Canadian Supply Chains Act

This Fighting Against Forced Labor and Child Labor in Supply Chains Act Report (“Report”) is published by Louis Vuitton Canada, Inc. (“LV Canada” or “We”), pursuant to Section 11 of the Fighting Against Forced Labor and Child Labor in Supply Chains Act, S.C. 2023 (the “Act”) and was approved by LV Canada’s Board on May 24, 2024. The Report is updated annually.

This Report outlines the steps LV Canada has taken during its previous financial year to prevent and reduce the risk that forced labor or child labor is used at any step of the production or exportation of goods into Canada.

LV Canada is committed to acting with integrity in all our dealings as a business and as an employer, and to promote ethical conduct, to enhance compliance with applicable laws and to protect the dignity and rights of all people connected to our business.  We strive to work ever more closely with our suppliers to ensure their workforce, and the workforce of their supply chains, including contractors, are treated with respect and dignity.

LV Canada is a subsidiary of Louis Vuitton Malletier SAS (“LVM”), which sells luxury and high-quality products under the Louis Vuitton trademark including luggage, leather goods, bags, ready-to wear, shoes, watches and fine jewelry, accessories, perfumes and cosmetics, stationery, home decoration, electronic devices, and accessories, to clients from our retail stores in Canada.

LV Canada has a number of policies and procedures, critical to our values and culture, that set out requirements for our employees, our suppliers, and their supply chains.

1. LVMH Employee Code of Conduct (the “Employee Code”)

The Employee Code, which applies to LV Canada employees, sets out the LVMH Group’s strict prohibition against forced labor and child labor and adherence to promoting human rights in its business endeavors.  All LV Canada employees are required to certify that they have read, understood and will comply with the Employee Code as part of their onboarding.  In addition, the Employee Code is available to all LV Canada employees on the Louis Vuitton Americas (“LVA”)  Ethics & Compliance intranet site.

2. LVMH Group Supplier Code of Conduct (the “Supplier Code”)

The Supplier Code, which applies to LV Canada suppliers, sets out the LVMH Group’s requirements for suppliers related to combating the risk of forced labor and child labor in their supply chains.  All LV Canada suppliers are required to certify their compliance with the Supplier Code as part of their onboarding process.

More specifically the Supplier Code states the following:

PROHIBITION OF CHILD LABOR

Work by children under the age of 16 is strictly prohibited. In countries where local laws set a higher age for child labor or set an age for completion of compulsory education higher than 16, the highest age is applicable. Workers under the age of 18 shall not perform any overtime or hazardous work or work a night shift. Suppliers may use lawful, legitimate, properly-managed workplace apprenticeship programs, such as student internships.

PROHIBITION OF FORCED LABOR AND HUMAN TRAFFICKING

The LVMH Group does not tolerate any form of abusive or illegal labor in its supply chain such as forced labor or human trafficking. All forms of forced labor, slavery, servitude or trafficking in human beings by Suppliers, as well as withholding identity papers or work permits or requiring workers to deposit a bond or the use of any other constraint, is strictly prohibited. All workers are entitled to accept or leave their employment freely. Suppliers must respect workers freedom of movement. Suppliers cannot require workers to work to repay a debt to them or to a third party.

The Supplier Code requires that LV Canada suppliers ensure that their own suppliers respect the principles set forth in the Supplier Code.  In addition, the Supplier Code requires suppliers to commit to establishing processes or mechanisms for their own employees and stakeholders, including a mechanism for them to raise issues or concerns in good faith without fear of retaliation.  The Supplier Code also provides suppliers with access to the LVMH Group Alert Line (“Alert Line”), which is an online interface that provides a confidential way of reporting good faith violations of the Supplier Code.    

LV Canada may take action against suppliers for non-compliance with the Supplier Code, such as requiring the supplier to take corrective action, suspending purchases, refusing to take delivery of products until the violation(s) is remedied to LV Canada’s satisfaction, or termination of its business relationship with the supplier.  

3. LVA Supplier Due Diligence Procedure

All new LV Canada suppliers are required to complete the LVA Supplier Due Diligence Procedure as part of their onboarding process.  This Procedure consists of three requirements: (1) the supplier’s completion of a questionnaire, (2) screening the supplier against a wide array of databases designed to identify elevated risk with respect to forced labor, child labor, and other compliance areas, and (3) the supplier’s certification of the Supplier Code, as discussed above.  If elevated risk is discovered as a result of these initial due diligence steps, then LVA’s Legal Department is required to review and approve the supplier.

·       The questionnaire includes questions related to the supplier’s business activities in specific countries and industry sectors that present heightened risk for forced and child labor and other regulatory compliance matters, as well as questions related to the supplier’s previous investigations or violations related to international trade and other regulatory compliance matters.

·       Each supplier is screened against restricted party lists related to forced labor, including the Uyghur Forced Labor Prevention Act (“UFLPA”) Entity List, a list of entities in Xinjiang Autonomous Region of China identified as mining, producing, or manufacturing wholly or in part any goods, wares, articles and merchandise with forced labor.

·       The supplier’s certification of the Supplier Code provides LV Canada with broad audit and termination rights, including to conduct compliance audits at any time to verify the supplier’s compliance with the Supplier Code.  Furthermore, in connection with these audits, a supplier may be required to grant access to LV Canada or its representatives to the supplier’s place of business to demonstrate compliance with the Supplier Code.  To the extent any violations of the Supplier Code are discovered, LV Canada may require the supplier to correct the violation or terminate its business relationship with the supplier.

4. LVA Anticorruption Policy

All LV Canada employees are required to follow the LVA Anticorruption Policy describing applicable anticorruption laws, LVA’s anticorruption policies and procedures, and illustrative hypotheticals.  LVA’s anticorruption policies and procedures include: (i) the previously mentioned LVA Supplier Due Diligence Procedure and (ii) LVA Legal Department pre-approval of any gifts, meals, entertainment, or travel (“GMET”) provided to government officials.

LV Canada employees must report any suspected violation of the LVA Anticorruption Policy to the LVA Legal Department and/or the LVMH Alert Line, which is available to all LV Canada employees.

5. LVA International Trade Policy

All LV Canada employees are required to follow the LVA International Trade Policy, which provides policies and procedures designed to prevent sanctions and international trade (i.e., import and export) law violations, including those related to forced and child labor.

LV Canada employees must report any suspected violation of the LVA International Trade Policy to the LVA Legal Department and/or the LVMH Alert Line, which is available to all LV Canada employees.

6. Participation in Multi-Party Initiatives in High-Risk Areas

·       Specific traceability requirements applicable to the leather and cotton sectors have been incorporated into the LIFE 360 program.  Leather traceability is taken into account via the score resulting from audits of the Leather Working Group standard.

·       A risk analysis focused primarily on risks associated with LV Canada’s supply chain was carried out with the assistance of Verisk Maplecroft, an external service provider specialized in analyzing political, economic, social and environmental risks.

LV Canada recognizes that any instances of forced labor or child labor should be addressed on first-priority basis.  To date, no instances of forced labor or child labor have been discovered in our business or supply chains. Therefore, no remediation measures have been necessary.

LV Canada also recognizes that any remediation measures potentially have the unintended consequence of inflicting loss of income on vulnerable persons.  As no instances of forced labor or child labor have been discovered in our business or supply chains, We have not taken any remediation measures that would have led to loss of income to the most vulnerable families.

LV Canada also recognizes that any remediation measures potentially have the unintended consequence of inflicting loss of income on vulnerable persons.  As no instances of forced labor or child labor have been discovered in our business or supply chains, We have not taken any remediation measures that would have led to loss of income to the most vulnerable families.

It is understood that forced labor and child labor practices can occur in any country or industry sector and that there are some factors that can increase the risk of forced labor and child labor, such as discrimination based on ethnicity, gender, caste, tribal group, religion and bribery and corruption.

In response, LV Canada employees are required to complete:

·       a mandatory Unconscious Bias e-Learning module to learn how bias impacts them personally and in the workplace and to show the benefits of workplace diversity.  All LV Canada corporate and retail new hires are required to complete the training. A record of attendance is maintained; and

·       a mandatory anticorruption e-Learning module covering the Employee Code and LVA’s anticorruption compliance program.  The training covers applicable anticorruption laws, LVA’s anticorruption policies and procedures, and illustrative hypotheticals.  All LV Canada new corporate hires are required to complete this training within 30 days of their start date.  At the end of this training, LV Canada employees are required to certify that they understood and completed the training and will comply with the Employee Code. The training enabled LV Canada to reduce business risk of non-compliance through efficient processes and reliable data and reporting.

The policies and procedures and employee trainings mentioned in this Report are available to all LV Canada employees on the LVA intranet site.

LV Canada assesses its effectiveness in ensuring that forced labor and child labor are not being used in its business and supply chain through monitoring and auditing processes, conducted by LV Canada and LVA, designed to ensure the policies and procedures and training outlined in this Report are carefully adhered to by our suppliers and employees.

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. 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.

__________________________

Lanessa Elrod
President and CEO
May 24, 2024

I have the authority to bind Louis Vuitton Canada, Inc.