REPORT ON THE FIGHT AGAINST FORCED LABOR AND CHILD LABOR
Fiscal Year 2024–2025
Seguin Morris Inc.
1. Introduction and Statement of Compliance
This report is published in accordance with the Act to Combat Forced Labor and Child Labor in Supply Chains (S.C. 2023, c. 9). It describes the measures taken by Seguin Morris Inc. during the 2024–2025 fiscal year to prevent and reduce the risks of forced labor and child labor in its operations and supply chain, including the importation of goods into Canada.
Seguin Morris adopts a zero-tolerance approach toward any form of forced labor, child labor, or human trafficking, in accordance with Canadian standards, International Labour Organization (ILO) conventions, and the United Nations Guiding Principles on Business and Human Rights.
2. Structure, Activities, and Supply Chain
Founded in 2006, Seguin Morris Inc. is a general contractor specializing in industrial and commercial electrical and mechanical infrastructure. The company operates primarily in the following sectors:
- Electrical infrastructure (high voltage, lighting, public utilities)
- Telecommunications and networks
- Mechanical construction and HVAC
- Major institutional and industrial projects
- 24/7 emergency and maintenance services
Seguin Morris has over 340 employees and carries out large-scale projects in Canada and internationally, with a significant annual turnover.
Supply Chain
Seguin Morris’s supply chain includes:
- Suppliers of electrical and mechanical equipment
- Specialized subcontractors
- Distributors and manufacturers (primarily in North America)
Certain components (specialized equipment, electronic parts, materials) may come from international markets, which potentially exposes the company to indirect risks, as observed in the industry.
3. Policies and Commitments
Seguin Morris relies on a robust framework inspired by best practices in the industry and among its partners:
3.1 Fundamental commitments
- Strict prohibition of forced labor and child labor
- Compliance with labor laws and human rights
- Fair and safe working conditions
- Zero tolerance for coercion, trafficking, or exploitation
These principles align with the standards set forth in sector-specific policies, where all forms of work must be voluntary and in compliance with applicable laws.
3.2 Human Rights Management Program
Seguin Morris adopts a structured approach inspired by human rights management programs:
- Identification of impacts on communities
- Assessment of risks in operations and projects
- Mitigation measures and ongoing monitoring
- Accountability of managers, employees, and suppliers
4. Due Diligence Process
Seguin Morris has implemented due diligence mechanisms aligned with industry best practices:
4.1 Supplier Qualification
- Supplier evaluation prior to selection
- Verification of compliance with labor laws
- Requirement to adhere to ethical standards
- Use of compliance questionnaires (e.g., suppliers)
4.2 Contractual clauses
- Inclusion of clauses explicitly prohibiting forced labor and child labor
- Right to terminate in case of non-compliance
4.3 Ongoing assessment
- Periodic monitoring of suppliers
- Risk-based reassessment
- Collaboration with partners that comply with standards
These practices are consistent with those of major industry players who require strict compliance with supplier codes of conduct and conduct regular audits.
5. Risk identification and management
5.1 Risk Analysis
The main risks identified are:
- International suppliers (specialized equipment)
- Origin of raw materials (electronics, metals)
- Outsourcing in certain regions
As demonstrated in the industry, risks are generally higher in global supply chains and manufacturing sectors.
5.2 Mitigation Measures
Seguin Morris implements:
- Selection of reputable suppliers
- Preference for local or North American suppliers
- Increased monitoring of high-risk suppliers
- Corrective or termination procedures as necessary
6. Training and Awareness
Seguin Morris ensures awareness among its teams:
- Employee training on human rights and ethical practices
- Integration of principles into operational procedures
- Clear communication of expectations to suppliers
These measures are part of recognized practices aimed at strengthening employees’ ability to identify risks.
7. Reporting and Remediation Mechanisms
Seguin Morris provides:
- Confidential reporting channels
- Protection against retaliation
- Internal investigation process
- Prompt implementation of corrective measures
In the event of non-compliance:
- Suspension or termination of business relationships
- Implementation of corrective plans
- Documentation and monitoring of incidents
8. Effectiveness assessment
For the 2024–2025 fiscal year:
- No cases of forced labor or child labor were identified in operations or the supply chain
- Existing controls are deemed adequate
- Continuous improvement is underway (supplier monitoring, formalization of processes)
This approach to continuous improvement is in line with industry best practices.
9. Conclusion
Seguin Morris Inc. confirms that it:
- Complies with the requirements of the Canadian Act (S.C. 2023, c. 9)
- Has implemented reasonable and proportionate measures
- Continues to improve its due diligence processes
- Maintains a firm commitment to human rights
The company considers its practices to be in line with the expectations of the Department of Public Safety Canada for the 2024–2025 fiscal year.
10. Certification and Signature
Pursuant to section 11 of the Act:
I, the undersigned, having the authority to bind Seguin Morris Inc., certify that I have reviewed the information contained in this report and that, to the best of my knowledge and after exercising due diligence, this information is true, accurate, and complete in all material respects.
Stéphane Séguin
Date: April 10, 2026
President
Seguin Morris Inc.