing, extracting, growing and processing)
    • in Canada
  • Selling goods
    • in Canada
    • outside Canada**
  • Distributing goods
    • in Canada
  • Importing into Canada goods produced outside Canada
  • Controlling an entity engaged in producing, selling or distributing goods in Canada, or importing into Canada goods produced outside Canada

5. Please provide additional information on the entity's structure, activities and supply chains (1,500-character limit).

  • **Sell goods to customers based outside Canada.

6. *Does the entity currently have policies and due diligence processes in place related to forced labour and/or child labour?

  • Yes

6.1 *If yes, which of the following elements of the due diligence process has the entity implemented in relation to forced labour and/or child labour? Select all that apply.

  • Embedding responsible business conduct into policies and management systems
  • Tracking implementation and results
  • Providing for or cooperating in remediation when appropriate

7. Please provide additional information on the entity's policies and due diligence processes in relation to forced labour and child labour (if applicable) (1,500-character limit).

N/A

8. *Has the entity identified parts of its activities and supply chains that carry a risk of forced labour or child labour being used? (Required)

  • Yes, we have started the process of identifying risks, but there are still gaps in our assessments.

8.1 *If yes, has the entity identified forced labour or child labour risks related to any of the following aspects of its activities and supply chains? Select all that apply. (Required)

  • The types of products it sources
  • The raw materials or commodities used in its supply chains
  • Tier one (direct) suppliers
  • Tier two suppliers
  • The use of forced labour
  • The use of child labour

9. *Has the entity identified forced labour or child labour risks in its activities and supply chains related to any of the following sectors and industries? Select all that apply. (Required)

  • Agriculture, forestry, fishing and hunting

10. Please provide additional information on the parts of the entity's activities and supply chains that carry a risk of forced labour or child labour being used, as well as the steps that the entity has taken to assess and manage that risk (if applicable) (1,500-character limit).

  • N/A

11. *Has the entity taken any measures to remediate any forced labour or child labour in its activities and supply chains? (Required)

  • Yes, we have taken remediation measures and will continue to identify and address any gaps in our response.

11.1 *If yes, which remediation measures has the entity taken? Select all that apply. (Required)

  • Actions to prevent forced labour or child labour and associated harms from reoccurring
  • Grievance mechanisms

12. Please provide additional information on any measures the entity has taken to remediate any forced labour or child labour (if applicable) (1,500-character limit).

At a global level, we have identified social risks in our supply chain although not with direct suppliers. We are working with suppliers on transformation projects to move the industry forward.

13. *Has the entity taken any measures to remediate the loss of income to the most vulnerable families that results from any measure taken to eliminate the use of forced labour or child labour in its activities 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.

14. Please provide additional information on any measures the entity has taken to remediate the loss of income to the most vulnerable families that results from any measure taken to eliminate the use of forced labour or child labour in its activities and supply chains (if applicable) (1,500-character limit).

  • N/A

15. *Does the entity currently provide training to employees on forced labour and/or child labour? (Required)

  • Yes

15.1 *If yes, is the training mandatory? (Required)

  • Yes, the training is mandatory for some employees. ***

16. Please provide additional information on the training the entity provides to employees on forced labour and child labour (if applicable). (1,500-character limit).

  • *** Training is mandatory for salaried employees.

17. *Does the entity currently have policies and procedures in place to assess its effectiveness in ensuring that forced labour and child labour are not being used in its activities and supply chains? (Required)

  • Yes

17.1 *If yes, what method does the entity use to assess its effectiveness? Select all that apply. (Required)

  • Setting up a regular review or audit of the organization's policies and procedures related to forced labour and child labour

18. Please provide additional information on how the entity assesses its effectiveness in ensuring that forced labour and child labour are not being used in its activities and supply chains (if applicable). (1,500-character limit).

  • Through our supplier engagement in key raw materials like palm, cocoa and sugar, we identify action plans to mitigate risk of human rights issues. We understand that these issues can arise further down our supply chain (tier 2 and further), so it is important to us to ensure that our suppliers are aware of the risks and are working to eliminate them in their supply chain. As well, we have a grievance mechanism that we leverage to address social and environmental issues in our supply chain, including forced labour.

May 30, 2024