Aspire Bakeries B.C. ULC Compliance with Canadian Bill S-211

This report describes Aspire Bakeries B.C. ULC's (Aspire Bakeries) position and approach to the important issues of Child Labour and Slavery and Human Trafficking. In compliance with Canadian Bill S-211, Aspire Bakeries is disclosing our policies and procedures established to combat child labour, slavery, and human trafficking.

Steps Taken to Address Child Labour & Slavery and Human Trafficking:

  • Based on our extensive review and analyses, Aspire Bakeries has not identified legal work duties for anyone under eighteen within our bakery operations. As a matter of policy, Aspire Bakeries does not hire anyone under the age of eighteen for any purpose. During the hiring process, the age of the prospective employee is verified by Aspire Bakeries' Human Resources Department.
  • Aspire Bakeries requires verification of legal right to work in Canada by verifying the Social Insurance Number (SIN) that all legal Canadian residents have.
  • All agencies supplying Aspire Bakeries with temporary workers are required to abide by this policy and furnish the date of birth for every worker placed within an Aspire Bakeries facility at the time of placement. No workers under the age of eighteen are placed at Aspire Bakeries facilities.
  • Our Internal Code of Conduct expressly prohibits slavery and human trafficking. Aspire Bakeries' associates and management who have direct responsibility for supply chain management complete annual training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chain of products.
  • Aspire Bakeries requires our raw material suppliers to comply with laws regarding child labour and slavery and human trafficking in the countries in which they are doing business. Aspire Bakeries requires our suppliers to sign our Supplier Code of Conduct which specifically prohibits child labour, slavery, and human trafficking.
  • Aspire Bakeries expressly reserves the right to verify its suppliers' compliance with the Supplier Code of Conduct. If Aspire Bakeries becomes aware of any actions or conditions that are not in compliance with the Supplier Code of Conduct, Aspire Bakeries reserves the right to demand corrective measures. Furthermore, Aspire Bakeries reserves the right to terminate an agreement with any supplier who does not comply with the Supplier Code of Conduct.

Human Rights Section from Employee Code of Conduct:

Aspire Bakeries prohibits the use of:

  • Child Labour: Aspire Bakeries complies with all applicable child labour laws and prohibits using workers under the legal age of employment in the relevant country or where work interferes with schooling requirements under applicable local laws and regulations. Aspire Bakeries' policy is not to hire any worker who is less than eighteen years old, regardless of the legal age of employment in the relevant country.
  • Forced Labour: Aspire Bakeries prohibits the use of prison labour, forced labour, labour under any form of indentured servitude, physical punishment, confinement, threats of violence, or any other forms of abuse. Aspire Bakeries will not tolerate any psychological, verbal, sexual or physical harassment or any other form of abuse and will comply with all applicable laws on harassment and abuse of associates.
  • Slavery & Human Trafficking: Aspire Bakeries forbids the use of slavery or human trafficking (including debt bondage) and abides strictly to local acts such as the California Supply Chain Transparency Act of 2010. Associates must comply in all countries in which Aspire Bakeries operates facilities or does business and with Canada's Immigration and Refugee Protection Act.

Human Rights Section from Supplier Code of Conduct:

We expect our suppliers to conduct their activities in a manner that respects human rights as set out in the United Nations Universal Declaration of Human Rights. Minimally, we expect suppliers to comply with the following employment-related practices:

  • Applicable Local Labour Laws: All business activities of suppliers must comply with all national and local legal requirements along with published industry standards pertaining to employment and manufacturing in the applicable country. Suppliers must demonstrate that all employees are eligible to work in the applicable country.
  • Forced Labour: Suppliers must not use prison labour, forced labour, labour under any form of indentured servitude, physical punishment, confinement, threats of violence, or any other forms of abuse. Suppliers shall not retain workers' government-issued identification, passports or work permits as a condition of employment.
  • Slavery & Human Trafficking: The use of slavery or human trafficking (including debt bondage) by suppliers is forbidden.
  • Child Labour Practices: Suppliers must comply with all applicable child labour laws and are prohibited from using workers under the legal age of employment in the relevant country or where work interferes with schooling requirements under applicable local laws and regulations. Suppliers shall not hire any worker who is less than fifteen years old regardless of the legal age of employment in the relevant country. Suppliers cannot assign any worker to work in any Aspire Bakeries facility who is less than eighteen years of age, regardless of the legal age of employment in the relevant country. In the event of an incident of child labour at a supplier's facility, Aspire Bakeries must be notified of the incident, and the supplier must provide corrective action plans within forty-eight (48) hours.

Suppliers should maintain accurate and transparent books, records, and accounts to demonstrate compliance with applicable laws and regulations, and the Supplier Code of Conduct. Aspire Bakeries reserves the right to verify suppliers' compliance with the Supplier Code of Conduct. If Aspire Bakeries becomes aware of any actions or conditions that are not in compliance with the Supplier Code of Conduct, Aspire Bakeries reserves the right to demand corrective measures. Aspire Bakeries reserves the right to terminate an agreement with any supplier who does not comply with the Supplier Code of Conduct.

Mandatory Disclosures Required Under Canadian Bill S-211:

The steps that Aspire Bakeries has taken during its 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 Aspire Bakeries or of goods imported into Canada by Aspire Bakeries:

  • To be employed within our facilities, Aspire Bakeries requires a minimum age of eighteen years. Our comprehensive system of internal policies and procedures including our Employee Code of Conduct is reviewed and signed by all associates and the Slavery and Human Trafficking training is in place to educate associates on this important issue. Aspire Bakeries' external Supplier Code of Conduct Policy sets the standard that suppliers' employees should be fifteen years or older, and our 1:1 meetings with our suppliers examine what they are doing to combat child labour, slavery, and human trafficking in their supply chains and emphasizes our focus on eliminating any known issues from our supply chain.

Structure, activities, and supply chains:

  • Aspire Bakeries produces baked goods made with high quality ingredients, care, and authenticity. The breadth and depth of our portfolio allows us to provide innovative solutions as a leading bakery manufacturer in North America. Our core portfolio items include Artisan bread, traditional bread, cookies, muffins, doughnuts, laminates, and sweet baked goods.
  • Aspire Bakeries operates three bakeries in Canada and ten bakeries in the United States; our corporate office is in Los Angeles, California.
  • Aspire Bakeries employed 2482 US associates in FY25.
  • Aspire Bakeries employed 1297 Canadian associates in FY25.
  • Our Canadian corporate entity is Aspire Bakeries B.C. ULC.
  • Our United States corporate entity is Aspire Bakeries LLC.
  • Aspire Bakeries does not own any farms, mills, or transportation services.
  • Our procurement team is responsible for purchasing the commodities used at our bakeries.
  • Aspire Bakeries uses commodities from various suppliers that source ingredients from around the world.
  • Aspire Bakeries purchases our commodities from suppliers that adhere to our Supplier Code of Conduct.

Its policies and due diligence processes in relation to forced labour and child labour:

  • Internal Policies: Aspire Bakeries has an Employee Code of Conduct with a Human Rights Section covering forced labour and child labour, as well as a Child Labour Policy prohibiting use of child labour.
  • External Policy: Aspire Bakeries has a Supplier Code of Conduct policy in place with a human rights section covering forced labour and child labour.
  • Supplier Meetings: Aspire Bakeries hosts meetings with our key suppliers where they provide details on how they are mitigating any threats of forced labour and child labour.
  • Bill S-211 Supplier Reports: Aspire Bakeries reviews published copies of our suppliers' CAN Bill S-211 Reports detailing what our suppliers do to ensure child labour and forced labour are not used in their supply chains.

The parts of its 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:

  • Distributors that carry a diverse selection of materials where we do not have visibility of full producer supply chain is a potential risk.
  • Cocoa, Palm, and Sugar supplier meetings are held and during these meetings, Aspire Bakeries discusses human rights issues directly with our suppliers.
  • Aspire Bakeries ensures that its suppliers have programs in place to combat any threats of forced labour and child labour.

Any measures taken to remediate forced labour or child labour:

  • Not applicable; Aspire Bakeries has not identified any forced labour or child labour in our activities and supply chains.

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:

  • Not applicable; Aspire Bakeries has 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.

The training provided to associates on forced labour and child labour:

  • Aspire Bakeries' associates take a Social Accountability training annually, focused on Slavery and Human Trafficking. The virtual training is 25 minutes, and it is paired with questions and answers that require a 100% pass rate.
  • The training was developed internally, and it is mandatory for specific associates including: the Corporate Social Responsibility team, Human Resources (Central Services and Bakery), Procurement, Bakery Directors, and our Senior Operations Team. Over 100 associates are currently required to complete this training.

How Aspire Bakeries assesses its effectiveness in ensuring that forced labour and child labour are not being used in its business and supply chains:

  • We conduct an extensive and comprehensive annual review of our policies and procedures related to forced labour and child labour. Our system is designed to stop slavery and human trafficking from occurring at our facilities and throughout our supply chain. We have a Supplier Code of Conduct in place, and we host ongoing conversations with our suppliers to better understand their programs.