Forced Labour and Child Labour Risk Assessment Procedure

For Eagle Vision Video Productions Ltd. (EVVP) | Canada

1. Purpose

This procedure explains how EVVP identifies, assesses, and reduces the risk of forced labour and child labour in EVVP’s supply chain and purchasing activities. It supports responsible procurement and helps EVVP meet client expectations and applicable Canadian requirements.

2. Scope

This procedure applies to:

• All purchasing of goods and services by EVVP, including equipment, apparel and merchandise, printing, sets and props, technology and software, travel-related services, and subcontracted production services
• All suppliers, vendors, contractors, and third-party partners that EVVP pays for goods or services
• New suppliers and renewals with existing suppliers
• One-time purchases when risk indicators are present

3. Definitions

• Forced labour: Work or service that is coerced, involuntary, or performed under threat, penalty, or intimidation.
• Child labour: Work performed by a person under the legal minimum working age, or work that is prohibited for young persons because it is hazardous or interferes with education.
• Supplier: Any organization or individual providing goods or services to EVVP.
• Supply chain: The full chain of sourcing, production, shipping, and delivery that supports a product or service.
• Risk assessment: A structured review to identify where forced labour or child labour could occur and what controls are needed.

4. Roles and responsibilities

Executive Lead

• Approves this procedure and any high-risk exceptions
• Reviews escalations and approves final risk decisions for high-risk suppliers

Procurement Owner (Operations Lead or designate)

• Ensures assessments are completed before onboarding or renewal when required
• Maintains assessment records and the supplier risk register
• Confirms mitigation actions are completed and tracked

Project Leads and Department Leads

• Flag high-risk purchases early (tight timelines, overseas manufacturing, unknown vendors)
• Ensure purchase decisions follow this procedure

Finance

• Confirms no payment is issued for high-risk suppliers until approval conditions are met

5. When a risk assessment is required

A forced labour and child labour risk assessment must be completed for:

1. All new suppliers that provide physical goods (for example merchandise, apparel, print materials, hard drives, accessories, promotional items, set materials).
2. Any supplier where EVVP spends above a defined threshold in a year (EVVP may set an internal threshold, for example $5,000).
3. Any supplier in higher-risk categories or geographies (see Section 6).
4. Any supplier requested by a client to meet specific screening requirements.
5. Renewals of existing suppliers at least every 24 months, or sooner if risk changes.

For low-risk purchases (for example local services, Canadian professional services, and common software subscriptions), a simplified screening may be used unless risk indicators appear.

6. Risk indicators

EVVP uses the indicators below to determine whether risk is low, medium, or high.

Product and service risk indicators

Higher-risk examples include:

• Apparel, textiles, promotional merchandise, and branded goods
• Electronics, batteries, cables, and components
• Print products sourced through complex networks
• Cleaning, security, or facility services using subcontracting layers
• Labour-only subcontracting in regions with limited labour protections

Supplier and sourcing indicators

• Supplier cannot clearly identify where goods are manufactured
• Heavy use of subcontractors without transparency
• No code of conduct, no labour policy, or no ability to answer basic questions
• Unusually low pricing that suggests labour exploitation risk
• Rush orders that reduce oversight

Country and sector indicators

• Manufacturing in regions with known labour rights concerns
• Industries widely associated with labour exploitation risk (for example mining inputs, textiles, electronics assembly)

Note: EVVP will use reasonable, good-faith screening based on available information and supplier disclosures. The goal is practical risk reduction, not perfection.

7. Procedure overview

EVVP uses a four-stage approach:

1. Screen and classify risk
2. Assess and document risk level
3. Mitigate and decide
4. Monitor and improve

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Procedure steps

Step 1: Start the assessment

The Procurement Owner starts an assessment when:

• A new supplier is proposed, or
• An existing supplier reaches the reassessment trigger (renewal cycle, spend threshold, or new risk indicator)

Create a record in the Supplier Risk Register with:

• Supplier name and contact
• What is being purchased
• Estimated annual spend
• Countries of manufacture or delivery (if goods)
• Whether subcontractors are used (if services)

Step 2: Collect supplier information

Request and collect, at minimum:

• Business registration and primary location
• Description of goods or services provided
• Countries where goods are manufactured or assembled (if goods)
• Confirmation of whether subcontractors are used
• Any relevant policies or statements (code of conduct, labour standards, modern slavery statement, supplier ethics policy)
• Agreement to EVVP supplier terms (including forced labour and child labour expectations)

If the supplier is unable or unwilling to provide basic information, treat as higher risk and move to Step 5.

Step 3: Complete the risk screening checklist

Complete the EVVP Forced Labour and Child Labour Risk Screening Checklist using the indicators in Section 6.

Recommended rating method (simple and consistent):

• Assign each indicator a score: 0 = none, 1 = some, 2 = clear
• Sum the score and classify:
  • Low risk: 0 to 3
  • Medium risk: 4 to 7
  • High risk: 8+ or any critical red flag (below)

Critical red flags (automatic escalation):

• Supplier cannot identify manufacturing location for goods
• Supplier refuses to confirm basic labour expectations
• Credible reports of forced labour or child labour linked to the supplier or a key subcontractor, with no remediation evidence
• Requests to bypass documentation or confidentiality to avoid disclosure of sourcing

Step 4: Determine required actions by risk level

Low risk

• Proceed with standard onboarding
• Keep the checklist on file
• Reassess at renewal or if risk changes

Medium risk

Proceed only if mitigation actions are completed, such as:

• Obtain written supplier attestation on forced labour and child labour
• Include EVVP supplier clauses in the agreement or purchase terms
• Request additional sourcing detail for goods
• Prefer suppliers with transparent sourcing and published policies
• Set a reassessment date within 12 months

High risk

Do not proceed until reviewed and approved by the Executive Lead. Required steps typically include:

• Enhanced due diligence questions (see Step 5)
• Written remediation plan if concerns exist
• Contract clauses requiring compliance, audit cooperation, and right to terminate for breach
• Consider alternate suppliers or sourcing options
• If risk cannot be reduced to an acceptable level, do not use the supplier

Step 5: Enhanced due diligence (for medium to high risk)

When required, send the supplier an enhanced questionnaire covering:

• Specific factory or production site locations (for goods)
• Labour recruitment practices (no recruitment fees, no document retention, voluntary employment)
• Wage and working hour standards and monitoring
• Age verification processes to prevent child labour
• Subcontractor oversight and approval process
• Any third-party audits or certifications
• Grievance and reporting mechanisms for workers

EVVP may also request:

• Recent audit summaries (if available)
• Evidence of corrective actions taken on prior issues
• References from other clients with similar requirements

Step 6: Decision and approvals

The Procurement Owner prepares a brief decision note that includes:

• The risk score and risk level
• Key findings and red flags
• Mitigations completed or planned
• Recommendation: approve, approve with conditions, or reject

Approval rules:

• Low risk: Procurement Owner approval
• Medium risk: Procurement Owner plus Executive Lead notification (or approval if required by client)
• High risk: Executive Lead approval required before purchase or contract signing

Finance confirms approvals are complete before payment.

Step 7: Contracting and purchase controls

Where feasible, EVVP includes supplier terms that cover:

• Compliance with forced labour and child labour prohibitions
• Obligation to disclose manufacturing locations and subcontractors upon request
• Obligation to notify EVVP of material changes (new factories, new subcontractors)
• Right to terminate for non-compliance or misrepresentation

For one-time purchases where a full contract is not practical, EVVP obtains written confirmation by email or purchase order terms.

Step 8: Ongoing monitoring

EVVP monitors supplier risk through:

• Annual review of spend and supplier category
• Reassessment triggers (new country of manufacture, new subcontractors, major pricing change, negative news, client requirement)
• Project lead feedback (quality issues, unusual behaviour, supply chain opacity)

For medium and high-risk suppliers, EVVP sets a reassessment schedule and documents updates in the Supplier Risk Register.

Step 9: Managing concerns, incidents, and remediation

If EVVP becomes aware of a credible forced labour or child labour concern:

1. Pause new purchases with the supplier where practical
2. Escalate to the Executive Lead within 2 business days
3. Gather facts and request a written response from the supplier
4. Determine corrective actions and timeline, or terminate the relationship
5. Document actions taken and outcomes

If a client is involved or contractual reporting is required, EVVP will coordinate communications through the Executive Lead.

Step 10: Records and retention

EVVP retains the following records securely:

• Screening checklists and risk scores
• Supplier questionnaires and responses
• Decision notes and approvals
• Contract clauses or attestations
• Any remediation documentation

Retention guideline:

• Keep records for at least 7 years after the last purchase or the end of the supplier relationship, unless a client contract requires longer retention.

Step 11: Training and review

• Procurement Owner and relevant staff receive training on this procedure during onboarding and at least every 2 years.
• This procedure is reviewed at least annually, and after any incident, major supplier change, or new client requirement.