Modern Slavery

Forced Labour and Child Labour Policy

Lorama Group is committed to protecting human rights and not engaging in forced Labour or Child Labour. We have developed this Forced Labour and Child Labour Policy to clarify our expectations in the areas of human rights and Labour practices within our Company to ensure compliance with Bill S-211 and all other applicable Labour laws and regulations.

Child Labour: we will not engage in or support the use of Child Labour in any aspect of our operations, and we will comply with the minimum age provisions of national laws and regulations. If young workers are employed, we will ensure that the kind of work is not hazardous and does not jeopardize their education or development.

Forced Labour: we will continue to ensure that all forms of forced or compulsory Labour, including coercion, bonded Labour, or human trafficking, are excluded from all aspects of our operations. This includes any work or service which has been exacted from an individual under the threat of penalty and for which the individual has not offered themselves voluntarily.

To ensure compliance with this policy, the following measures and processes have been implemented within our Company:

  • Mapping activities and supply chains: we have conducted comprehensive mapping activities to understand the various steps involved in the production of goods, both within our operations as well as throughout our supply chains.
  • Risk assessment: we have conducted both internal and external risk assessments to identify and evaluate the risks of forced Labour and Child Labour that exist within our activities and supply chains.
  • Action plan development: based on the risks we identified, we have developed and implemented action plans to prevent and mitigate forced Labour and Child Labour.
  • Due diligence policies and processes: we have established due diligence policies and processes for identifying, addressing, and prohibiting the use of forced Labour and Child Labour in our activities and supply chains (Annexure 1 & 2).
  • Supplier engagement: we require our suppliers to have policies and procedures in place to identify and prohibit the use of forced Labour and Child Labour in their activities and supply chains. Additionally, our suppliers will be subjected to regular monitoring and audits to ensure they are complying with our Company’s policies.
  • Remediation measures: we have implemented measures to provide for or cooperate in the remediation of forced Labour and Child Labour, including actions to support victims and prevent recurrence.
  • Grievance mechanisms: we have developed and implemented grievance mechanisms to enable workers and other stakeholders to report concerns related to forced Labour and Child Labour without fear of retaliation.
  • Training and awareness: we have provided mandatory training to relevant employees on forced Labour and Child Labour, ensuring they are aware of the risks and know how to identify and address them.
  • Performance tracking: we plan to track all relevant performance indicators including levels of employee awareness, the number of cases reported and solved through grievance mechanisms, and the effectiveness of our supplier engagement efforts.
  • Regular review and audit: we schedule regular reviews or audits of our policies and procedures related to forced Labour and Child Labour to assess their effectiveness as well as identify potential areas for improvement.
  • External collaboration: we engage with civil society groups, experts, and other stakeholders to collaborate on addressing forced Labour and Child Labour issues and sharing best practices.
  • Transparency and communication: we promote transparency and accountability, we communicate, both internally and externally, how as a Company we address forced Labour and Child Labour.


Lorama Bill S-211 Annual Report

Lorama Supplier Code of Conduct 2024