Modern Slavery Report GFCO.

REPORT RE FIGHTING AGAINST FORCED LABOUR AND CHILD LABOUR IN SUPPLY CHAINS ACT

Entity Information

Entity Name: The Good Flour Corp.

Entity Address: 5791 Sidley Street, Burnaby, B.C. V5J 5E6

Subsidiary Entities Covered by Report: The Good Flour Milling Corp., The Good Flour USA Corp.

 

 

 

Section 11 Information

 

(1) Describe the steps the entity has 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.

The Good Flour Corp. and its subsidiaries (collectively the “Company”) recognize that by the nature of its business, there is a risk that its operations could cause, contribute to, or be directly linked to, modern slavery. Potential modern slavery risk exposures in our operations have been assessed as follows:

• Employees/labour – a risk of “causing” or “contributing to” modern slavery if any of our employees or temporary workers were in exploitative situations.

• Community – a risk of “contributing” or being “directly linked” to modern slavery if our activity contributes to modern slavery in the community.

 

Our Supplier Approval Policy is designed to ensure the stringent assessment of all suppliers, mitigating potential risks related to ingredients, product safety, authenticity, legality, quality, and gluten-free integrity. Prior to the procurement of any product, suppliers must submit a comprehensive set of documents for analysis by our quality assurance team. Upon successful evaluation, approved suppliers are added to our supplier approval list.

Integral to our policy, we included a Letter of Guarantee, signed by each supplier, affirming their commitment to compliance with labour legislation and the prohibition of forced and/or child labour.

On an annual basis, our internal team conducts a thorough Performance Review of Suppliers, identifying areas of improvement and potential risks. We added a specific component to this review that focuses on monitoring and addressing issues related to forced labour and child labour. Our team is required to report any news or developments in this regard that may be linked to our suppliers.

2

 

To fortify our commitment internally, our documented Hiring Process explicitly prohibits the employment of individuals below the legal working age in Canada. The team responsible for the hiring process meticulously verifies the personal identification of candidates to prevent any non-conformities. All job opportunities are publicly advertised, and candidates apply voluntarily, ensuring a transparent and ethical recruitment process.

During the most recently completed financial year, the Company took initial steps to mitigate the risk of modern slavery in its supply chain. The key activities undertaken included providing suppliers and contractors with new certifications on modern slavery.

There have not been any modern slavery issues identified during the most recently completed financial year.

(3)(a) Entity structure, activities and supply chains

 

The Company’s only production of goods is the milling, blending, and packaging of dry ingredients into plastic bags for food service and into poly-plastic pouches for retail.

Products are sold in Canada and USA.

Our ingredients pass through a rigorous Approval Process and some of them are imported from other countries (e.g. India, Thailand, USA)

(3)(b) Entity policies and its due diligence processes in relation to forced labour and child labour

To fortify our commitment internally, our documented Hiring Process explicitly prohibits the employment of individuals below the legal working age in Canada. The team responsible for the hiring process meticulously verifies the personal identification of candidates to prevent any non-conformities. All job opportunities are publicly advertised, and candidates apply voluntarily, ensuring a transparent and ethical recruitment process.

Also, following the probation period (3 months post-hiring), employees undergo a comprehensive Performance Review. This review provides an open platform for team members to share valuable suggestions, provide feedback, or voice any concerns they may have. Additionally, we have implemented an anonymous reporting system through which employees can freely report any issues or concerns.

Our company places a strong emphasis on Food Safety and Food Security. We recognize that engaging in forced labour and or child labour not only goes against our ethical principles but also poses a significant risk to food security, increasing the likelihood of sabotage and/or unsafe practices. To uphold the highest standards, we closely monitor and assess the behaviors and conduct of our team members. This ensures that our commitment to ethical practices and maintaining a secure food environment remains unwavering.

(3)(c) The parts of Entity’s business and supply chains that carry a risk of forced labour or child labour being used and the steps it has taken to assess and manage that risk

With respect to the Company’s Canadian operations it has assessed the risk of child labour and forced labour as low due to its due diligence activities in verifying age status, paying a wage that is at or above the prevailing minimum wage in the Province of British Columbia and confirming employees are employed voluntarily.

3

With respect to its supply chain, the Company has determined that there is a low risk of forced labour or child labour in its supply chain due to almost all of the Entity’s suppliers being located in Canada or the United States. In order to manage the risk the Company has begun to require supplier certifications and contractual provisions regarding forced labour and child labour risk reduction practices and procedures.

(3)(d) Any measures taken to remediate any forced labour or child labour

The Company has not taken any measures to remediate any forced labour or child labour.

(3)(e) Any measures 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

The Company has not 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.

(3)(f) The training provided to employees on forced labour and child labour

Employees are trained in hiring practices to ensure that all employees are of legal age to work in the Province of British Columbia, provided relevant information on applicable minimum wages and directed to ensure that all employees are voluntarily employed. The Company has not yet implemented training on identifying forced labour or child labour risks in its supply chain but is in the process of establishing policies and training employees on such policies.

(3)(g) How the entity assesses its effectiveness in ensuring that forced labour and child labour are not being used in its business and supply chains

The Company does not have a process in place to ensure the effectiveness of ensuring that forced labour and child labour are not being used in its business or supply chains.

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.

Full name: Hamid Salimian

Title: CEO and Director

Date: May 21, 2024

Signature: