ArjoHuntleigh Magog Inc. Report

On Forced Labour in Canadian Supply Chains

1.    Purpose

This report is for the legal entity named ArjoHuntleigh Magog Inc. (hereinafter referred as “Arjo Magog”). It is not a revised version of a report already submitted or a joint report and covers the 2023 fiscal year.

The purpose of this report is to establish Arjo Magog’s reporting obligations under the Fighting Against Forced Labour and Child Labour in Supply Chains Act (hereinafter referred as “Act”)

2.    Business Overview

Arjo Magog is an entity headquartered in the province of Quebec, Canada, with business number 849904545 and a corporate structure.

Arjo Magog operates its activities in the sectors of manufacturing and distribution of medical devices. The elements used to describe the entity's activities, according to the various options provided in the questionnaire, are as follows:

a) the production of goods (including manufacturing and processing) in Canada, the sale of goods outside of Canada; and 

b) the import into Canada of goods produced outside of Canada, and the control of an entity engaged in producing, selling or distributing goods in Canada or outside Canada, or importing into Canada goods produced outside Canada

3.    Reporting Obligations

Arjo Magog is not subject to reporting requirements under supply chain legislation in any other jurisdiction, nor is it listed on a stock exchange in Canada. However, it has a Canadian business presence as it has a place of business in Canada, does business in Canada and has assets in Canada.

It also meets two (2) size-related thresholds: it has at least $20 million in assets for at least one of its two most recent financial years, and has generated at least $40 million in revenues for at least one of its two most recent financial years.

4.    Measures

During the previous financial year, the measures taken by Arjo Magog 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 goods imported into Canada by the entity, were as follows:

a)    Gathering information on worker recruitment and maintaining internal controls to ensure that all workers are recruited voluntarily;

b)    Addressing practices in the organization’s activities and supply chains that increase the risk of forced labour and/or child labour;

c)     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;

d)    Requiring suppliers to have in place policies and procedures for identifying and prohibiting the use of forced labour and/or child labour in their activities and supply chains;

e)    Developing and implementing child protection policies and processes;

f)      Developing and implementing anti-forced labour and/or – child labour contractual clauses;

g)    Developing and implementing anti-forced labour and/or – child labour standards, codes of conduct and/or compliance checklists;

h)    Auditing suppliers ;

i)      Monitoring suppliers ;

j)      Developing and implementing training and awareness materials on forced labour and/or child labour; and

k)     Engaging with supply chain partners on the issue of addressing forced labour and/or child labour.

Arjo Magog currently has policies and due diligence processes in place related to forced labour and/or child labour. Arjo Magog has developed a customized Code of Conduct for suppliers and business partners. Based on UN Global Compact – Arjo Magog supports and follows the ten (10) principles that apply to human rights, labor, the environment and anti-corruption.

The elements of the due diligence process that Arjo Magog has implemented in relation to forced labor and/or child labor are:

a)    Embedding responsible business conduct into policies and management systems;

b)    Identifying and assessing adverse impacts in operations, supply chains and business relationships;

c)     Ceasing, preventing or mitigating adverse impacts;

d)    Tracking implementation and results ;

e)    Communicating how impacts are addressed; and

f)      Providing for or cooperating in remediation when appropriate.

Arjo Magog has identified parts of its activities and supply chains that carry a risk of forced or child labor to the best of its knowledge, and will continue to strive to identify emerging risks.

The aspects of its activities and supply chains for which Arjo Magog has identified forced labour or child labour risks:

a)    The sector or industry it operates in;

b)    The locations of its activities, operations or factories;

c)     The raw materials or commodities used in its supply chains;

d)    Tier one (direct) suppliers ;

e)    The use of outsourced, contracted or subcontracted labour;

f)      The use of forced labour; and

g)    The use of child labour.

Arjo Magog has internal procedures to go through a risk assessment with suppliers that evaluate if the supplier has a code of conduct policy and if it complies to local labor law. While we do not call out the Forced Labour requirements specifically, we do have a detailed supplier selection process.

Although Arjo Magog has been able to identify risks related to forced labor or child labor in its operations and supply chains in the medical device manufacturing and distribution sectors, however, no measures have been taken to remediate forced labor and/or child labor in its activities and supply chains as it has not identified any forced labor or child labor in the latter.

In addition thereof, Arjo Magog has not identified any loss of income for vulnerable families and therefore Arjo Magog has not taken any measures to remediate such loss that results from any measure taken to eliminate the use of forced or child labor in its activities and supply chains.

5.    Training

Training on forced labor and/or child labor is provided to all Arjo Magog employees. However, this training is mandatory only for employees who make contracting or purchasing decisions.

Arjo Magog has policies and procedures in place to assess its effectiveness in ensuring that forced labor and child labor are not being used in its activities and supply chains through the following methods:

a)    Setting up a regular review or audit of the organization’s policies and procedures related to forced labour and child labour;

b)    Tracking relevant performance indicators, such as levels of employee awareness, numbers of cases reported and solved through grievance mechanisms and numbers of contracts with anti-forced labour and child labour clauses; and

c)     Working with suppliers to measure the effectiveness of their actions to address forced labour and child labour, including by tracking relevant performance indicators.