Social Compliance

Mastronardi Produce Statement – Canada’s Modern Slavery Act

Purpose of This Report

This report (the “Report”) highlights the actions that Mastronardi Produce Limited (“Mastronardi Produce”) has taken to ensure that no forced labour, child labour nor modern slavery exist in Mastronardi’s operations and supply chain during the fiscal year ending December 31, 2024. The Report has been prepared pursuant to Section 11 of the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “Act”). The use of the words “we”, “us” and “our” refers to Mastronardi Produce.

Our Company and Operations

Mastronardi Produce is an Ontario based company with our corporate headquarters in Kingsville, Ontario Canada.

We supply fresh produce including many varieties of tomatoes, peppers, cucumbers, lettuce, and berries. We have both owned and contract growers in our supply chain and our produce is grown in the Americas and Europe.

Modern Slavery Risk Assessment and Mitigation

To assess and mitigate risk, we require that each supplier facility, greenhouse, packhouse and distribution center location carry out an approved social compliance audit that covers Labour Standards, Health & Safety, Business Ethics and Environment. Using risk assessments and social audits enables Mastronardi Produce to identify potential areas of risk and non-compliance in our operations. In our risk assessments we have not identified any cases of forced or child labour.

The agricultural sector carries an inherent risk for forced labour in supply chains. The risks are strongest in:

  1. the use of agency workers and migrant labour; and
  2. labour in field growing operations.

Policies and Due Diligence Process in Relation to Forced Labour.

We operate strictly in accordance with the legislation in the countries in which we operate, and our Mastronardi Code of Conduct requires that our suppliers do the same. Our policies and protections for workers are regularly reviewed, and we update them to provide additional protections to workers. Our policies include:

  • Our Supplier Code of Conduct
  • Our Employee Handbook and Policies on non-discrimination
  • Compliance with local laws relating to Farm Labour Contracts
  • Health and Safety Policies and Procedures

Our Due Diligence Includes:

  • Appropriate Social Compliance Audits including:
    • EFI, Fair Trade or SMETA audits of Mastronardi’s operations
    • EFI, Fair Trade or SMETA audits of all supplier greenhouses and packhouses located in medium- and high-risk countries (and some located in low-risk countries)

    Audits will verify the worksite and any accommodations to ensure that employment is freely chosen, child labour is not used, living wages are paid, working hours are not excessive, regular employment is provided, and no hard or inhuman treatment occurs.

  • In-person visits to all supplier growers.
  • Berry Farm Auditing and Compliance Processes for all field grown berry farms, which includes in­ person visits by Mastronardi employees and outside audits.
  • Providing growers with a copy of our Supplier Code of Conduct and requiring them to sign a document stating they will follow the requirements outlined in the Supplier Code of Conduct.
  • Feedback and suggestion boxes
  • Reporting hotline

Our employment practices that ensure no forced labour nor child labour is used include:

  • No charging of recruiting fees
  • No holding of paychecks or savings
  • No holding of passports or other documents
  • Freedom of movement from bunkhouses
  • Contracts translated into the contractor’s language
  • Reporting and tipline posters hung in bunkhouses at the farms
  • Suggestion boxes
  • Confidential interviews with auditors
  • Social Compliance audits that include confidential interviews with auditors.

Steps Taken in Prevention and Risk Reduction

All suppliers have signed the Supplier Code of Conduct which forbids forced labour and child labour.

Mastronardi Produce employs a Social Compliance Director and a Social Compliance team, operating inside of the Compliance and Corporate Legal organizations, to ensure that all facilities are audited through appropriate schemes.

In 2024 all appropriate audits were completed for owned, operated and contracted facilities.

Employee Training

All Mastronardi Produce employees who are involved in human resources, assess labour and human rights risks or manage farm workers took the Mastronardi Produce updated Code of Conduct training. This training is mandatory for employees working in these aspects of our business.

Measures Taken to Remediate the Loss of Income to the Most Vulnerable Families that Result from any Measures taken to Eliminate the Use of Forced or Child Labour in our Activities or Supply Chains

We have not identified any lost income for vulnerable families resulting from our measures taken to eliminate the use of forced of child labour in our activities and supply chain. Should we identify any instances of this nature in the future, we will investigate and consider remediation plans appropriate to the circumstances and in accordance with international standards.

Effectiveness

Mastronardi Produce did not find any instances of forced labour or child labour in operations or supplier operations in 2024. We continue to operate in accordance with our policies and best practices for labour, social compliance and health & safety. Mastronardi Produce has not yet taken any actions to assess the effectiveness of our policies and best practices and intends to do so at a later stage.

Communication and Reporting:

A copy of this Report is available in Public Safety Canada’s Forced Labour in Canadian Supply Chains Report Registry at Public Safety Canada. Additionally, this Report is posted on the Mastronardi Produce website.