That the Board of Directors provide a report to shareholders by December 2019 and updated annually, detailing the due diligence process used by Dollarama Inc. (“Dollarama”) to identify and address risks to human rights from Dollarama’s business.
The report, prepared at reasonable cost and omitting proprietary or confidential information, should address how Dollarama identifies risks to human rights, identifies root causes of adverse human rights impacts, integrates the findings into its decision-making and actions to prevent and mitigate adverse human rights impacts, tracks the effectiveness of these measures, and remedies any adverse human rights impacts that it causes or contributes to. The report should cover all aspects of Dollarama’s business including its own operations, its direct sourcing and importing business, as well as its contracting and supply chains.
Investors, stakeholders and law makers expect international business to conduct effective human rights due diligence within their operations and supply chains. This expectation is delineated in the United Nations Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises.
Dollarama sources more than half of its goods from China and 24 other countries. These suppliers are required to signal adherence to the company’s Vendor Code of Conduct which prohibits the use of child or forced labour and to, at minimum, comply with local laws with respect to wages and working conditions. The company does not currently monitor compliance with its Vendor Code of Conduct nor does it require Vendors to establish any clear standards of practice with regard to critical concerns like labour recruitment and the risk of forced labour, which are known risks in the company’s sourcing countries.
Recent global estimates found that 16 million people are trapped in conditions of forced labour in the extended supply chains of the private sector, generating over $150 billion in profits for illegal labour recruiters and employers through underpayment of wages. Unscrupulous labour recruiters in the exploitation of workers and job seekers through charging fees, withholding personal papers/passports and failing to provide written contracts spelling out the terms of employments.
The retail sector globally has been tackling the issue of forced labour by instituting “no fees” policies and establishing monitoring and ethical recruitment practices. Dollarama, however, has not reported any specific policies or practices beyond its Vendor Code of Conduct.
In the UK, France, Australia and elsewhere governments are moving to require businesses to disclose their due diligence processes for some of the most egregious human rights abuses with a particular focus on forced and child labour. A recent Canadian parliamentary committee recommended adoption of similar laws in Canada, where Dollarama operates its business.
Failure to put proactive policies and procedures in place therefore exposes Dollarama to significant risks, including regulatory action and media reports that negatively impact reputation.
We urge shareholders to support this proposal.