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Canadian Supply Chain – Forced Labour Report
Introduction
Nature Fresh Farms Sales lnc. and Nature Fresh Farms lnc. together form one of the largest independent greenhouse produce marketers and growers in Canada and are headquartered in Leamington, Ontario Canada.
For the purpose of clarity Nature Fresh Farms lnc. and Nature Fresh Farms Sales lnc. shall be referred to as Nature Fresh in the context of this joint report. This joint report outlines Nature Fresh’s processes and progress made towards preventing and reducing the risks of forced labour and child labour in the financial reporting year of 2024 and is the second version of this annual report.
Reporting Context
Nature Fresh Farms lnc. and Nature Fresh Sales lnc. are each corporate entities subject to the legal requirements in section 11 of the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Act) and are both part of the same corporate group with a common owner. This Joint Report is made pursuant to the Act and was approved by the President & CEO of Nature Fresh, Patrick Criteser on May 22, 2025.
Our Corporate Structure and Business Activities
Nature Fresh Sales lnc. was lncorporated in 2009 and is headquartered in Leamington, Ontario Canada at 33 Princess Street, Leamington, Ontario N8H 5C5. Nature Fresh Farms lnc. was created by amalgamation in 2OO7 and is located at 525 Essex Road 14 Box 400 Leamington, ON N8H 3V8. Nature Fresh currently comprises of a team of over 1000 Employees, and we grow, purchase, sell, and distribute fresh produce, including but not limited to tomatoes, bell peppers, cucumbers, and berries. Nature Fresh purchases greenhouse grown produce from Canada, USA and Mexico suppliers and markets and distributes that produce in Canada and USA to retail and wholesale customers.
A. Our Supply Chain
Nature Fresh’s supply chain risk analysis focuses on the suppliers of goods and services that contribute to the final product, including packaging materials and procurement of fresh greenhouse grown produce, and suppliers of growing materials like substrate, clips, seeds and conveyance equipment. Knowing that some of these items may be sourced from higher risk global south countries, our vetting of suppliers is governed mainly by ensuring that our suppliers meet the standards set forth by the Global Food Safety lnitiative (GFSI), by the Ethical Charter, by our customer requirements, and by our Supplier Code of Conduct.
B. Policies and Due Diligence
Nature Fresh operates and complies with all applicable laws and regulations, whether local, provincial, federal or industry specific and in accordance with our Supplier Code of Conduct, our Employee Handbook, and our Health and Safety Polices. Each of Nature Fresh’s owned facilities undergo annual Social Responsibility Audits including SMETA and/or Fair Trade.
Our focus is to protect, respect and value all employees by following all employment laws, including those involving wages earned and hours worked. Violating those laws is not just a legal issue but goes against Nature Fresh’s core values. Nature Fresh does not tolerate any form of forced labour, included bonded labour, indentured labour and slave labour, or human trafficking. Workers must be allowed to move around freely and leave their place of work when their shift ends. Nature Fresh does not tolerate the hiring of child labour under any circumstances.
Nature Fresh endorses the Ethical Charter of the lnternational Fresh Produce Association, Ethical Charter on Responsible Labor Practices, and in doing so, commits to workplace safety, respect for worker dignity, compliance with all applicable legal requirements and a commitment to building coordinated action across the industry on responsible labour practices.
Nature Fresh also encourages our growers to participate in the ECIP LAB platform, which is a capacity building tool that provides guidance and support for developing, implementing, and being recognized for the management systems needed to align with the Ethical Charter on Responsible Labor Practices.
Since 2019, as part of Nature Fresh’s vendor onboarding process, vendors are provided with the ‘Ethical Charter of Responsible Labor Practices Endorsement Document’ for their review and signature. This document highlights the main principles of the Ethical Charter of Responsible Labor Practices, namely:
1. Respect for Laws at Work
a) Legal Compliance
b) Occupational Health & Safety
c) Wages & Benefits
d) Working Hours
2. Respect for Professional Conduct
a) Communication and Worker Protections
b) Ethical Recruitment
c) Management Systems and Continuous lmprovement
d) Responsible Purchasing Practices
3. Respect for Human Rights
a) Employment is Freely Chosen
b) Feedom of Association
c) Humane Treatment and Non-Harassment
d) Non-Discrimination
e) Protection of Children and Young Workers
Nature Fresh asks the vendor to agree to implement and abide by the principles set out
within. lmplementation is tracked by our Compliance department.
C. Forced Labour and Child Labour Risks
Nature Fresh’s greatest risk exposure to forced labour and child labour is through suppliers, and the primary sources of these risks come from procuring goods in higher risk geographies and sectors. We recognize the potential risks of forced labour and child labour in our extended supply chain and the complexity and challenges in operationalizing modern slavery compliance.
We encourage our procurement department to seek growers/vendors who have implemented social responsibility audits such as SMETA, Fair Trade USA, or EFI.
Nature Fresh strives to continue to identify emerging risks.
D. Our Remediation Measures
Nature Fresh has not identified any specific instances of forced labour or child labour, accordingly, no measures have been implemented to remediate any forced or child labour.
E. Loss of Income Measures
Currently, Nature Fresh has not identified any loss of income to be remediated, however, we remain dedicated to contributing and supporting local drives and donations to support the unhoused.
F. Remediation of Loss of Income
No measures have been taken by Nature Fresh to remediate the loss of income to the most vulnerable families as no loss of income has been identified.
G. Our Training and Awareness
Nature Fresh currently has policies and due diligence processes in place related to forced labour and child labour. Nature Fresh provides mandatory orientation training to employees upon hire to educate workers and keep them informed with the laws and requirements regarding forced labour and child labour.
H. Assessing Our Effectiveness
Nature Fresh has not taken action to assess the effectiveness in preventing and reducing the risk of forced labour and child labour outside our workplaces.
Report Approval and Attestation
This report has been approved by written resolution by the director of each of Nature Fresh Farms lnc. and Nature Fresh Farms Sales lnc. ln accordance with the requirements of the Act, and in particular section 11 thereof, l, in my capacity as a director of Nature Fresh Farms Sales lnc. and Nature Fresh Farms lnc., attest that I have reviewed the information contained in the Joint Report for the 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.
—Patrick Criteser, President & CEO
May 22, 2025
“I have the authority to bind Nature Fresh Farms Inc., and Nature Fresh Farms Sales Inc.“
