Location: Toronto, ON Canada
Date of Report: May 29, 2025
Prepared by: Michael Ranieri
EXECUTIVE SUMMARY
This report is published pursuant to the Canadian “Fighting Against Forced Labour and Child Labour in Supply Chains Act” and outlines out the efforts and actions that Polytainers Inc. (the “Company” or
“Polytainers”) has taken and is continuing to take to combat forced and child labour within our business and supply chain, in compliance with the S-211 bill. The report covers activities for the fiscal year ending December 31, 2024, and highlights the company’s commitment to transparency, ethical sourcing practices, and responsible business conduct.
1. INTRODUCTION
We acknowledge our responsibility to combat forced and child labour and are committed to acting ethically and with integrity and transparency. As a responsible corporate citizen, we are working to put systems and controls in place to safeguard against any form of forced or child labour taking place within the business or our supply chain and ensuring the well-being of workers at every stage of production.
2. OUR BUSINESS
Polytainers Inc. is a privately held company that manufactures and sells rigid plastic packaging to the food industry. Polytainers operates two Global Food Safety Initiative (GFSI) certified manufacturing facilities, located in Toronto, Ontario, Canada and Lee’s Summit, Missouri, USA as well as a mold-making facility located in Markham, Ontario, Canada. Polytainers sells product to customers throughout North America. Polytainers employed approximately 810 employees in 2024.
3. COMPLIANCE WITH S-211
The S-211 bill mandates businesses to disclose efforts to address forced labour and child labour within their supply chains. Polytainers Inc. is fully compliant with the reporting requirements outlined in the bill and is committed to transparency and accountability in its operations.
4. OUR SUPPLY CHAIN
We procure a significant proportion of goods and services from a small number of suppliers and choose to establish strategic, long-term, and transparent relationships and to engage with all suppliers in an ethical and socially responsible way. Our supply chains include the sourcing of raw materials, packaging supplies, machinery, maintenance components, and other direct materials. Key materials inputs used in Polytainers’ production process include resin, pigments, polybags, corrugated, labels, and inks. Our direct material and indirect material suppliers are in North America, and equipment is purchased from North America and Europe.
5. POLICIES AND DUE DILIGENCE PROCESSES
Polytainers has set up policies and due diligence processes that lay out our standards and expectation to keep our supply chains responsible and ethical. A variety of policies and tools are in place to supplier our commitment including
Standards of Conduct
Polytainers maintains a Standards of Conduct policy (POL-HR-0051) with the aim of fostering a culture that values diversity, equity & inclusion, and maximizes the potential of all team members by always encouraging ethical and moral conduct. Our Standards of Conduct covers:
- Labour Standards & Ethical Sourcing
- Unfair Practices, Bribery and Inappropriate Gifts Confidentiality & Non-Solicitation
- Safeguarding Company Property/Assets
- Equal Employment Opportunity
- Prevention of Workplace Harassment, Violence & Disrespectful Behaviour
- Personal Accountability
- Training and Support
- Reporting Violations
Supplier Code of Conduct
Polytainers Supplier Code of Conduct helps ensure that all suppliers, contractors, consultants, agents and other providers of goods and services who do business with Polytainers meet our basic expectations of conducting business, including in relation to forced and child labour. Suppliers must comply with all laws and regulations applicable to their own operations. Any unlawful or prohibited conduct, inclusive of forced labour or child labour, will not be condoned.
Polytainers Integrity Hotline
Polytainers has implemented an Integrity Hotline operated by an independent firm, 24 hours a day, seven days a week, 365 days a year, with translation services available in multiple languages for employees. The Integrity Hotline allows individuals to report suspected illegal or unethical behavior, including suspected issues of child labor, slavery or human trafficking in either Polytainers own business or its supply chains.
Background Screening
We use Verified First for background checks in both Lee’s Summit and Toronto. Polytainers continues to work with responsible and reputable recruitment or placement agencies to ensure that no persons under the age of 15 (or younger if prohibited by local law) are recruited and that employees are legally able to work. In addition, we are asking for a document for proof of birthdate upon commencement of employment.
Polytainers currently has in place several policies aimed at preventing violence, harassment, and other unwelcome behaviours in the workplace. If an incident occurs, we encourage our employees to report the incident. The management team investigates and deals with all incidents and complaints in a
serious, fair, and confidential manner (except where disclosure if required by law) without fear of reprisal. All policies and procedures are reviewed and improved on a regular cadence.
Polytainers also maintains close relationships with our largest, strategic partners who share our values regarding human rights, ethics, health & safety, and the environment.
6. FORCED LABOUR AND CHILD LABOUR RISKS
We have performed an assessment of the risk of forced and child labour in our supply chains with the suppliers that represent 80% of spend to better understand the risks associated with the country of origin and industrial risk of our procured products and the risk profile in terms of forced and child labour for supply chains. Utilizing US Department of Labors list of List of Goods Produced by Child Labor or Forced Labor (List of Goods Produced by Child Labor or Forced Labor | U.S. Department of Labor) we confirmed that none of Polytainers supply chain falls into the categories defined as high risk for the presence of child or forced labor.
7. REMEDIATION MEASURES
Polytainers has not identified any instances of forced labor or modern slavery in our supply chain, therefore remediation is not applicable currently. We will continue to be vigilant in this regard. If potential violations are identified, Polytainers is prepared to take prompt and appropriate remediation actions, which may include.
- Engagement with suppliers to address non-compliance
- Implementation of corrective action plans to rectify
- Termination of business relationships with non-compliant suppliers, if
8. REMEDIATION OF LOSS OF INCOME
To our knowledge, there were no incidents of non-compliance in our operations or supply chains. Therefore, no remediation measures were necessary in 2024.
9. TRAINING
Polytainers conducts workplace safety training and workplace violence training during onboarding process as well as during monthly communications meetings. Polytainers is committed to a safe work environment for all employees and has zero tolerance for workplace violence. Our procurement team has been trained to ensure a deep understanding of the Supplier Code of Conduct, our principles, and values.
10. ASSESSING EFFECTIVENESS
As a supplier member of Sedex, Polytainers has undergone a Self-Assessment audit based on the Sedex Members Ethical Trade Audits (SMETA) that covers a variety of topics, such as labour health and safety, environment, and business ethics. These audits are designed to help protect workers from unsafe working conditions, discrimination, low pay, and forced labor.
Polytainers continues to monitor the effectiveness of its programs to manage the risks of forced and child labor, modern slavery and human trafficking throughout its supply chain.
Polytainers Inc. is committed to continuous improvement in its efforts to combat forced labour and child labour. The company regularly reviews and enhances its policies, procedures and monitoring mechanisms to stay aligned with best practices and emerging standards in ethical sourcing.
11. APPROVAL AND ATTESTATION
In accordance with the requirements of the Act, and in particular section 11 thereof, I, Susan Dalgleish, President & CEO, hereby 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.
Susan Dalgleish
President & CEO
I have the authority to bind Polytainers Inc.