This Report was prepared by Maple Leaf Sports & Entertainment Partnership ("MLSE", "our" or "we") for the year ended December 31, 2023 (the "Reporting Period") and describes the steps MLSE has taken to prevent, reduce and mitigate the risk that modern slavery, forced labour or child labour is used at any stage of the manufacture of goods imported or sold by MLSE. MLSE acknowledges the ethical, legal, financial and reputational risks of such activities and is committed to building relationships with suppliers who prioritize ethical and sustainable business practices.
This is the first Report prepared by the MLSE pursuant to Canada's Bill S-211, the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the "Act").
HUMAN RIGHTS AND LABOUR PRACTICES REPORT - 2023
- 1. Steps Taken to Reduce the Risk of Forced Labour and Child Labour
MLSE is committed to conducting business in a socially responsible manner and respect for human rights is a core value in our business and an important factor in selecting the suppliers we do business with. -
- We have taken a number of steps in furtherance of human rights during the Reporting Period, which we believe will help to reduce the risk of forced labour and child labour in our supply chain:
-
- We undertook a review of our supplier relationships to ensure that compliance with MLSE's Supplier Code of Conduct is a contractual requirement for the majority of our key suppliers, and began implementing a plan to ensure that he MLSE Supplier Code of Conduct will be a requirement in all new contracts on a going forward basis;
- MLSE had discussions with each of our key league partners (NHL, NBA, MLS and CFL, collectively, the "Leagues") to ensure that (a) they were aware of the requirements of the Act, and (b) to understand the steps they have taken or will take to reduce forced labour and child labour in the manufacture of licensed goods that MLSE sells pursuant to League licensing agreements; and
- While MLSE implemented a Supplier Code of Conduct in 2021, following the passage of the Act, we undertook to review and update our Supplier Code of Conduct in order to implement changes intended to strengthen the requirements for our suppliers with respect to human rights in the manufacture of goods that enter MLSE's supply chain.
- We undertook a review of our supplier relationships to ensure that compliance with MLSE's Supplier Code of Conduct is a contractual requirement for the majority of our key suppliers, and began implementing a plan to ensure that he MLSE Supplier Code of Conduct will be a requirement in all new contracts on a going forward basis;
-
- 2. Business Structure, Activities and Supply Chains
-
MLSE is primarily engaged in the operation of professional sports teams, along with related businesses including operating entertainment venues, live events, restaurants, and retail stores.
Based in and operating out of Toronto, MLSE traces its roots back to the founding of the Toronto Maple Leafs in 1917. MLSE has approximately 3,000 full and part-time employees.
MLSE is privately held and owned by three beneficial shareholders that include BCE Inc., Rogers Communications Inc., and Kilmer Sports Inc.MLSE has produced this report on behalf of itself and its wholly-owned subsidiaries.
MLSE does not manufacture any goods, however MLSE purchases and sells to consumers a variety of goods including sports uniforms and jerseys, lifestyle apparel, and other sports related merchandise including collectibles and souvenirs, along with selling food products to consumers through restaurants and food service operations at our venues.
The MLSE supply chain consists of a mix of goods that we purchase directly pursuant to supplier agreements with vendors, and team-branded goods purchased pursuant to licensing agreements with our Leagues.
Most of the goods that MLSE purchases are sold directly at our venues, 'brick and mortar' retail stores and food service operations. Due to the structure of our League relationships, MLSE is limited in its ability to sell licensed apparel through e-commerce channels, and as a result this represents a very small percentage of MLSE's total goods sales.
- 3. Policies and Due Diligence
In 2021, MLSE implemented a Supplier Code of Conduct and we have since undertaken to make it a requirement for the majority of suppliers and vendors in MLSE's supply chain. Many of our suppliers have long-term supply agreements with MLSE, and compliance with our Supplier Code of Conduct is generally a requirement of renewal or extension of such agreements. MLSE's Supplier Code of Conduct is available online at https://mlse.com/SupplierCode. -
- In addition, MLSE purchases a team-branded uniforms and apparel from a number of League suppliers pursuant to licensing agreements between those suppliers and the respective Leagues. For example, Nike, Inc. produces the official Toronto Raptors uniforms pursuant to an agreement between Nike, Inc. and a company controlled by the NBA, and MLSE sells those uniforms at its venue and on-site retail store. Each of our Leagues has taken a different approach to managing the risk of forced labour and child labour in its supply chains. The NBA, for example, has a Supplier Code of Conduct that applies to each of its suppliers. MLSE has encouraged all of its Leagues, including those based in the United States, to implement measures that align with MLSE's human rights goals.
-
- 4. Assessing and Managing Risk
MLSE recognizes that forced labour and child labour can be present in the manufacture of goods in Canada and overseas. Following internal risk management meetings, we identified that the greatest risks are present in (a) overseas manufactured goods, and (b) overseas seafood supply. MLSE continues to make compliance with the MLSE Supplier Code of Conduct mandatory for all suppliers, including those operating in those industries. In addition, in the case of seafood suppliers, MLSE has included additional contract clauses that require compliance with human rights and labour laws along with additional requirements with respect to measures that include fair treatment, compliance with minimum wage and maximum working hours, and an obligation to ensure there is no child labour in the supplier's business operations.
- 5. Remediation Measures
In the event that MLSE becomes aware, is informed of, or discovers or reasonably believes there to be forced and child labour in its supply chains, we will investigate and take the appropriate remedial measures to cease, prevent or mitigate such actions and any adverse impacts.
To date, MLSE has not identified any instances of forced labour or child labour in our supply chains during the Reporting Period and therefore no remedial measures have been taken, including those related to remediating the economic impact on the most vulnerable families.
MLSE employees engaged in the procurement of retail goods are encouraged to bring information or concerns forward to management and legal staff at MLSE. MLSE also is in the process of implementing training to help employees identify risks and the sources of child labour and forced labour. If non-compliance is identified, MLSE will work to develop an action plan to address and remediate the issue.
- 6. Training
MLSE has recently undertaken to enhance existing training programs by developing a new training module that will be required of all employees engaged in procurement or operations in our procurement, retail and food services groups. The module focuses on learning to identify sources of forced labour and child labour, understanding the impacts of these practices, and includes training on the MLSE Supplier Code of Conduct. We anticipate that roll-out of this new module will be complete by October, 2024.
- 7. Assessing Effectiveness
MLSE has not yet become aware of any instances of child labour or forced labour in our supply chain, however we intend to work towards developing a framework to assessing effectiveness at a future date, which will become part of our overall risk management and governance review processes. We also engage in ongoing dialogue with our League partners on the actions they have taken to reduce the risk of forced labour and child labour and MLSE has expressed its support for those efforts.
- 8. Approval and Attestation
In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the 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 have the authority to bind Maple Leaf Sports & Entertainment Ltd., managing partner of Maple Leaf Sports & Entertainment Partnership.
![](https://cdn.prod.website-files.com/5e160b5d0858b1ede33e5b33/6658c6a985d2917fafb40a18_Screen%20Shot%202024-05-30%20at%202.34.05%20PM.png)
Keith Pelley
President and Chief Executive Officer
Maple Leaf Sports & Entertainment Ltd.
Date: May 30, 2024