Canadian Statement Against Forced Labour and Child Labour in Supply Chains
pursuant to an Act to enact the Fighting Against Forced Labour and Child Labour in Supply Chains Act and to amend the Customs Tariff, referred to as Canada’s “Modern Slavery Act” (the “Act”) for the year ending 2023
1. INTRODUCTION
This is a statement made by Hootsuite Inc. in respect of the Act, as referenced above. Hootsuite Inc. is a corporation incorporated pursuant to the laws of Canada.
2. REPORTING ENTITY
This report is being filed on behalf of Hootsuite Inc.
3. STRUCTURE, ACTIVITIES AND SUPPLY CHAINS
Hootsuite is a leading social media management platform that integrates social media sites such as X, Facebook and Instagram. Hootsuite allows its users to, among other things, manage their social media from a single dashboard.
Hootsuite Inc. is the ultimate parent company of Hootsuite and is headquartered in Vancouver, Canada. We operate and have subsidiaries all over the world.
Hootsuite remains vigilant and monitors the level of risk involved through any of our supply chains and will take appropriate measures if a higher risk of modern slavery is deemed to exist.
Hootsuite’s business focuses on the provision of a software-as-a-service platform and professional services. There is no traditional manufacturing of products or “goods”.
Hootsuite uses a limited number of outside consultants and contractors. Any such use is limited to the provision of professional services (e.g software development).
Our vendors are typically hosting or other cloud service providers, as is usually the case for software-as-a-service businesses.
We import a limited number of goods into Canada from one supplier: Apple. This supplier holds its suppliers accountable, reports transparently, and regularly engages experts.
Our vendors are generally located in jurisdictions where we do not consider there to be a high risk of modern slavery, such as the United States.
We ensure we have a robust recruitment process - our HR teams ensure that employees have the requisite authorisations to work in the applicable location.
Overall, and on the basis of the above, Hootsuite does not consider that there is a significant risk of modern slavery existing in our supply chain.
4. POLICIES AND DUE DILIGENCE PROCESSES IN RELATION TO FORCED LABOUR AND CHILD LABOUR
We have implemented policies as part of our commitment to ethical business practices. In addition to our Respectful Workplace Policy, we also have in place a Code of Ethics which requires employees of Hootsuite to conduct business in a way that is fair, ethical and honest and in compliance with all applicable laws and regulations.
Our Respectful Workplace Policy provides that employees of Hootsuite must:
i) treat co-workers with dignity and respect;
ii) not engage in, and prevent workplace discrimination and harassment from occurring; and
iii) report unresolved incidents of inappropriate workplace behaviour.
In addition to requiring that all employees review and acknowledge our Respectful Workplace Policy on an annual basis, we also ensure compliance with all applicable employment legislation relating to employee recruitment and terms and conditions, including obtaining right to work evidence and ensuring that no staff in our global offices are paid less than the applicable national minimum or living wage.
We also expect all of our contractors, suppliers and other business partners to uphold the same high standards that we do, by ensuring all employees and workers are treated with dignity and respect in a fair and ethical environment. We endeavour to review potential areas of risk in relation to our business and, where applicable, consider the nature of what is being supplied and the location from where it is being supplied.
Our Vendor Code of Conduct (the "Code") outlines our expectations regarding the practices and values that our vendors should comply with in order to engage with Hootsuite. The Code is not intended to limit or exclude any other legal or contractual obligations that vendors may owe to Hootsuite. The Code should be viewed as a set of minimum standards expected from the Hootsuite vendor community to ensure vendors share Hootsuite’s commitment to human rights and equal opportunity in the workplace.
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
As described under section 3, Hootsuite does not currently consider the business it carries on or its supply chains to carry a significant risk of forced labour or child labour. Hootsuite remains vigilant and monitors the level of risk of our supply chains and will take appropriate measures if a higher risk of forced labour or child labour is deemed to exist.
6. MEASURES TAKEN TO REMEDIATE FORCED LABOUR AND CHILD LABOUR
This section is not applicable as Hootsuite has not identified any instances of forced labour or child labour in its supply chain.
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
This section is not applicable at this time.
8. TRAINING PROVIDED TO EMPLOYEES ON FORCED LABOUR AND CHILD LABOUR
It is important to us that our employees are aware of the issues surrounding modern slavery and support our values. We intend to work with relevant employees to reinforce any steps that should be taken and to remind them of the channels through which any concerns can be reported.
9. HOW ENTITY ASSESSES ITS EFFECTIVENESS IN ENSURING THAT FORCED LABOUR AND CHILD LABOUR IS NOT BEING USED IN ITS BUSINESS AND SUPPLY CHAINS
We do not currently have a formal method for assessing our effectiveness in ensuring that forced labour and child labour is not being used in our business and supply chains.
HOOTSUITE INC.
_Craig Segal___________________________
Full Name: Craig Segal
Title: Chief Legal Officer & Corporate Secretary
Date: May 30, 2024
Click here to consult our UK and Australia Modern Slavery Act Transparency Statement