Response to the Fighting Against Forced Labour and Child Labour in Supply Chains Act

Effective Period / Reporting Year: January 1, 2026 – December 31, 2026

 

1. Introduction & Purpose

Pursuant to Bill S-211, An Act to enact the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “Act”), which came into force on January 1, 2024, certain Canadian entities and importers are required to report publicly on the steps they have taken during the prior financial year to prevent or reduce the risk that forced labour or child labour is used at any step in the production of goods produced in or imported into Canada. (See Canada’s guidance and the government’s summary of the Act.) 

This disclosure describes how Once Upon a Farm is responding to the Act: our structure, due diligence, risk assessment, remediation approach, training, and monitoring of effectiveness.

This Modern Slavery Report (the “Report”) addresses the period from January 1, 2026 to December 31, 2026 “Fiscal 2026” and has been prepared in compliance with the Fighting Against Forced Labour and Child Labour in Supply Chains Act (Canada) (the “Act”). This Report is made on behalf of Once Upon a Farm (“Once Upon a Farm”, - “we”, “us” or “our”). 

2. Structure, Activities, and Supply Chains

Business Activities in Canada: Once Upon a Farm sources finished products, ingredients, packaging components, and finished goods from both US and international suppliers, and exports goods from the US into Canada for sale. We procure raw ingredients (e.g. fruits, vegetables, grains), packaging materials, contract manufacturing services, transportation, and logistics services. Our supply chain spans multiple tiers (direct suppliers, sub-suppliers) across geographies, including regions with risk of labour exploitation.

3. Policies & Due Diligence Processes

We have adopted the following policies, contractual requirements, and due diligence systems to comply with the Act and manage the risks of forced labour and child labour:

1. Supplier Code of Conduct / Responsible Sourcing Policy: We require all direct suppliers to adhere to our Supplier Code of Conduct, which expressly prohibits forced labour, slavery, human trafficking, and child labour. We include these requirements in supplier contracts and onboarding documentation.
2. Contractual Clauses & Certifications: Via the Supplier Code of Conduct, each supplier must certify that its operations, and its supply chain, comply with all applicable labour laws and that no forced labour or child labour is used. These certifications are contractually binding.
3. Risk Assessment & Mapping: We plan to conduct annual supplier risk assessments focused on geography, commodity type, labor intensity (e.g. seasonal agricultural work), and supplier history. We will map our supply chain to the extent possible (direct and indirect tiers) to identify higher-risk nodes.  Suppliers in higher-risk categories will be subject to additional screening, enhanced due diligence, and potentially third-party audits.
4. Audits & Monitoring: We have the ability to conduct unannounced internal or third party audits which include document review, worker interviews, and site inspections. We also monitor compliance through periodic review of third-party audits such as SMETA audits if possible. 
5. Grievance & Reporting Mechanism: We maintain a grievance mechanism (e.g. whistleblower reporting channel) where workers or third parties in the supply chain can report concerns about forced labour or child labour confidentially. We investigate reported cases and escalate serious matters. We also partner with Ethical Farming Initiative (EFI) to promote best practices at farm level of some suppliers, which includes a grievance and reporting hotline. 

4. Risk Assessment & Management

As required by the Act, we identify parts of our supply chain that may have elevated risk of forced or child labour, and describe steps that will be taken to continue to manage those risks:

High-Risk Commodities / Regions: Agricultural commodities (e.g. fruits, vegetables) sourced in certain geographies may be higher risk due to seasonal migrant labor, informal labor relations, or weak regulatory enforcement. Packaging raw materials or packaging component manufacturing in certain countries may also present elevated risk.

Supply Chain Tiers & Visibility Gaps: We acknowledge that our visibility decreases beyond Tier 1 suppliers. Subcontractors or intermediaries may be harder to monitor, which raises risk.

Risk Mitigation Steps

1. Prioritize higher-risk suppliers for audits and monitoring.
2. Require additional due diligence (e.g. supplier questionnaires, certifications) for suppliers in high-risk geographies.
3. Engage with suppliers to help them strengthen their labour practices, including training and capacity building.
4. Where a supplier refuses to cooperate or fails to remediate, we may suspend or terminate the business relationship.
   
   

5. Remediation & Corrective Action

Our Company Code of Conduct requires all employees and of Once Upon a Farm to report actual or possible misconduct. We also undertake diligence efforts (as further described in this Report) to ensure that the risk of forced labour and child labour is mitigated in our business. 

In the event that we discover any forced labour or child labour in our business and supply chains, we may take the following measures to remediate such forced labour or child labour: 

If any instance of forced labour or child labour is identified, we follow a remediation protocol that may include:

• Elevate the event to the Once Upon a Farm Sustainability Steering Committee.
• Suspension or termination of a supplier, sub-supplier, or contractor. 
• Requiring the supplier to implement a corrective action plan within a specified timeframe (e.g. changes to management systems, worker payments, contract reformation).
  Monitoring implementation and verifying remediation results.
• Actions to prevent forced labour or child labour and associated harms from reoccurring
• Suspending or terminating the relationship if remediation is not satisfactory.
• Where workers have suffered harm (wages withheld, unsafe conditions), considering compensation or support for those workers, consistent with local law and human rights best practice.
• Cooperating with authorities or NGOs (if applicable) to ensure victims receive support and to prevent recurrence.

We also recognize the risk of unintended negative impacts (e.g. job loss) and, where feasible, aim to provide alternatives or transitional support rather than punitive withdrawal without mitigation.

6. Training & Awareness

We provide training internal teams on forced labour and child labour risks, indicators, and mitigation practices for high risk ingredients. We update training materials to reflect emerging risks, regulatory developments, and best practices.

7. Effectiveness & KPIs

To assess our performance and compliance with the Act, we track key performance indicators and review effectiveness. Metrics may include:

• Number of suppliers evaluated / audited
• Number of non-compliance incidents identified and remediated
• Percentage of supply chain spend covered by audits or assessments
• Training completion rates among internal teams
• Follow-up verification of corrective actions
  
  

We conduct periodic internal reviews and, where feasible, may opt to engage independent third parties to assess our due diligence systems.

8. Public Reporting & Transparency

• We will publish this disclosure (or a version thereof) prominently on our website and make it accessible to the public, as required under the Act.
• We will file our required report to the Minister of Public Safety by May 31 each year, covering the prior fiscal year’s actions.
• We may consider consolidating our Canadian reporting with global supply chain disclosures (e.g. in ESG or sustainability reports), provided the Canadian legal requirements are fully met.
• We will notify stakeholders of material changes to this policy or our practices.
  
  
  

9. Limitations & Forward-Looking Commitments

We acknowledge certain limitations including that 

1. Complete visibility across deep tiers of supply chains can be challenging.
2. Some suppliers or subcontractors may refuse cooperation.
3. Effectiveness is contingent on supplier integrity, audit reach, and on-the-ground enforcement.
   
   

Nevertheless, we commit to continual improvement — refining our mapping, expanding audits, strengthening supplier engagement, and aligning with evolving regulatory expectations and human rights norms.

10. Approval & Signature 

In accordance with paragraph 11(4)(a) of the Act, this Report was approved by Once Upon a Farm’s Board of Directors on 2/5/2026 and has been submitted to the Minister of Public Safety and Emergency Preparedness in Canada. 

Based on my knowledge and having exercised reasonable diligence, I attest that the information in this Report is true, accurate, and complete in all material respects for the purposes of the Act for the reporting year listed above. 

Jane Kuhn
Sr Director of Strategic Sourcing & Sustainability
February 5, 2026
I have the authority to bind Once Upon a Farm.