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Modern Slavery Act

Canadian Statement Against Forced Labour and Child Labour in Supply

Chains pursuant to the Fighting Against Forced Labour and Child Labour in Supply

Chains Act (the "Act")

for the year ending 1/31/2026

 

 

1. INTRODUCTION

This report (the “Report”) constitutes the third report prepared by Foot Locker Inc., and director of Foot Locker Canada Co. ("Foot Locker Canada Co." or "the Company") pursuant to the Act.

2. REPORTING ENTITY

This report concerns reporting entity, Foot Locker Canada Co., a retail trade entity, business number 134482702.

The reporting period of this report is 2/2/2025 - 1/31/2026.

Foot Locker Canada Co. meets the applicable legislative requirements concerning business, size, revenue thresholds for reporting.

3. STRUCTURE, ACTIVITIES, AND SUPPLY CHAINS

Foot Locker Canada Co. is a corporation incorporated pursuant to the laws of Nova Scotia that engages in producing goods outside Canada and Importing goods manufactured outside Canada. Foot Locker Canada Co. engages in the sale of retail goods (footwear, apparel, and accessories).

4. POLICIES AND DUE DILIGENCE PROCESSES IN RELATION TO FORCED LABOUR AND CHILD LABOUR

Foot Locker Canada Co. has implemented policies and due diligence processes related to managing the risk of forced and child labour, including (1) embedding responsible business conduct into policies and systems; (2) identifying and assessing adverse impacts to operations, supply chains and business relationships; (3) ceasing, preventing and mitigating those adverse impacts; (4) tracking implementation and results; (5) communicating to stakeholders how impacts are addressed; and (6) remediation of cooperation when necessary.

The company is committed to respecting international human rights standards and seeks to avoid any negative impact on human rights arising from its business activities. This commitment is based not only on our own values, but also on the ILO Declaration on Fundamental Principles and Rights at Work, the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises and the UN Universal Declaration of Human Rights. The company currently has a Code of Business Conduct and global sourcing standards, which support compliance with human rights and ethical business conduct across our operations and supply chain.

5. PARTS OF BUSINESS AND SUPPLY CHAINS THAT CARRY A RISK OF FORCED LABOUR AND CHILD LABOUR AND STEPS TAKEN TO ASSESS AND MANAGE THAT RISK

We recognize apparel is a potential area of risk and by its nature contains risk of forced and child labour. However, through our compliance practices and policies, we have performed due diligence to minimize risk in our supply chain. In addition, Foot Locker Canada Co. continues to conduct regular assessments in an effort to strive to identify new and emerging risks. Among the considerations in assessing risk in our supply chain are the types of products we produce, sell, distribute and import, along with the types of products we source. We also assess the locations of our activities and

factories. An additional consideration is the raw materials used in our supply chains, such as cotton. Lastly, our risk assessment includes a review of our Tier 1, direct suppliers who may outsource, contract, or subcontract labour.

The Company uses various methods to prevent and reduce the risk of forced labour and child labour in our supply chain. Such activities include the following:

  • Supply Chain Mapping;
    • internal assessments of risks of forced and child labour in our activities and supply chains;
    • developing and implementing action plans for addressing forced and child labour;
    • gathering information via our audit process on worker recruitment to ensure workers all workers are recruited voluntarily;
    • developing and implementing policies and processes for identifying, addressing and prohibiting the use of forced and child labour in our activities and supply chains;
    • prioritizing efforts on the most severe risks of forced and child labour;
    • requiring suppliers to have in place policies and procedures for identifying and prohibiting the use of forced and child labour in their activities and supply chains;
    • developing and implementing child protection policies and processes;
    • developing and implementing anti-forced and child labour contractual clauses, standards, codes of conduct, and compliance checklists;
    • auditing and monitoring suppliers;
    • enacting measures to provide for, cooperate in, and remediate forced and child labour; and
    • developing and implementing procedures to track vendor performance in addressing forced and child labour.

6. STEPS TAKEN TO REMEDIATE FORCED LABOUR AND CHILD LABOUR

Foot Locker Canada Co. has not taken measures to remediate forced or child labour because we have not identified any actual forced or child labour in our activities and supply chains.

7. MEASURES TAKEN TO REMEDIATE LOSS OF INCOME TO MOST VULNERABLE FAMILIES THAT RESULT FROM MEASURES TAKEN TO ELIMINATE USE OF FORCED LABOUR AND CHILD LABOUR

Foot Locker Canada Co. has not taken measures to remediate loss of income to the most vulnerable families that result from measures taken to eliminate use of forced and child labour because we have not identified any use of forced or child labour in our activities and supply chains during the applicable reporting period.

8. TRAINING PROVIDED TO EMPLOYEES ON FORCED LABOUR AND CHILD LABOUR

Foot Locker Canada Co. provides training to employees who are engaged in the entity's supply chain compliance to identify and deal with any potential instances of forced and or child labour. Training is provided from the parent company and from third-party providers.

9. HOW ENTITY ASSESSES ITS EFFECTIVENESS IN ENSURING THAT FORCED LABOUR AND CHILD LABOUR IS NOT BEING USED IN ITS BUSINESS AND SUPPLY CHAINS

The Company regularly reviews and audits the organization's policies and procedures related to forced and child labour. We partner with external organizations to conduct independent reviews and audits of the organization's actions. In addition, we work with our suppliers to measure the effectiveness of their actions in addressing forced and child labour, including tracking performance indicators. For additional information regarding our policies and procedures related to forced and child labour, please reference the Foot Locker, Inc. Impact Report.

 

ATTESTATION

In accordance with the requirements of the Act, and in particular section 11 thereof, I, Steve Miller, in the capacity of a Director, Senior Vice President, attest that I have reviewed the information contained in the Report on behalf of the governing body of the entity [or entities] 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 purposes of the Act, for the reporting year listed within this report. 

 

 

Name: Steve Miller

Title: Director and Senior Vice President of Foot Locker Canada Co.

Date:  5/29/2026