Ministry Of Public Safety Annual Forced & Child Labour Report

Section 1: Purpose of Report

This report has been developed in response to the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “Act) which came into force on January 1, 2024.  This legislation requires certain employers to submit an annual report regarding force & child labour in their supply chain to the Ministry of Public Safety and Emergency Preparedness we well as to post this report in their company website.  This report has been drafted for the purpose of ensuring Fulger Transport Inc. is compliant with this legislation.  As outlined in the act this report will contain the seven mandatory sections as shown below.  

Section 2: Organizational Description

Entity Structure:  Fulger Transport Inc. is managed and overseen by its single private owner.  The company is managed by the President who oversees the core departments of the firm, each of which are management by their Department Managers.  The core departments of the company include Sales, Brokerage, Operations, Safety, Fleet Management, Maintenance, Human Resources, and Accounting.  

Activities: The primary business activity of Fulger Transport Inc. is to transport refrigerated goods across the US & Canada via road vehicle transportation.  These activities include both using company owned assets to transport goods as well as brokering out transactions to third party carriers. The company mainly services Ontario as well as the east coast states and the southern states of the USA.  

Supply Chains: Fulger Transport Inc.’s supply chains are primarily integrated with the type of cargo it transports.  Most of the refrigerated products that are transported are food products such as meat, vegetables, frozen foods, etc.  The vast majority of freight the company transports is produced and distributed in North America. For example, a pepper may be grown in Ontario by a manufacture, then Fulger Transport would transport the product to Michigan to the final retail center who would sell the product to the consumer.  There is a small portion of our business that involves international transported product.  An example of this would be a product that is delivered by boat from overseas, Fulger Transport would transport the product via road from the port to the distribution center.  

Section 3: Policies & Due Diligence Process

Being that the vast majority of the company’s supply chain is based in North America and the majority of the product the company moves is produced in North America the risk of child and/or forced labour in its supply chain is greatly reduced compared to firms heavily involved in international/oversea supply chains.   Fulger Transport conducts background checks on all new clients they service which include credit checks and legal backgrounds to ensure there are no outstanding legal issues such as Human Right violations.  Fulger Transport is also certified and participates in the CTPAT Program (Customs-Trade Partnership Against Terrorism) and the PIP Program (Partners in Protection) which has a variety of requirements that ensure good business practices are being followed both inside and outside the company.  The company has a comprehensive Reporting System that all employees are trained on which provides them an avenue and instruction on how to report any concerns they may have included Human Rights violations.  The company also completes background checks on all new employees and has a variety of vetting activities to ensure all employees are of age and are fully consenting to employment without any presence of coercion.  

Section 4: Risk Points & Reduction Strategies

With most of our product being produced and transported within North America the risk points of child and/or forced labour are greatly reduced compared to international trade companies.  The majority of companies we service are subject to the same legal framework and enforcement bodies as all other North American companies which ensure a fairly effective strategy to deterring or eliminating child/forced labour.  The primary risk point in Fulger Transport’s supply chain come from the less common service avenue of transporting raw material from oversea locations.  This may account for five percent or less of the company’s operations.  An example of this type of activity would be if a pineapple is transported from overseas by boat and arrives at a North American port where it is picked up and transported by Fulger Transport to be delivered to a packaging facility.  

However, based on the operational design our firm does not have any contact with these sourcing locations nor viable means to discovered where the product originated.  Usually by the time the product comes to a Fulger Transport truck at a sea port it would have passed through more than six separate companies’ hands who themselves typically have little to no knowledge of the exact sourcing location.  Typically, all the information the client requesting the transportation are willing to provide is the type of product, the total weight, and the starting/ending locations.  Fulger Transport trusts in the integrity of its clients to ensure they practice morally sound business decisions.  Fulger Transport also trusts in government enforcement bodies including North America bodies to ensure they require applicable companies to adhere to all legal requirements of their operating regions.  

Section 5: Remedying Measures Taken

Fulger Transport has taken all reasonable measures to ensure it does not directly participate in child/forced labour nor promote these behaviours by servicing other companies who do engage in these activities.  Fulger Transport is always searching for new ways to ensure it adheres to all legal and moral obligations in its business practices.  Fulger Transport also invites all parties including government agencies and individuals to pass along any suggestions they may have to help ensure this goal is achieved.  

Section 6: Vulnerable Parties Impacts

At this time the company has not been able to identify impacts to vulnerable parties either directly through its actions or through remedying actions it has implemented.  Fulger Transport is always searching for new ways to ensure it adheres to all legal and moral obligations in its business practices.  Fulger Transport also invites all parties including government agencies and individuals to pass along any suggestions they may have to help ensure this goal is achieved.  

Section 7: Employee Training

All employees receive standard employment training including instruction on how to report any issues including Human Rights violations.   Fulger Transport is always searching for new ways to ensure it adheres to all legal and moral obligations in its business practices.  Fulger Transport also invites all parties including government agencies and individuals to pass along any suggestions they may have to help ensure this goal is achieved.  

Section 8: Accessing Effectiveness

At this point in time Fulger Transport has determined its current activities to company forced/child labour are sufficient given its level of involvement and control over these activities.  In the event further direction is provided to the company the firm would be able to engage in an in-depth effectiveness assessment and determine areas of improvement.