MODERN SLAVERY STATEMENT

Fighting Against Forced Labour and Child Labour in Supply Chains Report Act for Financial Year Ended 2024

Contents:

  • About this Report
  • Introduction
  • Structure
  • Activities
  • Our Supply Chain
  • Policies and Due Diligence in Relation to Forced Labour and Child Labour
  • Risk of Forced Labour or Child Labour
  • Training Provided to Employees on Forced Labour and Child Labour
  • How We Assess Our Effectiveness
  • Attestation
  • About This Report

    • October’s Very Own Merchandising (“October’s Very Own, “OVO”, “we” or “us”) has prepared this report (the “Report”) being submitted pursuant to Section 11 of the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “Act”) for the financial year ended December 31, 2024.

    Reporting Entity

    October’s Very Own Merchandising (Ontario)

    Principal Activities

    Apparel brand specializing in the design, manufacture and global sale of apparel, headwear and accessories.

    This Report describes the ongoing efforts to enhance the transparency in our supply chain by outlining the steps taken during the 2024 financial year. This has been done in accordance with the mandatory reporting criteria outlined in Sections 11(1) and 11(3) of the Act.

  • Introduction

    • OVO is a lifestyle apparel brand founded in 2008 and headquartered in Toronto, Ontario, Canada.

  • Structure

    • OVO is a partnership existing under the laws of Ontario, Canada.

    In 2024, the OVO employed approximately 289 employees in Canada.

  • Activities

    • OVO specializes in the design, manufacture and global sale of apparel, headwear and accessories, as can be found on our website: https://ca.octobersveryown.com/ (our “Products”).

    Our Products are sold globally via the following sales channels:

    • direct-to-consumer sales in OVO branded retail stores or via our website; https://ca.octobersveryown.com/ (or global variations thereof); and
    • wholesale sales to authorized third-party retailers.
  • Our Supply Chain

    • Our Products are designed in Toronto, Ontario, Canada, manufactured primarily across North America, Europe, and Asia and shipped globally via the channels identified above.

    OVO has an in-house Product & Sourcing team that manages a network of third-party contract manufacturers. Only authorized manufacturers may product OVO Products.

  • Policies and Due Diligence in Relation to Forced Labour and Child Labour

    • Our policies and due diligence efforts are described further below

    • Policies:
      • OVO Code of Conduct Policy: OVO’s Code of Conduct Policy prohibits forced and involuntary labour, the use of child labour and reflects international standards set out in the Universal Declaration of Human Rights, the UN Convention on the Rights of the Child, and applicable ILO Conventions and federal Legislation.
    • Due Diligence Processes and Procedures:
      • Supply Chain Mapping: In 2025:, OVO mapped out it’s Tier 1 suppliers and is actively expanding visibility into Tier 2 suppliers. This process allows us to identify geographic and product-specific risks (e.g., regions with high prevalence of forced or child labour).
      • OVO Code of Conduct Policy: All suppliers, their subcontractors and other business partners are required to abide by OVO’s Code of Conduct Policy, which was introduced in 2024. All transport and logistics partners have executed OVO’s Conde of Conduct Policy, and we are targeting full execution by all manufacturing partners by the end of 2025.
      • Training: OVO will be introducing general training in 2025 for certain staff on the topic of forced & child labour.
      • Contractual Terms: OVO will be updating its standard Manufacturing Agreement in 2025 to include provisions related to compliance with laws, ethical business practices and sanctions compliance, anti-corruption law compliance and a zero-tolerance policy for unauthorized subcontracting by otherwise authorized suppliers.
      • In-House Legal Department: In 2025, OVO added full-time in-house legal counsel to assistwith compliance efforts.
  • Risks of Forced Labour or Child Labour and Steps Taken to Assess and Manage that Risk
    • Steps Taken in 2024 to Prevent and Reduce the Risk of Child and Forced Labour: In 2024, OVO took the following steps to prevent and reduce the risk of child and forced labour being present in any step of its supply chains:
      • introduced the OVO Code of Conduct Policy to suppliers & vendors;
      • third Party Social Compliance Audit;
      • site-Visits: Informal site-visits to local factories in Canada; and
      • sourcing employee undergoing Fair Labour Association (FLA) quarterly trainingII
    • Risks of Forced or Child Labour in Our Activities: With respect to its own operations, OVO considers the risk of forced and child labour to be low. In reaching this conclusion, OVO considered the following factors:
      • OVO follows stringent employment practices in accordance with Canadian labour laws, which mitigate the risk of forced and child labour; and
      • according to the Global Slavery Index, published by Walk Free—an international human rights organization—Canada ranks 17th lowest out of 160 countries in the prevalence of modern slavery, which includes both forced and child labour.
    • Risk of Forced of Child Labour in Our Supply Chains: Although OVO has not identified any instances of forced or child labour in its supply chains, we recognize that these risks exist across all industries and sectors—particularly within the global apparel industry and in certain geographic regions. As such, we acknowledge that there is a risk of forced and child labour occurring in OVO’s supply chains. In particular, some of our Tier 1 suppliers operate in countries with elevated human rights concerns.
    • Mitigation of Potential Risk: While OVO has not identified any instances of forced or child labour in its supply chains, we recognize the inherent risks in global apparel sourcing. In 2024, we took the steps identified in section 7.I., and plan to build on this foundation by continuing to implement our Code of Conduct Policy across all Tier 1 suppliers, enhancing contractual protections, and introducing employee training in 2025.
    • OVO Did Not Identify Any Forced Child Labour in Its Operations or Supply Chains: In 2024, we did not identify any instances of forced or child labour. Accordingly, no specific remediation measures were required during the reporting period.
  • Training Provided to Employees on Forced Labour and Child Labour: With the exception of FLA training, no formal training was conducted in 2024. However, we will be introducing training for certain staff in 2025, with the goal of building internal capacity to identify and manage labour risk.
  • How We Assess Our Effectiveness: As we continue to evaluate our policies, procedures and risk mitigation strategies, we intend to consider implementing processes or benchmarks, where appropriate, to assess the effectiveness of our processes.
  • Attestation:

    • This Report was approved by the partners of October’s Very Own Merchandising, in their capacity as the general partner of October’s Very Own Merchandising, pursuant to section 11(4)(a) of the Fighting Against Forced Labour and Child Labour in Supply Chains Act, on May 30, 2025.

    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.

Oliver El-Khatib
Partner, October’s Very Own Merchandising
Dated: May 30, 2025