Introduction
This report has been prepared by BMW Canada Inc. (“BMW Canada”) in response to the requirements under Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “Act”) for the financialyear ending 31 December 2025.
BMW Canada opposes the use of forced labour and child labour in its supply chains. It is committed torespecting, protecting, and promoting the human rights of people impacted by its operations and supply chain, and to continuously improving its due diligence, risk assessment, remediation, and training processes.
Organizational structure, activities, and supply chain
BMW Canada is part of BMW Group, a vehicle manufacturer and financial services provider. BMW Canada imports vehicles and other goods into Canada and distributes and sells vehicles and other goods in the Canadian market. The ultimate parent company of BMW Group is Bayerische Motoren Werke
Aktiengesellschaft (“BMW AG”), which is headquartered in Munich, Germany.
BMW Canada Inc. comprises the sales and financial services divisions in Canada for the BMW, MINI, and Motorrad brands. The sales division distributes and sells goods manufactured by BMW Group. BMW Group Financial Services Canada (“BMW Financial Services”), the financial services division, provides wholesale
financing to dealerships and regulated consumer loans and leases to retail customers. BMW Experience Centre Inc. is a holding company that does not contract for goods or services. BMW Canada Inc. is supported by head office services provided by BMW Group Canada, including accounting, compliance, and legal services.
All vehicles across BMW Canada’s brands are manufactured outside of Canada, in facilities operated by BMW Group or its approved service providers, and are imported by BMW Canada for the Canadian market, including BMW, MINI, and Motorrad products. BMW Canada also procures various services, including
professional corporate services (marketing, legal, and consulting), vehicle delivery services, roadside assistance services, and warehousing and logistics services. The procurement and management of these locally acquired services are directly overseen by BMW Canada.
2025 Highlights:
• Training Implementation: Conducted comprehensive training for all associates on the Fighting
Against Forced Labour and Child Labour in Supply Chains Act to enhance awareness and compliance.
• Supplier Onboarding Questionnaire: Developed and implemented a supplier onboarding questionnaire to help ensure alignment with our commitment to ethical practices.
• Policy Enhancement: Enhanced awareness of our internal policies to strengthen our stance against forced and child labour, incorporating best practices and regulatory requirements.
• Monitoring and Evaluation: Established a framework for monitoring and evaluating the effectiveness of our initiatives, ensuring continuous improvement in our supply chain practices.
Steps to prevent and reduce the risks of forced labour and child labour
In the financial year ending 31 December 2025, BMW Canada coordinated with BMW Group to take steps to prevent and reduce the risks of forced labour or child labour in its operations and supply chain. Among other things, BMW Group has:
• Continued to require new and existing suppliers, as well as other business partners, to (i) comply with BMW Group standards, including the Supplier Code of Conduct, (ii) participate in Canadaspecific risk assessments, and (iii) apply equivalent requirements to their own suppliers and business partners;
• Monitored risks of forced labour and child labour that could affect supply chains;
• Conducted its annual assessment of the risks associated with BMW Group operations to human beings and the environment, as well as the impact of business activities;
• Evaluated internal and external data sources to identify any risks of modern slavery for tier one suppliers;
• Implemented a register of suppliers with increased modern slavery risks within BMW Group supply chains to guide future assessments;
• Developed a supplier risk questionnaire to determine forced labour and child labour risks of new vendors;
• Expanded existing measures to identify and minimize risks relating to human rights, including forced labour and child labour, through engagement with internal stakeholders, review of affected processes, and analysis of supplier arrangements; and • Provided training to increase awareness of modern slavery risks within local and global supply chains.
• BMW Canada supported BMW Group by reviewing supplier risk profiles relevant to the Canadian market, including service providers involved in logistics, warehousing, and transportation. BMW Canada also engaged in regular consultation with BMW Group’s Supply Chain Integrity Department to align risk mitigation priorities.
Policies and due diligence processes
Governance
BMW Canada has coordinated with BMW Group with respect to policies and due diligence processes in relation to forced labour and child labour.
BMW Group has an internal, cross-functional Supply Chain Integrity Department that oversees BMW Group’s supply chains, including for goods imported by BMW Canada. To support and monitor due diligence requirements and processes, BMW Group has a Chief Compliance Officer who also serves as its Human Rights Officer and regularly updates and advises the BMW Group Board of Management on significant supply chain issues facing BMW Group.
Policies
BMW Group has adopted a Code on Human Rights and Working Conditions that describes how BMW Grouppromotes human rights and implements the International Labour Organization Core Labour Conventions in its business activities.
BMW Group has adopted a Supplier Code of Conduct that prohibits its suppliers from using any form of forced labour and requires suppliers to ensure that no other forms of modern slavery are tolerated. The Code also requires suppliers to prevent the use of child labour in their businesses and supply chains.
Suppliers must pass on these requirements to their sub-suppliers where relevant.
Due diligence processes
BMW Group has approved and is implementing risk assessment and due diligence processes to evaluate, prevent, and mitigate human rights risks in its operations and with suppliers.
BMW Group’s due diligence processes include:
• Performing comprehensive risk analyses on tendering and active supplier sites;
• Assessing vendors to determine modern slavery risk based on geographical location, industry and total spend;
• Evaluating abstract human rights risks based on internal and external data sources;
• Requiring potential suppliers within jurisdictions with increased human rights risks to complete a supplier risk questionnaire;
• Conducting online evaluations of suppliers’ organizational compliance with internal provisions and standards, as well as their internal guidelines and targets along the supply chain;
• Engaging third parties to conduct onsite assessments of suppliers;
• Implementing numerous reporting methods for any employee to raise concerns where human rights abuses are suspected; and
• Analysing and responding to all substantiated information relating to forced labour or child labour in the supply chain.
• BMW Canada applied these due diligence processes particularly in its procurement of logistics providers, roadside assistance services, and marketing agencies in Canada, ensuring that each new supplier was screened for modern slavery risks as part of the onboarding process.
Please refer to the BMW Group website for further information about the due diligence and human rights standards at the BMW Group for our own business area and in our supply chain:
BMW Group - dealer network & other business partners:
https://www.bmwgroup.com/en/sustainability/human-rights.html
BMW Group – due diligence in the supplier network:
https://www.bmwgroup.com/en/sustainability/supply-chain.html
Forced labour and child labour risk
The automotive supply chain is one of the most complicated of any industry with many tiers of suppliers. As a result, the global supply chain is subject to multiple risks and uncertainties. Generally, BMW Group prioritizes the most salient risks connected to its operations and business relationships.
Some suppliers that BMW Group uses to source BMW vehicles, parts, and components are located in jurisdictions with increased human rights risks. Suppliers are required to comply with BMW Group policies and requirements regarding manufacturing processes and procurement arrangements, including those relating to forced labour and child labour. Certain raw materials used in automotive production, such as cobalt, mica, and aluminum, are globally
recognized as having elevated human rights risks. While BMW Canada does not source these materials directly, BMW Group’s due diligence processes address risks associated with these commodities at upstream supplier tiers.
BMW manages the risk of forced labour in the supply chain in various ways, including by investigating the purported risk and, in some cases, seeking alternative sources of supply.
Remediation measures
If any incident of forced labour or child labour is confirmed in BMW Group’s supply chain, BMW-related production at that facility would be stopped immediately, and BMW Group’s relationship with the supplier
may be paused or terminated. If a case of forced labour or child labour is substantiated, BMW Canada will immediately escalate the issue through BMW Group’s Human Rights Officer, initiate a supplier investigation, and require corrective action plans with defined timelines. Failure to remediate may result in suspension or termination of the business relationship..
Employee training
BMW Group’s human rights and modern slavery obligations are accessible by all employees across the BMW Group, including BMW Canada. This access includes key documents referred to in this report, including the BMW Group Code of Human Rights. BMW Canada provides training to increase awareness of modern slavery risks within its local and global supply chains, including live training throughout the year, as part of its mandatory compliance awareness
and training programs. BMW Canada has also implemented a Modern Slavery policy to inform employees of requirements under the Act. The guidance provided includes:
• A definition of modern slavery;
• Information on how to recognise modern slavery risks;
• Action to be taken when a modern slavery risk is identified; and
• Information on how to escalate incidents.
Assessing effectiveness
BMW Group conducts an annual review of the due diligence tools and procedures used in its supply chain, such as risk analyses, complaints procedures, and preventive and remediation measures. BMW Group also
undertakes performance assessments of its prevention and remediation measures to identify and implement effective improvements to targeted due diligence measures. BMW Canada measures effectiveness through indicators such as the number of employees trained, completion rates of supplier
questionnaires, results of supplier assessments, and the number of concerns raised through reporting channels. BMW Canada plans to expand performance indicators over time.
BMW Canada recognises that the review and assessment of its actions to identify and address forced labour and child labour risks in its operations and across supply chains will be an ongoing and evolving process. To this end, BMW Group, in coordination with BMW Canada, continues to develop policies and procedures
and strengthen its due diligence and compliance framework to ensure its effectiveness.
Approval and attestation
In accordance with the requirements of the Fighting Against Forced Labour and Child Labour in Supply Chains Act, and in particular section 11 thereof, we attest that we have reviewed the information contained in the report for the entity or entities listed above. Based on our knowledge, and having exercised
reasonable diligence, we 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.
Dated in Richmond Hill, Ontario, this 31st day of May 2026.
Andrew ScottPresident & Chief Executive Officer, BMW Canada Inc. |
Konstantin OettelVice President, Finance & Administration, BMW Canada Inc. |
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