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This report is made and submitted by Mazda Canada Inc. (“MCI” or “Company”) pursuant to Section 11 of Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act1 (the “Act”) which has been approved by the governing body of MCI.
MCI is the exclusive importer and distributor of Mazda motor vehicles, parts, and accessories in Canada, working with a network of 163 independently owned Mazda retailers across the country to promote, sell and service such products. MCI employs approximately 169 full-time staff operating through its head office in Richmond Hill, Ontario and its regional offices in Langley, British Columbia and Pointe-Claire, Québec. MCI is a privately held, wholly owned subsidiary of Mazda Motor Corporation which is based in Hiroshima, Japan. The directors of MCI have primary responsibility for the governance of MCI.
With at least $20 million in assets and $40 million in revenue in its last financial year, MCI is required to file this report with Canada’s Federal Minister of Public Safety in accordance with the Act. In alignment with this commitment to ethical business practices and human rights, MCI has drafted this report to assist in preventing and reducing the risk of forced labour and/or child labour within its supply chain.
MCI is an organization incorporated under the laws of the Province of Ontario, which is governed by a Board of Directors and led by an Executive Team consisting of its President and Chief Executive Officer, Chief Financial Officer, and Chief Operating Officer who oversee the day-to-day operations of the Company. Underneath the Board and Executive Team are additional levels of management consisting of its Directors, National Managers, and Managers who, in turn, supervise the Company’s remaining levels of employees.
MCI works with a network of independently owned and authorized Mazda retailers across Canada who, in turn, have each entered into a Dealer Sales and Service Agreement with MCI outlining each party’s respective rights and obligations concerning, among other things, the wholesale purchase, retail sale, and after-sale repair and maintenance services of Mazda products to customers.
Overarching MCI’s organization and governance structure is the Company’s policies and procedures, culture and values, business processes, and risk management.
MCI operates primarily as an importer and distributor of Mazda motor vehicles, parts, and accessories with its operations including the workers it employs.
MCI recognizes that its supply chain encompasses all products and services (including labour) that contribute to the Company’s own products and services, whether sourced in Canada, the United States, Mexico, or overseas.
MCI maintains a robust and carefully managed network of contracted suppliers across a range of sectors, including: Automotive Parts, Consulting Services, Corporate Apparel, Fleet Management, Information Communications and Technology, Logistics and Transport, Marketing, Office Cleaning, Office Supplies, Print and Promotional Goods and Services, Property Services and Travel.
MCI is committed to upholding the highest standards of ethical sourcing and supplier conduct throughout its supply chain. The Company’s approach extends beyond direct suppliers to include products and services provided by indirect suppliers, reflecting a comprehensive approach to supply chain management and oversight and MCI’s dedication to responsible business practices and continuous improvement.
MCI understands the importance of protecting human rights and is committed to protecting the rights of all people, and is further supportive of Canada’s international commitment to contribute to the fight against forced labour and child labour with the objective of eradicating modern slavery.
To this end, MCI has established key policies and procedures to assist in protecting human rights, and to encourage conducting business in an open and ethical way. These policies and procedures include the following:
MCI is continuing with its review of the following to minimize the risks of modern slavery within Mazda and its supply chain:
As detailed in its inaugural Sustainability Report released in February 2024 and, subsequently, its second Sustainability Report published in October 2024, MCI has adopted a strong, values-driven culture and is actively applying a sustainability framework in Canada designed to deliver meaningful results for our earth, people, and society. The high standards we bring to every aspect of MCI has guided us in several of our social and environmental activities and accomplishments to-date, and are confident that they will continue to do so in our ongoing commitment towards co-creating a more sustainable future including the upholding and enhancement of respect for human rights.
MCI is further aligned with the Human Rights Policy of its global parent company in Japan, Mazda Motor Corporation (“MC”), whereby Mazda globally is committed to upholding, promoting, and respecting human rights. Additionally, for the supply chain of Mazda branded products and those partners and suppliers who work with us, MC created the Mazda Supplier CSR Guidelines in July 2010 which was updated in May 2024 and now known as the Mazda Supplier Sustainability Guidelines (“MSSG”). This promotes sustainability activities among Mazda suppliers globally and requests total compliance with the laws and regulations of all countries and regions. The MSSG outline six areas such as respect for people including the prohibition of child labour and forced labour, and requests that all Mazda suppliers comply with the guidelines in these areas.
MCI expects its suppliers and contractors to operate in a manner that is consistent with its commitment to ethical business practices, including the promotion of labour and human rights within its supply chain. To further support these expectations, MCI has prepared a draft Supplier Code of Conduct which outlines our approach to labour and human rights and references the MSSG that we expect suppliers to follow. This Code of Conduct is currently under review and is expected to be finalized and implemented in the near future. MCI continues to work towards strengthening its procurement processes to ensure that suppliers understand and align with our values and standards. Non-compliance with these expectations may result in appropriate action, including reconsideration of the business relationship.
MCI continues to evaluate opportunities to enhance its standard terms and conditions, including the potential introduction of requirements for suppliers to provide, upon request, written confirmation of the steps they have taken within their own supply chains to address issues such as bribery, corruption, and modern slavery. MCI also aims to incorporate minimum standards relating to ethical business practices, safety, and environmental protection into its contractual arrangements. These initiatives remain under consideration as part of MCI’s ongoing review of its procurement and supplier management processes.
It is important to differentiate that MC is responsible for conducting compliance and due diligence processes with respect to MCI’s indirect suppliers, as MC oversees the governance and manufacturing of Mazda vehicles globally. For suppliers with whom MCI has a direct contractual relationship, such as Consulting Services, Corporate Apparel, Fleet Management, Information Communications and Technology, Logistics and Transport, Marketing, Office Cleaning, Office Supplies, Print and Promotional Goods and Services, Property Services and Travel, MCI continues to review and consider enhancements to its due diligence practices as part of its ongoing procurement and supplier management processes.
MCI has a number of mechanisms for stakeholders and third parties to anonymously report suspected or actual illegal activities, breaches of human rights and/or Company policies. One such mechanism is the completion of an annual Global Employee Survey, which allows Mazda employees to anonymously share their concerns.
In addition, MCI provides an ethics hotline and webform, which can be used by employees and other internal stakeholders to confidentially report concerns or grievances of this nature. These tools are specifically designed to facilitate the reporting of issues related to modern slavery, human rights, and other ethical concerns within the organization.
Reports may also be submitted via direct correspondence, social media, or through bodies such as Canada’s federal and provincial Human Rights Commissions.
All grievances are promptly acknowledged, logged, and subject to an investigation process in accordance with regulatory requirements. Investigations are conducted by trained personnel, ensuring confidentiality, protection against retaliation, and timely resolution. MCI regularly reviews and updates its grievance procedures to ensure they remain comprehensive, accessible, and effective, and communicates the availability of these mechanisms to all employees, suppliers, and stakeholders.
Modern slavery has the potential to exist in supply chains in a number of ways, including by child labour, debt bondage, forced labour, and human trafficking.
MCI therefore recognizes the following risks in its operations and supply chains:
MCI considers the third risk the most likely (if any) that may link MCI to modern slavery practices. MCI is highly aware of the risk that its operations, products, or services may be connected to modern slavery through the activities of another entity MCI has a business relationship with, including those suppliers which maintain a majority of operations outside Canada. These business relationships include all entities in the Mazda supply chain, including entities MCI does not have a contractual relationship with. It also includes all business partners but does not include customers who purchase Mazda products and services.
MCI considers products and services arising from Office Cleaning, Corporate Apparel and Print and Promotional Good sectors, as well as some subsets of the Vehicle Manufacturing and Parts Supply Sectors, to present the highest risk of modern slavery in Mazda’s supply chain. MCI appreciates its most severe modern slavery risks may not align with the volume or cost of the products and services procured.
MCI further recognizes that products and services procured from select countries may constitute some of the highest modern slavery risks. This is due to a variety of factors including some countries maintaining poor governance, weak rule of law, conflict, migration flows, and socio-economic factors such as poverty.
MCI is committed to continually improving how we work with business, government, suppliers, and society to meet moral and ethical obligations to combat modern slavery. MCI is strongly committed to working with its suppliers to eliminate modern slavery from its supply chain.
As a leading vehicle importer and distributor, MCI considers the risk of modern slavery within its direct business operations to be low, particularly when considering that all Mazda products that are imported into and distributed across Canada are overseen from Richmond Hill, Ontario under the supervision of MCI’s management and employees. Nevertheless, MCI recognizes that its supply chain and customers can be indirectly exposed to modern slavery risks.
MC works with MCI’s indirect stakeholders to identify and understand the impacts of its activities. Due diligence is implemented to prevent and mitigate adverse impacts arising from MC’s activities. This due diligence refers to an ongoing management process to identify, prevent, mitigate, and account for how MC addresses actual and potential adverse human rights impacts in its operations and supply chains.
The due diligence process is initiated by a risk identification and assessment of suppliers prior to any contracting. These measures are discussed in more detail below. MCI being a small/medium Canadian enterprise understands that its ability to use its leverage to minimize modern slavery risks may be limited, particularly when engaging with large conglomerate organizations further down its supply chain.
MCI is not aware of any confirmed or suspected instances of forced labour or child labour within our supply chain. If any instances of child labour or forced labour are identified, MCI would address them on a case-by-case basis using the tools currently available to MCI, including without limitation the termination of contracts, reporting of illegal activity to law enforcement agencies, and excluding the offending suppliers from future opportunities to conduct business with MCI if they cannot provide sufficient evidence that forced labour and child labour have been eliminated from their supply chain or business practices.
MC is actively conducting human rights due diligence initiatives in partnership with Caux Round Table (CRT) Japan, a third-party non-profit organization. In the financial year 2024, MC undertook human rights impact assessments involving identified suppliers or sales companies in Japan as part of its ongoing efforts to strengthen human rights protections throughout its value chain. In January 2018, MC signed the United Nations Global Compact. This is a voluntary effort by corporations and organizations to be good corporate citizens by exercising responsible, creative leadership and to build a global framework for sustainable growth. Mazda works to uphold the 10 principles of the United Nations Global Compact, including protecting human rights, eliminating all forms of forced labour, undertaking environmental initiatives, and working against corruption. Mazda is committed to contributing to the development of a sustainable society through these activities.
To measure whether the steps outlined in this Report are achieving their intended purpose, MCI monitors a set of objective, readily verifiable indicators. These indicators include (i) the percentage of employees who successfully complete the mandatory “Modern Slavery & Human Trafficking: Canadian Edition” training module (100 percent as of March 31, 2025), and (ii) the volume and outcome of any grievances or incident reports received through MCI’s whistleblower and stakeholder-feedback channels that relate to forced or child labour. Analysis of these data points allows MCI’s management to determine whether current controls are effective, to benchmark progress against internal expectations and industry norms, and to identify areas where additional resources or remedial actions may be required.
On December 19, 2024, MCI implemented an online training course in both English and French, entitled Modern Slavery & Human Trafficking: Canadian Edition. MCI worked with a third-party provider to implement this training course which was designed to provide a better understanding of modern slavery and human trafficking, how these crimes happen, what they can look like, how to spot the warning signs, what to do if one suspects its occurrence, and the role that staff can play in ensuring that supply chain partners are socially and ethically responsible. As of March 31, 2025, 100% of MCI’s staff had completed this training course.
For its 2025-2026 financial year, MCI will continue to review the effectiveness of its policies and procedures, and to identify additional opportunities for further improvement to prevent and reduce the risk that forced labour or child labour is used in its supply chain. In particular, MCI will focus on:
