Anti-Child Labour Report

Fighting Against Forced Labour and Child Labour in Supply Chains Report

For the Year Ended December 31, 2023

FYi Holdings LP, through its subsidiaries, is a leading Canadian provider of eye care services and products. This report is a joint report made pursuant to subsection 11(2) of the Fighting Against Forced Labour and Child Labour in Supply Chains Act (Canada) (the “Act”). It is made in respect of FYi Holdings LP and its subsidiaries that are reporting entities under the Act, being FYi Eye Care Services and Products Inc., FYi Services and Products Quebec Inc., Factory Optical Holdings Inc., BonLook Inc., BonLook Optique Inc., 10778907 Canada Inc. and 655425 B.C. Ltd. In this report “we”, “our” and “FYi” refer to, as the context requires, FYi Holdings LP or, collectively, FYi Holdings LP and the foregoing subsidiaries that are reporting entities.

As an eye care provider, the principal products we provide to our patients and customers are eyewear (i.e. glasses) and contact lenses, together with ancillary products such as eyedrops and eyewear cases and cleaning supplies. Frames and lenses are the most significant tangible goods that we procure, with the vast majority being acquired from large, well-known international providers of such products that also have reporting obligations under the Act or similar legislation in the jurisdictions in which they operate. Such providers have indicated their own commitment to ensuring they and their business partners adhere to high ethical, professional and legal standards, and comply with all laws related to child labour, forced labour or human trafficking and slavery. In certain cases, our affiliates procure products directly from manufacturers overseas. In such cases they may require the manufacturing facility to provide evidence it has successfully completed an annual code of conduct audit. Finally, geographically we operate in Canada and California, which, according to the Global Slavery Index, have a low prevalence of forced and child labour, a low risk of vulnerability to forced and child labour, and comparatively robust governmental oversight of the issue. We are also governed by applicable federal, provincial and state labour laws and standards. As such, we consider there to be a limited risk of forced and child labour occurring in our business and supply chain.

In the event we are informed of, or discover, the probability or confirmed presence of forced or child labour in our supply chain, we will investigate and take the appropriate remedial measures by either ceasing, preventing or mitigating any adverse impacts. We did not identify any instances of forced labour or child labour in our supply chain during our last completed financial year and, therefore, no remedial measures were taken, including those related to remediating the economic impact on the most vulnerable families. We are committed to acting responsibly and ethically; however, given the nature of our business and our assessment of the limited risk of forced and child labour occurring in our business and supply chain, we do not currently provide formal training to our employees on forced labour and child labour but we endeavour to at least annually evaluate whether any such training should be instituted. 

Management, under the supervision of our Board, is responsible for assessing our effectiveness in ensuring that forced labour and child labour are not being used in our business and supply chain. Based on evolving industry standards and trends, the Board provides management ongoing guidance on the orientation FYi should take in addressing Environmental, Social and Governance risks such as responsible supply chain management. As we continue to broaden our understanding of forced labour and child labour risks, we anticipate strengthening our due diligence and assessment processes, while simultaneously facilitating greater knowledge and understanding of such issues across our people and operations.

In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in this report for 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 above.
I make the above attestation in my capacity as a director of the Board of Directors of FYi Holdings GP Inc., the general partner of FYi Holdings LP, for and on behalf of FYi Holdings GP Inc. in its capacity as general partner of FYi Holdings LP.
I have the authority to bind FYi Holdings LP.
Blue ink signature above a straight line.

Dr. Alan J. Ulsifer
Chairman of the Board
FYi Holdings GP Inc.

Date: May 28, 2024.