Canadian Forced and Child Labour Act

Modern Slavery Report January 1, 2025 to December 31, 2025 Sonoco Products Company

Introduction

This Modern Slavery Report (the “Report”) addresses the period from January 1, 2025 to December 31, 2025 and has been prepared to comply with the Fighting Against Forced Labour and Child Labour in Supply Chains Act (Canada) (the “Act”). This Report is made on behalf of Sonoco Products Company (“SPC”) and its subsidiary, Sonoco Canada Corporation (collectively “Sonoco,” the “Company,” “we,” “our,” or “us”). Information contained on the websites referenced in this report is not part of, or incorporated by reference into, this report.

Forced labour and child labour, each as defined in the Act, are crimes and serious violations of human rights. As a leading global developer, manufacturer and seller of a wide variety of packaging products, Sonoco recognizes its responsibility to ensure that our operations and the supply chains supporting them uphold the highest ethical standards. We are committed to acting ethically, with integrity and transparency, and to implementing and strengthening systems and controls designed to safeguard against modern slavery in our business and supply chains.

This Report sets out the steps we have taken in 2025 to prevent and reduce the risk of forced labour or child labour being used in the production of goods we produce in or import into Canada or elsewhere. It also describes the actions we have taken to identify, address, and mitigate risks of modern slavery—including slavery, servitude, human trafficking, and forced labour—within our global operations and supply chains.

1. Our Business

Structure and Activities

Sonoco Products Company is headquartered in Hartsville, South Carolina and employs, either directly or through its subsidiaries, approximately 22,500 employees (approximately 230 of which are employed by Sonoco Canada Corporation) across 270 facilities in 40 countries, spanning all major continents. SPC’s global operations include manufacturing facilities, recycling operations, distribution centers, and service locations that support its production and supply activities.

SPC is a global provider of highly engineered and sustainable packaging solutions serving diverse consumer and industrial end markets within the packaging and containers sector. SPC designs, develops, and manufactures products including rigid paper containers, metal  packaging, and industrial paper packaging. SPC serves a wide range of industries including food and beverage, consumer packaged goods, healthcare, electronics, textiles, construction, and automotive.

Sonoco business in Canada is conducted through Sonoco Canada Corporation, a wholly owned direct subsidiary of SPC. Sonoco Canada Corporation is a manufacturing company with operations in Brantford, Ontario; Chatham, Ontario; Edmonton, Alberta; and Trois-Rivieres, Quebec. Sonoco Canada Corporation manufactures and sells paper, converted paper, and rigid paper products. Sonoco Canada Corporation procures goods and services from approximately 100 external suppliers and contractors. The suppliers Sonoco Canada Corporation engages include businesses that produce certain raw material inputs, including recycled paperboard, adhesives, metal ends, and chemicals for producing paper and converted paper products. 

Further information about Sonoco businesses can be found in SPC’s Annual Report on Form 10-K, subsequent Quarterly Reports on Form 10-Q, its other filings with the U.S. Securities and Exchange Commission, and its website at www.sonoco.com.

Supply Chains

Sonoco’s supply chain is global, diverse, and multilayered, with suppliers located around the world. The company relies on a wide range of raw materials, components, equipment, and services to support its global packaging operations.

  • Key input categories include, but are not limited to:
  • Fiber and paperboard (e.g., recycled fiber)
  • Metals (e.g., tinplate steel, metal ends)
  • Laminates and films (e.g., paper-based laminates, aluminum layers, resin-based films)
  • Labels and printed materials (e.g., preprinted labels, printed packaging components)
  • Inks, adhesivescoatings, and chemicals (e.g., printing inks, functional coatings, processing chemicals)

Sonoco engages a broad spectrum of suppliers, including multinational raw-material manufacturers, regional producers, distributors, and service providers. Our direct suppliers provide the materials used in manufacturing, while indirect suppliers support our operations through equipment, logistics, maintenance, and other facility-related services. In addition to externally sourced inputs, Sonoco produces key raw materials internally through its recycling and paperboard operations.

2. Our Policies

Through Sonoco’s organizational and governance policies, we clearly communicate our values and expectations to our employees, suppliers, and selling partners. Guided by our core values of honesty, integrity, accountability, and respect, we set a high standard of conduct across our operations and supply chain. Sonoco does not tolerate any form of forced labour, child labour, or other human rights abuses.

To uphold these commitments, we maintain a robust library of policies and monitor compliance to prevent our activities from contributing to adverse human rights impacts. Our key policies supporting this commitment are available on our website and are outlined in further detail below.

Policy Maintenance

The following policies are maintained by Sonoco’s Legal and Compliance Office (LCO) under the Office of General Counsel and are reviewed on an annual basis. The LCO collaborates with key stakeholders (including HR, Finance, Safety, and IT) to ensure policies remain current, accurate, and aligned with applicable regulations. Sonoco’s Internal Audit Department performs periodic risk assessments and monitors the company’s compliance with these policies.

Communication and Enforcement

Salaried employees are required to attest annually to having reviewed the Code of Conduct, Antitrust Policy, and Anti-Bribery and Anti-Corruption (ABAC) Policy as part of mandatory Code of Conduct training. Supplier contracts and purchase orders require suppliers to review and comply with the Supplier Code of Conduct. All policies are evaluated regularly to ensure continued effectiveness and alignment with evolving legal and regulatory expectations.

Policies on Business Conduct

Sonoco’s Business Conduct Policies, including our Code of Conduct, Anti-Bribery and Anti-Corruption Policy, and Antitrust Policy, establish the principles and expectations that guide the behaviour of Sonoco employees, directors, and representatives. These policies form the foundation of how we operate and reinforce our commitment to lawful, ethical, and responsible business practices. Our Business Conduct Policies are available on our website here.

In 2025, Sonoco executed a policy integration initiative to standardise governance following the December 2024 acquisition of Eviosys. Policies from both organizations were reviewed section by section to directly compare requirements, eliminate redundancies, bridge gaps, and ensure critical content was retained or enhanced. The integrated policies adopted the most effective and risk-appropriate provisions from each organization and introduced new content where needed, all within Sonoco’s established policy framework. Key stakeholders from both companies were engaged throughout the process, with final approvals obtained through appropriate governance channels, resulting in clear, consistent, and enterprise-ready policies across the combined organization.

Code of Conduct

Sonoco is committed to conducting business in a lawful and ethical manner. The Code of Conduct outlines the core principles all employees and directors must follow, emphasizing honesty, integrity, accountability, and compliance with all applicable laws, rules, and regulations. The Code of Conduct applies to Sonoco’s employees, officers and directors and is publicly available on our website here.

Anti-Bribery and Anti-Corruption (ABAC)

Anti-bribery and anti-corruption expectations are addressed in both the Code of Conduct and a
dedicated Anti-Bribery and Foreign Corrupt Practices Act Policy. This policy applies to all Sonoco subsidiaries, employees (permanent and temporary), and any representatives acting on Sonoco’s behalf, including business partners. It supports compliance with applicable laws such as France’s Sapin II Law, the UK Bribery Act, and the U.S. Foreign Corrupt Practices Act (FCPA). The Policy is publicly available on our website here.

Anti-Trust / Competition Law Compliance

Sonoco strives to maintain a free and competitive marketplace. Our Policy for Compliance with Antitrust Laws sets out the principles of EU, U.S., and other applicable competition laws and provides guidance on acceptable and prohibited business practices. The Policy applies to Sonoco’s employees, officers and directors and is publicly available on our website here.

Policies on Corporate Social Responsibility

Human Rights Policy

Sonoco’s Human Rights Policy affirms our commitment to respect internationally recognized human rights standards, including the International Bill of Human Rights and the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work. The policy applies to all operations of the Sonoco Group, including all divisions, subsidiaries, and affiliates, and governs the conduct of employees, directors, officers, agents, contractors, vendors, and suppliers. The Human Rights Policy is publicly available on our website here.

Conflict Minerals Policy

alignment with SEC requirements and OECD guidance. Sonoco uses the Responsible Minerals Initiative’s Conflict Minerals Reporting Template (CMRT) to collect standardized sourcing information from suppliers and enhance supply chain transparency. Suppliers are required to trace minerals through their own supply chains and maintain due diligence programs. Corrective actions are taken if any non–conflict-free sourcing is identified. Sonoco discloses conflict minerals information annually in Form SD filed with the SEC. The policy is publicly available on our website here.

Supplier Standards

Sonoco’s Supplier Code of Conduct (“Supplier Code”) outlines the standards and expectations we require of all suppliers, their supply chains, and any contractors they engage. The Supplier Code sets forth our principles of environmental awareness, non-discrimination, human rights, fairness, and accountability and reinforces Sonoco’s commitment to human rights. The Supplier Code aligns with the ILO 1998 Declaration on Fundamental Principles and Rights at Work and supports the following:

  • Fair and safe work
  • Rights of children and abolition of child labour
  • Prohibiting forced or compulsory labour and human trafficking
  • Non-discrimination
  • Freedom of Association and collective bargaining

Suppliers must commit to operate under the Supplier Code as a condition of doing business with Sonoco. Sonoco’s purchase order (PO) Terms and Conditions require suppliers to comply with Sonoco’s Supplier Code of Conduct as a condition of doing business. In addition, new suppliers are required to attest to having reviewed the Supplier Code as part of the onboarding process. Sonoco does not engage suppliers that require work beyond statutory limits without lawful compensation, employ individuals below the legal working age, or engage in any form of child exploitation. The Supplier Code is reviewed and updated regularly to reflect evolving best practices. In 2025, Sonoco released a reformatted and translated version to improve clarity and accessibility. The updated Supplier Code and translations are available on our website here.

Corporate Sustainability Report

Sonoco’s 2025 Corporate Sustainability Report highlights our commitment to sustainable packaging, environmental stewardship, and employee wellbeing. The report outlines ongoing initiatives related energy efficiency, renewable energy, waste reduction, and water management aimed at reducing greenhouse gas emissions. It also outlines Sonoco’s efforts to uphold strong human rights and ethical procurement practices by establishing clear supply chain expectations and complying with laws such as the California Transparency in Supply Chains Act and the conflict minerals requirements under the U.S. Dodd-Frank Act. The full report is available on our website here.

3. Due Diligence

Sonoco acknowledges the risks of forced labour, child labour, and other forms of modern slavery within our global supply chains and seeks to identify, mitigate, and respond to these risks across our operations. To support this commitment, Sonoco maintains a structured due diligence framework that includes supplier onboarding and monitoring, internal compliance controls, participation in global responsible sourcing platforms, and established remediation processes. Sonoco’s Legal and Compliance Office oversees compliance of these programs.

Supplier Due Diligence

Sonoco expects all third parties to uphold ethical standards consistent with our own and to comply with all applicable laws and regulations. Our supplier due diligence process evaluates risks throughout the third-party relationship and applies risk-based checks to help identify and mitigate potential concerns.

Onboarding

Suppliers are required to review and comply with Sonoco’s Supplier Code of Conduct as a condition of becoming an approved Sonoco supplier. Under this Code, suppliers commit to conducting business in accordance with human rights principles and all applicable laws and regulations.

Screening

Designated Sonoco liaisons conduct initial supplier screenings as the first line of defense. The Legal and Compliance Office supplements this by using a third-party business intelligence platform to identify and monitor risks among Sonoco’s largest suppliers. 

Third-Party Human Rights Risk Management Dashboard 

Since 2024, Sonoco’s Legal and Compliance Office has used a third-party risk management dashboard to help monitor supplier compliance with the Supplier Code of Conduct. The dashboard incorporates insights from Freedom House’s Freedom in the World ratings, which classify countries and territories as “free,” “partially free,” or “not free.” Suppliers located in higher-risk jurisdictions may be required to review and agree to the Supplier Code more  frequently. Monitoring these risk profiles enables Sonoco to maintain transparency with customers and stakeholders regarding human rights conditions within our value chain.

Responding to Risks

Should Sonoco become aware of suspected risks of supplier human rights violations, we take further action. This may include requesting more human rights information via an extended questionnaire, conducting an audit, or reassessing the relationship.

Internal Due Diligence

Employee Recruitment

Sonoco maintains internal safeguards to prevent modern slavery within its workforce. Prospective employees must provide evidence of their legal right to work, and staffing agencies engaged by Sonoco undergo appropriate vetting to verify compliance with ethical and legal standards.

Ongoing Communication and Training

The Legal and Compliance Office requires salaried employees to complete annual Code of Conduct training, which includes business ethics topics such as human rights, modern slavery whistleblowing, and retaliation. Employees must complete knowledge checks and attest that they understand our Business Conduct Policies. Sonoco continues to explore opportunities to expand training to hourly employees.

Confidential Reporting and Grievance Mechanisms

Sonoco encourages employees to raise concerns confidentially and without fear of retaliation, as outlined in our Whistleblowing Policy. Reports may be made through an independently managed third-party hotline or directly to the Legal and Compliance Office. The LCO is responsible for receiving, investigating, and addressing reported concerns. Suspected breaches of the Act are handled promptly and seriously.

Memberships and affiliations

ISO Certification

Approximately 80 Sonoco locations have one or more ISO certifications. In Canada, our Chatham location maintains a food safety certification.

SEDEX Membership

Many Sonoco facilities participate in the Supplier Ethical Data Exchange (SEDEX), a global nonprofit promoting responsible supply chain practices. Approximately 106 Sonoco operations worldwide are enrolled in SEDEX. In Canada, two facilities participate: Chatham RPC and Edmonton T&C. Participating sites have completed SEDEX’s Self-Assessment Questionnaire (SAQ) and operate in alignment with the Ethical Trading Initiative (ETI) Base Code. Several Sonoco locations also
undergo SEDEX Members Ethical Trade Audits (SMETA). Many of Sonoco’s customers and suppliers are also members of SEDEX.

Sonoco continues to evaluate opportunities to expand participation in SEDEX and SMETA audits to enhance visibility into modern slavery and related supply chain risks.

4. Assessing and Managing our Risk

Sonoco recognizes that, because of the nature of our operations in the manufacturing and packaging industry, we may be indirectly linked to risks of modern slavery within our business relationships and supply chains. Certain sectors—particularly those involving the provision of materials, contracted services, or labour—may present heightened exposure. To address these risks, Sonoco has established procedures and assessments designed to identify, evaluate, and manage the risk of forced labour and child labour in our operations and supply chains. Our Legal and Compliance Office conducts periodic risk assessments and monitors customer and supplier
data throughout the year through our Third-Party Risk Management Program.

Risk

To identify the business activities with the greatest exposure to these risks, we consider the following factors:

  • Reliance on low skilled workforce;
  • Presence of migrant workers;
  • Long, complex, or non-transparent supply chains; and
  • Jurisdictional risks including poverty, conflict, and enforcement of international human rights standards.
Risk Assessment

In 2025, Sonoco continued to rely upon data collected from a Human Rights Risk Assessment conducted in 2023 by our Legal and Compliance Office (the “2023 Assessment”) to monitor compliance with our Human Rights Policy in accordance with methodologies informed by the United Nations Guiding Principles on Business and Human Rights, the International Labour Organization, and the U.S. Department of State’s Bureau of Democracy, Human Rights, and Labour.

The 2023 Assessment focused on ensuring the following: (i) fair and safe work environment, (ii) the rights of children and the abolition of child labour, (iii) prohibiting forced or compulsory labour and human trafficking, (iv) non-discrimination, (v) freedom of association and collective bargaining; and (vi) indigenous people’s rights. The 2023 Assessment included interviews covering broad topics, including human rights risks and priorities, policy and awareness, risk mitigation efforts, and supplier due diligence.

As part of the 2023 Assessment, Sonoco sampled 20 suppliers to evaluate their due-diligence practices, onboarding procedures, and human rights compliance. This review included an examination of supplier contracts, recent bidding or diligence activities, and any public information regarding human rights concerns associated with the supplier. Sonoco intends to update its Human Rights Risk Assessment in 2026.

Third Party Risk Management Program

Sonoco operates a multidomain third-party risk management (TPRM) program. Sonoco applies a risk-based, tiered approach to supplier screening and due diligence designed to identify and mitigate human rights risks, including modern slavery. 

New suppliers are subject to fundamental screening and verification procedures. These measures are intended to confirm supplier legitimacy, financial ownership, and basic risk indicators, and include payment verification controls, confirmation of bank account ownership, and completion of onboarding questionnaires.

Sonoco leverages external data sources to monitor our third-party population. Sonoco subscribes to a collection of data sources to monitor risks across several domains, including cybersecurity, financial stability, ecosystem dependencies, geopolitical, and regulatory compliance. Compliance screenings include sanctions violations, enforcement actions, adverse media, and Politically Exposed Persons (PEPs), and other risks. This information is refreshed regularly and can be used
to identify indicators of modern slavery or broader human rights concerns.

Enhanced Screening

Sonoco is expanding its third-party risk management (TPRM) program by enhancing supplier screening and due diligence capabilities. Sonoco employs a risk-based framework to identify suppliers that present heightened risk and warrant enhanced screening. As part of this expansion, Sonoco has developed an internal supplier questionnaire and a more comprehensive external control assessment designed to assess risks at various levels of detail.

The internal questionnaire assesses the inherent risk posed by a third-party relationship. This inherent risk assessment is calibrated to identify risks across multiple domains to score inherent risks, including potential human rights and modern slavery risks.

Where potential issues are identified, Sonoco utilizes a third-party management tool to conduct control assessments, requiring suppliers to provide additional information regarding their policies, processes, and practices for preventing modern slavery within their operations and supply chains. This may include targeted scoping questions, supplemental documentation requests, and further clarification to assess the effectiveness of supplier controls. Considerations include exposure to elevated human rights risk environments and internationally recognized risk indicators. Suppliers may be assigned corrective actions to take to remedy identified risks.

If supplementary information is insufficient and corrective action is not taken within established timeframes, findings are escalated to appropriate stakeholders. Modern slavery or human rights concerns (including forced labour, child labour, and related modern slavery indicators) are assigned the highest risk rating, which triggers the highest level of escalation and remediation. Failure to meet Sonoco's requirements would lead to a re-evaluation of the business relationship.

5. Remediation Measures

While Sonoco has not identified any instances of forced labour or child labour in its operations or supply chains in Canada, we maintain processes intended to respond promptly and responsibly should such concerns arise. These processes are designed to support early identification, effective remedy, and continuous improvement in the management of human rights risks across our operations and supply chain.

Prevention and Mitigation

Sonoco’s operations are primarily focused on the manufacturing of paper- and metal-based packaging, which presents a relatively low inherent risk of human rights abuses. Nevertheless, Sonoco maintains programs and controls designed to prevent, identify, and mitigate potential modern These include supplier onboarding and due diligence processes, expectations set through the Supplier Code of Conduct, contractual compliance requirements, and ongoing oversight of higher-risk suppliers as part of Sonoco’s Third-Party Risk Management (TPRM) program. These measures are complemented by internal policies, training, and governance processes intended to promote compliance with applicable laws and respect for human rights throughout Sonoco’s operations and supply chains.

Grievance and Reporting Mechanisms

Any employee, customer, supplier, or third party with a grievance may submit a report through Sonoco’s third-party Business Ethics Reporting Hotline. Reports may be submitted online at sonoco.ethicspoint.com, by emailing Sonoco’s Legal & Compliance Office at complianceoffice@sonoco.com, or by calling a 24/7 hotline.

Reports can be submitted anonymously, in most preferred languages and through the reporter’s preferred method (web or phone). All reports are reviewed and investigated in accordance with Sonoco’s Compliance Program. Any Sonoco employee who, in good faith, raises an issue regarding a possible violation of law or Company policy will be protected from retaliation. Additional information can be found in our Code of Conduct policy here and our Supplier Code of Conduct here.

Remediation Measures

Sonoco maintains an internal Whistleblower and Investigations policy that outlines how concerns are reported, assessed, and managed. Allegations involving human rights violations are assigned the highest level of priority. Where an investigation identifies credible findings, matters are escalated to senior and executive management to develop and implement appropriate corrective action plans, proportionate to the severity of the issue.

No Identified Incidents of Modern Slavery

Sonoco has not identified any instances of forced labour or child labour in its operations or supply chains in Canada. As a result, no remediation actions have been required. Sonoco remains committed to continuously improving its prevention, monitoring, and remediation frameworks and to taking appropriate action should any instances of modern slavery be identified in our business or supply chain.

6. Our Training

At Sonoco, we recognize that meaningful human rights protections begin with informed and empowered employees. We therefore invest in regular, comprehensive education to ensure our workforce understands their responsibilities, recognizes human rights risks, and upholds our values of integrity, accountability, and respect.

Code of Conduct Training

All salaried employees are required to complete Sonoco’s annual Code of Conduct Training. The purpose of this training is to: reinforce Sonoco’s commitment to ethical and responsible business practices, ensure compliance with all applicable laws and regulations, and promote a workplace culture grounded in integrity, accountability, and mutual respect. The curriculum covers key business ethics topics, which can include human rights, modern slavery, whistleblowing, protections against retaliation, and ethical standards of conduct. Training content is refreshed annually and incorporates relevant focus areas as appropriate. Each year, employees must also
attest to having reviewed and agree to comply with our Business Conduct Policies.

In 2025, salaried employees completed a 30-minute training composed of four modules, including modern slavery awareness. Each module concluded with a short quiz, followed by a final assessment. Participants were permitted unlimited attempts to achieve the required minimum passing score of 80%, ensuring comprehension of the material. The training program achieved a high completion rate of 98% across 5,371 employees enrolled globally, with 100% completion among Canada’s 44 salaried workers.

In 2026, Sonoco intends to implement a global anti-harassment campaign for salaried workers. We also intend to expand our conflict minerals training to include more employees.

7. Our Progress and Effectiveness

As part of our governance processes, we monitor compliance with our policies and procedures on an ongoing basis. We also review any concerns raised through formal and informal mechanisms of employee feedback. To date no significant concerns or complaints have been identified with respect to Sonoco’s Canada operations.

Key achievements in 2025

In 2025, Sonoco made significant progress in strengthening its human rights and compliance practices. Key achievements include:

  • Updated both the Employee and Supplier Codes of Conduct to integrate and align key standards with Eviosys, our recent acquisition, and ensured global employee access to all policies.
  • Expanded and strengthened our Third-Party Risk Management (TPRM) program and integrated our newly acquired Eviosys. This included developing a workflow for supplier code of conduct attestations, developing a compliance finding review process, and improving the scoring rubric.
  • Achieved a 98% completion rate among salaried employees globally and a 100% completion rate among Canadian salaried employees for Code of Conduct training.
  • Maintained our SEDEX and EcoVadis scores.
2026 Goal Setting

To guide our efforts and maintain continuous improvement in our human rights program, we have established the following goals for 2026 and have established associated Key Performance Indicators (KPIs):

  • Launch a global anti-harassment campaign
    • Percentage of employees completing the anti-harassment training
  • Maintain high compliance with our Code of Conduct Training
    • Percentage of employees completing the Code of Conduct training
  • Bolster our Supplier Due Diligence
    • Percentage of suppliers completing required attestations to the Supplier Code of Conduct
  • Maintain a strong whistleblowing and reporting system
    • Timeliness and closure rates for investigations of reported concerns
  • Maintain strong policy governance
    • Frequency of policy reviews to ensure alignment with global standards
  • Maintain high ratings from third parties
    • Number of sites participating in SEDEX and SMETA audits 
    • EcoVadis scores
  • Continue to develop TPRM program and spread internal awareness
    • Percentage of identified high risk suppliers surveyed
Monitoring and Evaluation

To ensure accountability and continuous improvement, the Legal and Compliance Office conducts ongoing monitoring and evaluation activities, which include:

  • Reviewing supplier and employee data to identify emerging risks
  • Monitoring trends in reports received through internal and external reporting channels.
  • Assessing compliance with global requirements and internal controls.
  • Recommending enhancements to strengthen our human rights governance framework.

8. Approval & Signature

In accordance with paragraph 11(4)(b)(ii) of the Act, this Report was approved by SPC’s Board of Directors on May 26, 2026, and has been submitted to the Minister of Public Safety and Emergency Preparedness in Canada. This Report is also available on our company website at www.sonoco.com.

In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in this Report for Sonoco Products Company and Sonoco Canada Corporation. 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.

Signed on Behalf of Sonoco Canada Corporation:

__________________________
Theresa J. Drew
Director, Audit Committee Chair
Date:
I have the authority to bind Sonoco Products Company.

FORWARD-LOOKING STATEMENTS

The information in this Report contains “forward-looking statements” within the meaning of Section 27A of the Securities Act of 1933, as amended (the “Securities Act”), and Section 21E of the Securities Exchange Act of 1934, as amended (the “Exchange Act”), which are subject to the “safe harbor” created by those sections, as well as “forward-looking information” as defined in applicable Canadian securities laws. Such forward-looking statements are based on our management’s beliefs and assumptions and on information currently available to our management. You can identify forward-looking statements by terms such as “may,” “expect,” “intend,” “potential” and similar expressions intended to identify forward-looking statements. Forward-looking statements in this Report include, but are not limited to, statements regarding our future due diligence, risk assessment, audit and remediation activities and commitments; our expectations regarding supplier policies and practices; supplier engagement with respect to human rights; and our employee hiring and training practices. By their nature, these forward-looking statements involve known and unknown risks, uncertainties, assumptions, and other factors that may cause actual results to differ materially from those contemplated by the forward-looking statements, including, among other things, risks relating to our ability to complete intended due diligence steps and carry out additional human rights assessments; the timeliness, cooperation, and accuracy of our suppliers in our due diligence and assessment efforts; our ability to identify and mitigate risks in our supply chain; our ability and willingness to use third-party compliance providers; future legal and regulatory; and the other risks and uncertainties discussed in our most recent Annual Report on Form 10-K and Quarterly Reports on Form 10-Q filed with the U.S. Securities and Exchange Commission, including under the captions “Forward-Looking Statements” and “Risk Factors.” You are cautioned not to place undue reliance on the forward-looking statements in this Report. The forward-looking statements contained in this Report represent our estimates and assumptions only as of the date of this Report. Except as may be required by applicable law, we undertake no obligation to update any forward-looking statements, whether as a result of new information, future events, or otherwise.

Download a copy of this policy here.