Canada Modern Slavery Statement

Report Under Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act

This joint report is published on behalf of ADP Canada Co. (“ADP Canada”) and its controlling entity, ADP Foreign Holding Coöperatief, U.A. ("ADP Holding”, and together with ADP Canada, the “Reporting Entities” or “our”), under the Fighting Against Forced Labour and Child Labour in Supply Chains Act. This report covers our 2023 financial year and incorporates by reference the Modern Slavery Statement for the Financial Year Ending 30 June 2023 (“2023 Modern Slavery Statement”) published by our parent, Automatic Data Processing, Inc. (“ADP”), which is appended below.

Structure, activities and supply chain

The Reporting Entities are indirect wholly owned  subsidiaries of ADP.

ADP Canada is registered in Canada as an unlisted public company with approximately 2700 associates providing payroll and human capital management services to over 40,000 clients. ADP Canada operates within the professional, scientific, and technical services sector, and is primarily engaged in providing payroll and human capital management services. As an ancillary part of its business, ADP Canada is involved in the import and sale of time and attendance devices in Canada. ADP Canada sources the time and attendance devices wholesale from North American distributors and manufacturers, and keeps an inventory warehouse in Mississauga, Ontario.  ADP Canada, engage hundreds of vendors or a range of services, including cleaning, printing services, software and hardware providers, marketing, production, logistics, network services, building works, professional and IT infrastructure. 

ADP Holding is a holding corporation based in the Netherlands. It does not engage in any commercial activities and relies on the efforts of ADP Canada, as the operating entity, to monitor and manage its activities and supply chains.

Policies, due diligence processes, risk assessment, training, and assessing effectiveness

ADP oversees a global supply chain to procure the goods imported into Canada by its subsidiaries, which includes the Reporting Entities. Accordingly, ADP establishes the global vendor due diligence, risk assessment and broader Corporate Social Responsibility policies and programs, including modern slavery and human trafficking initiatives, policies and processes, which are incorporated into ADP Canada's business operations. This includes identifying risks of forced labour or child labour and the steps taken to assess and manage that risk, employee training, and assessing the effectiveness of its policies and procedures to mitigate the risk of forced labour or child labour in its supply chain. See the attached 2023 Modern Slavery Statement included in Annex A for more information regarding these matters.

Remediation measures

The Reporting Entities have not identified any forced labour or child labour in its activities and supply chains, and no remediation measures have needed to be taken to address forced or child labour or any resulting loss of income of vulnerable persons.

 

APPROVAL AND ATTESTATION

This report was approved pursuant to subparagraph 11(4)(b)(ii) of the Fighting Against Forced Labour and Child Labour in Supply Chains Act, by the board of directors of  ADP Foreign Holding Coöperatief, U.A.

 

Annex “A”

Modern Slavery Statement for the Financial Year Ending 30 June 2023

For nearly 75 years, Automatic Data Processing, Inc. (ADP), a multinational corporation through its many subsidiary entities, has served as a trusted human resources, payroll and benefits partner to employers around the world. Our mission is to provide insightful solutions that drive value and success for our clients by allowing them to focus on their business.

Today, we serve more than one million clients, ranging from small, start-up businesses with a handful of employees to large, multinational companies with tens of thousands of employees spanning the globe. From our humble beginnings as a local New Jersey business in 1949, we have expanded to become one of the world’s largest global business-to-business outsourcers with a global team of approximately 60,000 associates.

As a global corporate citizen, ADP recognizes its responsibility to give back to and generate a lasting, positive impact on the communities in which we operate. This commitment to corporate social responsibility (CSR) is a core pillar of ADP’s Mission, Vision and Values, and encompasses everything from philanthropy, volunteerism and environmental stewardship to diversity, corporate governance, ethics, data privacy and data security.

At ADP, we see our success and the rights of citizens as inextricably linked. We also firmly believe that businesses can and should have a positive impact on the world. That’s why we constantly strive to embed our CSR principles and practices into everything we do.

Our commitment to minimizing the risk of modern slavery and embedding our broader CSR principles is memorialized in our Code of Business Conduct and Ethics (the “Code”), which states that “[e]ach person must be accorded equal opportunity, without regard to their race, color, creed religion, national origin….”. In April 2017, we revised the Code to expressly state that ADP’s approach to human rights is consistent with the United Nations Universal Declaration of Human Rights. These principles prohibit use of any form of slave, forced, bonded, indentured or involuntary labor and require full compliance with the U.K. Modern Slavery Act of 2015 and Modern Slavery Act 2018 (Cth) of Australia. All of our associates receive annual training on the Code and are required to provide an acknowledgement of acceptance. Specific training on modern slavery is also provided to relevant associates annually to help them identify and mitigate modern slavery in the supply chain or operations.

Using internal and external resources, ADP monitors labor laws within the jurisdictions in which we operate in order to recruit and employ our associates in accordance with applicable laws, including age requirements, remuneration, working hours and conditions and we hire our associates in accordance with those laws.  Upon hire, associates are provided materials and training that detail the policies and values core to ADP business.

In addition, the ADP Vendor Code of Conduct, which we adopted in 2016 and is regularly reviewed, includes similar principles to the Code and specifically requires our vendors to comply with modern slavery laws globally, which include the U.K. Modern Slavery Act of 2015 and Modern Slavery Act 2018 (Cth) of Australia. Since its adoption, we have incorporated the Vendor Code of Conduct into vendor contracts, which imposes contractual obligations on our vendors to comply with modern slavery laws with rights for ADP to terminate vendor contracts for failure to meet required standards. It is our goal that each and every ADP vendor around the globe comply with the principles set forth in our Vendor Code of Conduct. ADP engages thousands of vendors for a range of services, including supply by non-trade or unskilled workers to semi-skilled and professionals.  ADP conducts due diligence and risk assessments on all vendors irrespective of the nature of service provided, be it security or cleaning vendors, or business consultants or software developers. Towards that end, in addition to the contractual obligations regarding vendor conduct, our comprehensive vendor assurance process requires all prospective vendors to respond to direct questions regarding any violations of laws designed to punish slavery, servitude, forced or compulsory labor, human trafficking, debt bondage, child labor, and/or forced marriage (collectively “Modern Slavery Laws”). We will not enter into any agreements with any vendor who answers such questions in the affirmative. The vendor assurance process is a centralized model for vendor engagements globally and is conducted by ADP’s dedicated global procurement team, with applicable consultation among relevant ADP subsidiary entities and functions, including support on vendor due diligence, liaising with vendors, and the contracting process. Our process provides us with the capability to request and track certifications, including vendor re-assessments, from our vendors regarding the status of their compliance with specified legal and/or contractual obligations, including modern slavery laws such as the U.K. Modern Slavery Act of 2015 and the Modern Slavery Act 2018 (Cth) of Australia.  Each fiscal year, ADP evaluates on an ongoing basis the practices outlined in this statement.  Therefore, these practices apply for the stated fiscal period as well as the current period. ADP continues to assess and review such practices on an ongoing basis for further improvement opportunities during fiscal year 2024.

The Code, the Vendor Code of Conduct and the governance, risk and compliance solution are periodically reviewed, including an internal audit of the vendor assurance process, to assess their effectiveness. During this reporting period, we analyzed our supply chains and operations to identify modern slavery related risks. Based on this assessment process, we identified certain activities that pose lower modern slavery risks, such as operations handled by staff directly employed by us and professional service providers. We also identified higher risk supplier categories such as hardware suppliers, apparel manufacturers, cleaning service providers, and low-skilled labor recruiting / staffing providers. While recognizing that risks of modern slavery may exist in some of our supply chains, based on our measures, the nature of services provided by ADP, and the vendors engaged to support the provision of ADP’s services and operations, the risk of modern slavery is considered low within ADP, including for its subsidiaries in Australia and the U.K., and its supply chains.

This statement is published on behalf of Automatic Data Processing Limited ACN 003 924 945 (ADP AU), under the Modern Slavery Act 2018 (Cth) of Australia. ADP AU is an indirect wholly owned subsidiary of ADP, registered in Australia as an unlisted public company with approximately 350 associates providing payroll and human capital management services to over 5,000 clients. ADP AU engages hundreds of vendors in Australia for a range of services, including cleaning, printing services, software and hardware providers, network services, building works, professional and IT infrastructure.  ADP conducts the same due diligence and risk assessment on all these vendors as outlined above, including consultation with ADP AU as required. ADP is responsible for ADP's broader CSR program, including modern slavery and human trafficking initiatives, policies and processes within its subsidiaries and has prepared this statement in consultation with ADP AU for purposes of the Modern Slavery Act 2018 (Cth) of Australia. 

Effective on the 8th day of November 2023, this Modern Slavery Statement, covering the period from July 1, 2022 to June 30, 2023, has been duly approved and adopted by the ADP Board of Directors.

Maria Black
Director & Chief Executive Officer

 

Subsidiaries include, without limitation, Automatic Data Processing Limited, Business Management Software Limited and ADP Network Services Limited