Modern Slavery Act

Canadian Statement Against Forced Labour and Child Labour in Supply Chains 

pursuant to an Act to enact theFighting Against Forced Labour and Child Labour in

Supply Chains Act and to amend the Customs Tariff,referred to as Canada's "Modern Slavery Act” (the "Act") 

for the year ending 2/3/2024

 

1. INTRODUCTION:
   This is a statement made by Frank Bracken, EVP, Chief Commercial Officer, and director of Foot Locker Canada Co. ("Foot Locker Canada Co." or "the Company") on behalf of the Company, in respect of the Act, as referenced above. Foot Locker Canada Co. is a corporation incorporated pursuant to the laws of Nova Scotia.
   
   
2. REPORTING ENTITY:
   This report concerns reporting entity, Foot Locker Canada Co., a retail trade entity, business number 134482702.
   
   The reporting period of this report is 1/29/2023-2/3/2024.
   
   Although Foot Locker Canada Co. is not subject to reporting requirements under supply chain legislation in other jurisdictions, its parent Company, Foot Locker, Inc., which is headquartered in the United States, is subject to supply chain legislation including the United Kingdom's Modern Slavery Act 2015, California's Transparency in Supply Chains Act, and the Uygher Forced Labour Prevention Act.
   
   Foot Locker Canada Co. meets the applicable legislative requirements concerning business, size, revenue thresholds for reporting.
   
   
3. STRUCTURE, ACTIVITIES AND SUPPLY CHAINS:
   Foot Locker Canada Co. is a Canada Corporation that engages in selling goods in Canada, distributing goods in Canada, and importing goods in Canada produced outside of Canada. Foot Locker Canada Co. engages in the sale of retail goods (footwear, apparel, and accessories).
   
   
4. POLICIES AND DUE DILIGENCE PROCESSES IN RELATION TO FORCED LABOUR AND CHILD LABOUR: 
   Foot Locker Canada Co. has implemented policies and due diligence processes related to managing the risk of forced and child labour, including (1) embedding responsible business conduct into policies and systems; (2) identifying and assessing adverse impacts to operations, supply chains and business relationships; (3) ceasing, preventing and mitigating those adverse impacts; (4) tracking implementation and results; (5) communicating to stakeholders how impacts are addressed; and (6) remediation of cooperation when necessary.
   
   Our Global Sourcing Guidelines are available at https://investors.footlocker-inc.com/gsg, and the Global Human Rights Policy is available at https://investors.footlocker-inc.com/humanrights.
   
   
5. PARTS OF BUSINESS AND SUPPLY CHAINS THAT CARRY A RISK OF FORCED LABOUR AND CHILD LABOUR AND STEPS TAKEN TO ASSESS AND MANAGE THAT RISK:
   We recognize apparel is a potential area of risk and by its nature contains risk of forced and child labour. However, through our compliance practices and policies, we have performed due diligence to minimize risk in our supply chain. In addition, Foot Locker Canada Co. continues to conduct regular assessments in an effort to strive to identify new and emerging risks. Among the considered in assessing risk in our supply chain are the types of products we produce, sell, distribute, and import, along with the types of products we source. We also assess the locations of our activities and factories. An additional consideration is the raw materials used in our supply chains, such as cotton. Lastly, our risk assessment includes a review of our Tier 1, direct suppliers who may outsource, contract, or subcontract labour.
   
   The Company uses various methods to prevent and reduce the risk of forced labour and child labour in our supply chain. Such activities include the following:
   
   

   ·       Supply Chain Mapping;

   ·       Internal assessments of risks of forced and child labour in our activities and supply chains;

   ·       Developing and implementing action plans for addressing forced and child labour;

   ·       Gathering information, via our audit process on worker recruitment to ensure workers all workers are recruited voluntarily;

   ·       Developing and implementing policies and processes for identifying, addressing, and prohibiting the use of forced and child labour in our activities and supply chains;

   ·       Prioritizing efforts on the most severe risks of forced and child labour;

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

   ·       Developing and implementing child protection policies and processes;

   ·       Developing and implementing anti-forced and child labour contractual clauses, standards, codes of conduct, and compliance checklists;

   ·       Auditing and monitoring suppliers;

   ·       Enacting measures to provide for, cooperate in, and remediate forced and child labour; and

   ·       Developing and implementing procedures to track vendor performance in addressing forced and child labour. 

   
   
6. MEASURES TAKEN TO REMEDIATE FORCED LABOUR AND CHILD LABOUR:
   Foot Locker Canada Co. has not taken measures to remediate forced or child labour because we have not identified any actual forced or child labour in our activities and supply chains.
   
   
7. MEASURES TAKEN TO REMEDIATE LOSS OF INCOME TO MOST VULNERABLE FAMILIES THAT RESULT FROM MEASURES TAKEN TO ELIMINATE USE OF FORCED LABOUR AND CHILD LABOUR:
   Foot Locker Canada Co. has not taken measures to remediate loss of income to the most vulnerable families that result from measures taken to eliminate use of forced and child labour because we have not identified any use of forced or child labour in our activities and supply chains during the applicable reporting period.
   
   
8. TRAINING PROVIDED TO EMPLOYEES ON FORCED LABOUR AND CHILD LABOUR:  
   Foot Locker Canada Co. provides training to employees who are engaged in the entity's supply chain compliance to identify and deal with any potential instances of forced and or child labour. Training is provided from the parent company and from third-party providers.
   
   
9. HOW ENTITY ASSESSES ITS EFFECTIVENESS IN ENSURING THAT FORCED LABOUR AND CHILD LABOUR IS NOT BEING USED IN ITS BUSINESS AND SUPPLY CHAINS: 
   The Company regularly reviews and audits the organization's policies and procedures related to forced and child labour. We partner with external organizations to conduct independent reviews and audits of the organization's actions. In addition , we work with our suppliers to measure the effectiveness of their actions in addressing forced and child labour, including tracking performance indicators. For additional information regarding our policies and procedures related to forced and child labour, please reference the Foot Locker, Inc. Impact Report.
   

    

   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. 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. For clarity, I am providing this attestation in my capacity as an officer of Foot Locker Canada Co. and not in my personal capacity. I have the authority to bind Foot Locker Canada Co.
    

   Name: Franklin R. Bracken

   Title: President, Foot Locker Canada Co.

   Date:  5/31/2024