Bill S-211 Report

This report is filed in compliance with Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act (“the Act”).

Introduction

This report is submitted by CLEVA INTERNATIONAL TRADING LIMITED in accordance with Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act (Bill S-211). This legislation requires entities to report on the steps taken during the previous financial year to prevent and reduce the risk of forced labour or child labour in their operations and supply chains.

1. Structure, Activities, and Supply Chains

1.1 Company Structure

Legal Name: CLEVA INTERNATIONAL TRADING LIMITED
Business Type: E-commerce retailer
Primary Market: Canada
Contact: serviceca@cleva.com

1.2 Business Activities

CLEVA INTERNATIONAL TRADING LIMITED operates an online retail business specialising in outdoor lawn care equipment and robotic lawn mowers. We sell exclusively within Canada through our e-commerce platform.

1.3 Supply Chain Overview

Our supply chain includes:

Manufacturing partners for outdoor lawn care equipment and robotic lawn mowers
Warehousing and logistics providers in Richmond, BC and Scarborough, ON
Shipping and fulfillment service providers
Technology and e-commerce platform providers

2. Policies and Due Diligence Processes

2.1 Code of Conduct and Supplier Standards

We are committed to conducting business ethically and in compliance with all applicable laws. Our supplier agreements include provisions requiring compliance with:

All applicable labour laws and regulations
Prohibition of forced labour, child labour, and human trafficking
Fair wages and working conditions
Freedom of association and collective bargaining rights

2.2 Supplier Due Diligence

We conduct due diligence on our suppliers through:

Initial supplier assessments and questionnaires
Review of supplier certifications and compliance documentation
Contractual requirements for ethical labour practices
Ongoing monitoring of supplier performance and compliance

2.3 Risk Assessment

We assess risks of forced labour and child labour in our supply chain by:

Identifying high-risk countries and industries in our supply chain
Evaluating supplier locations and manufacturing practices
Reviewing industry reports and third-party assessments
Monitoring news and reports of labour violations

3. Forced Labour and Child Labour Risks

3.1 Identified Risks

Based on our assessment, we have identified the following potential risk areas:

Manufacturing operations in regions with known labour compliance challenges
Complex, multi-tier supply chains where visibility may be limited
Subcontracting practices that may reduce oversight

3.2 Risk Mitigation Measures

To address these risks, we have implemented:

Supplier selection criteria that prioritise ethical labour practices
Contractual requirements for compliance with labour standards
Regular communication with suppliers about our expectations
Procedures for investigating and addressing potential violations

4. Remediation Measures

4.1 Remediation Process

If forced labour or child labour is identified in our supply chain, we are committed to:

Immediately investigating the allegation or finding
Working with the supplier to remediate the situation
Ensuring affected workers receive appropriate support
Terminating relationships with suppliers who fail to remediate violations
Reporting violations to appropriate authorities as required by law

4.2 Remediation of Loss of Income

We recognise that remediation efforts must not result in loss of income for vulnerable workers. Our approach includes:

Working with suppliers to ensure workers are not penalised during remediation
Supporting transition to compliant employment where necessary
Considering the impact on workers' livelihoods in all remediation decisions

5. Training and Awareness

5.1 Employee Training

We provide training to relevant employees on:

Recognising signs of forced labour and child labour
Understanding our policies and supplier requirements
Reporting procedures for suspected violations
The importance of ethical sourcing and supply chain transparency

5.2 Supplier Engagement

We communicate our expectations to suppliers through:

Supplier onboarding materials and agreements
Regular updates on our policies and requirements
Resources and guidance on compliance best practices

6. Assessing Effectiveness

6.1 Monitoring and Evaluation

We assess the effectiveness of our measures through:

Regular review of supplier compliance documentation
Tracking and investigating any reports or concerns
Monitoring industry developments and best practices
Annual review of our policies and procedures

6.2 Key Performance Indicators

We track the following indicators:

Number of suppliers assessed for labour compliance risks
Percentage of suppliers with contractual labour standards requirements
Number of employees trained on forced labour and child labour issues
Number of reports or concerns received and investigated

7. Actions Taken During 2024

During the 2024 reporting period, we took the following actions:

Reviewed and updated our supplier agreements to include explicit prohibitions on forced labour and child labour
Conducted risk assessments of our primary suppliers
Provided training to procurement and operations staff on identifying and addressing labour risks
Established internal procedures for reporting and investigating potential violations
Reviewed industry best practices and guidance on supply chain due diligence

8. Approval and Attestation

This report has been approved by the governing body of CLEVA INTERNATIONAL TRADING LIMITED.

In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for the entity 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 Act, for the reporting year listed above.