ARCELORMITTAL CANADA HOLDINGS INC. & ARCELORMITTAL LONG PRODUCTS CANADA G.P.
Fighting Against Forced Labour and Child Labour in Supply Chains Act Report
This statement is made by ArcelorMittal Canada Holdings Inc. (“AM Holdings”) a subsidiary of ArcelorMittal SA on behalf of itself and its subsidiaries ArcelorMittal Canada Inc., ArcelorMittal Long Products Canada G.P. (“Long Products”) (collectively the “Subsidiaries” and together with AM Holdings the “Company”) pursuant to the Fighting Against Forced Labour and Child Labour in Supply Chains Act, SC 2023, c. 9 (the “Act”) for the reporting year 2023 and sets out the steps it has taken to prevent and reduce the risk that forced or child labour is used at any step in the production of goods in Canada or elsewhere or of goods imported into Canada by the Company. As part of the ArcelorMittal group of companies (“ArcelorMittal Group”), the Company is committed to preventing acts of forced labour and child labour within its business and supply chain and expects the same from its suppliers and partners.
General Policies and Approach to Forced and Child Labour
Our approach to preventing forced and child labour in our activities and supply chains is set out primarily in the ArcelorMittal Human Rights Policy (which is derived from various International Human Rights Declarations including the United Nations Declaration of Human Rights) and various ArcelorMittal Group policy documents (the “Policy Framework”) which is structured to ensure the ArcelorMittal Group operates with the highest level of integrity and compliance with applicable laws. Through the Policy Framework, the ArcelorMittal Group asks its suppliers to have effective management systems in place to achieve the social, environmental and governance objectives to which the Company is committed. The Company also seeks to influence its suppliers to work together to identify further opportunities to improve responsible business practices along the supply chain and develop ongoing performance improvements to the Policy Framework. The following are the main policies of the Policy Framework setting out the Company’s general approach to the risks of forced and child labour:
Code of Business Conduct: Articulates the fundamental legal and ethical principles that guide the Company’s conduct and prohibits the use of forced or child labour. It also sets out the Company’s commitments to a work environment free of harassment and discrimination, promoting occupational health and safety and respecting the environment.
Human Rights Policy: Articulates the Company’s commitment and respect for all human rights in line with the United Nations Guiding Principles on Business and Human Rights. This policy affirms that the Company is opposed to the use of forced labour, child labour, human trafficking and all forms of human rights violations known as “forced labour”, within the Company’s operations and supply chain.
Code for Responsible Sourcing: The Code for Responsible Sourcing (the “Code”) sets out the expectations the Company has of its supply chain in relation to human rights, labour, health and safety, the environment and anti-corruption. This includes ensuring that all work is freely chosen and without the use of forced or child labour. The Code is supplemented by a guidance document for the ArcelorMittal Group’s buyers and suppliers which details specific expectations in relation to force and child labour. Our Code for Responsible Sourcing supports the ArcelorMittal 10 Sustainable Development Outcomes which are aligned with the UN Sustainable Development Goals.
ARCELORMITTAL CANADA HOLDINGS INC.
AM Holdings is a federal corporation and does not produce goods in Canada or elsewhere nor does it import goods produced outside of Canada. AM Holdings controls the Subsidiaries which engage in these activities as highlighted in the following entity specific sections.
ARCELORMITTAL CANADA INC.
ArcelorMittal Canada Inc. is a federal corporation and does not produce goods in Canada or elsewhere nor does it import goods produced outside of Canada. ArcelorMittal Canada Inc. is a subsidiary of AM Holdings and is a direct controlling entity of Long Products which engage in these activities as highlighted in the following entity specific sections.
ARCELORMITTAL LONG PRODUCTS CANADA G.P
Structure, Activities and Supply Chains
Structure
Long Products Canada aCanadian partnership domiciledQuebec is Canada’s fourth-largest steel producer and the only Canadian steelmaker using internally produced direct iron as its primary metallic input. Our wide range of high-quality steel products is sold mainly in Canada and in the United States to the automotive, construction and other industries. Long Products’ main production facilities in Canada are located in and around Contrecoeur, Quebec and include a bar mill in Longueil, Quebec as well as wire mills in Montreal, Quebec and in Hamilton, Ontario
Activities
Long Products have around 1,900 employees in Canada and the operating budget is $1.5
billion dollars. Long Products have an annual production capacity of around 2 million tons.
Supply Chain
Long Products’ supply chain generally includes the sourcing of a variety of raw materials, equipment and specialized services. The main raw material suppliers are located in North America (Canada, USA, Mexico). Some suppliers are located in China, India, Germany, and Austria.
Regarding equipment, the sources of supply are located in North America (Canada, USA, Mexico). Some suppliers are located in China, India, Turkey and Italy.
The main service providers are located predominantly in North America (Canada, USA and Mexico). The procurement of goods and services at Long Products is led by commercial teams with support from legal and tax professionals.
Steps Taken to Prevent and Reduce Risks
Risk Assessment and Mitigation
Long Products completes an annual risk assessment that considers human rights issues as part of its general local risk assessments. The Code includes explicit references and targets relating to our commitment to Responsible Steel and other industry initiatives and standards. We prioritize our approach to selectively engage with our suppliers and focus attention on those parts of the supply chain where the risk of violation of our policies is the highest.
Supply Chain Evaluation
Suppliers are subject to due diligence processes and the Code, Code of Business Conduct and Human Rights Policy as part of our supplier registration process. Long Products also uses third party due diligence software as one way to evaluate new suppliers.
Contractual Requirements
Long Products’ general contracting terms include representations and agreements from the
supplier to comply with key policies within the Policy Framework.
Forced Labour and Child Labour Risks
Long Products recognizes that the jurisdictions in which it sources its goods and services could potentially be directly or indirectly linked to actual or potential risk of forced or child labour and such risks are the focus of the Policy Framework. We have assessed our supply chain and potential risk of exposure exists through our indirect relationships with our raw material and equipment suppliers provided that aims to engage with globally recognized and reputable organizations. Based on annual Human Rights risk assessment, the level of risk is low as it relates to our service suppliers.
Remediation Measures
The ArcelorMittal Group operates a confidential and anonymous whistleblowing facility on its website, in accordance with its Whistleblower Policy through which stakeholders may report ethical concerns, along with our global assurance team, monitors the volume, type and response to such concerns. also operates a community grievance program on its website which encourages its community members to notify of any material environmental or ethical concerns. No further measures have been taken to remediate forced labour or child labour in activities and supply chains.
Remediation of Loss of Income
No measures have been taken to remediate loss of income in activities and supply chains.
Training
All employees are required to be trained and to refresh their training on the Code of Business Conduct every three years. Managers and above, and those in relevant roles, also undertake specific human rights training which is also refreshed every three years. In addition to the mandatory training, the Policy Framework is communicated to employees through various channels, including email communications, compliance videos, local targeted trainings and initiatives.