Intent & Purpose
Armour Valve Ltd. (“Armour Valve”) is committed to ethical business practices, the protection of human rights, and responsible supply chain management. Although Armour Valve is not a reporting entity under Canada’s Fighting Against Forced Labor and Child Labor in Supply Chains Act (Bill S‑211, “the Act”), we support the Act’s intent and have established this policy to promote safe, fair, and lawful working conditions across our supply chain.
This policy applies to:
- All Armour Valve employees, contractors, and temporary workers
- All suppliers, manufacturers, distributors, and service providers engaged in the supply of products or services to Armour Valve
- All global supply chain partners, regardless of geographic location
Compliance with this policy is a condition of doing business with Armour Valve. To ensure clarity, Armour Valve adopts the following definitions:
- Forced Labor: Work performed involuntarily under threat, coercion, penalty, or deception.
- Child Labor: Work performed by individuals below the minimum legal working age or that is harmful to a child’s health, development, or education.
- Human Trafficking: Recruitment, transportation, or harboring of individuals through coercion or deception for the purpose of exploitation.
- Supply Chain: Any entity involved in the production, distribution, or delivery of goods and services provided to Armour Valve.
- Remediation: Corrective actions taken to address confirmed violations and prevent recurrence.
- Worst Forms of Child Labor: Includes hazardous work, exploitation, trafficking, or any activity likely to harm the health, safety, or morals of a child.
- Recruitment Fees: Any fees or costs charged to workers during hiring or placement. Armour Valve prohibits suppliers from charging such fees.
- Migrant Workers: Individuals employed outside their home country. Armour Valve requires suppliers to ensure migrant workers are protected from exploitation.
Guidelines
Armour Valve strictly prohibits:
- Forced labor
- Child labor
- Slavery or servitude
- Human trafficking
- Any form of exploitation or abuse of workers
Armour Valve also prohibits suppliers from withholding workers’ identity documents, passports, or immigration papers. We expect all partners to uphold safe, fair, and lawful working conditions. This includes maintaining non‑discriminatory practices across race, ethnicity, religion, sex, gender identity, sexual orientation, disability, political opinion, marital status, and union membership. Partners are required to prohibit commercial sex acts during contract performance and to follow ethical recruitment practices that ensure workers are never charged recruitment fees.
Workers must receive clear and accurate work agreements in a language they understand, have the ability to end their employment without financial penalty with reasonable notice, and be paid in accordance with applicable legal requirements or prevailing sector standards. All partners must respect workers’ rights to form and join trade unions, bargain collectively, and engage in peaceful assembly where permitted by law. Age‑verification processes must be in place to ensure all workers meet legal working‑age requirements.
We expect all suppliers and partners to uphold these principles and maintain safe, fair, and lawful working conditions.
Compliance
Armour Valve requires suppliers to:
- Provide their human rights and labor policies during onboarding
- Demonstrate compliance with applicable labor laws
- Participate in audits and assessments if requested
- Implement controls to prevent forced labor and child labor
- Notify Armour Valve immediately of any suspected violations
Suppliers must certify that materials incorporated into products supplied to Armour Valve comply with all applicable forced labor and child labor laws. Suppliers must flow down these requirements to their subcontractors and labor agents.
Our supplier approval process includes reviewing supplier policies, assessing compliance with labor standards, and verifying that appropriate controls are in place to prevent forced and child labor. We consider potential human rights risks when evaluating new suppliers and during periodic supplier reviews. Factors may include the nature of the goods supplied, supplier transparency, and compliance with applicable labor laws. These considerations support our commitment to maintaining ethical and responsible supply chain practices.
Armour Valve prohibits sourcing from regions or programs associated with forced labor risks, including the Xinjiang Uyghur Autonomous Region and any use of North Korean labor. We prioritize the use of ethical recruitment agencies certified by credible assurance agencies when recruitment services are required.
Due Diligence & Risk Assessment
Armour Valve conducts risk assessments across direct suppliers, indirect suppliers, labor agents, and recruitment channels to identify potential forced labor or child labor risks. We assess worker vulnerability, including migrant workers, temporary workers, and workers in high‑risk geographies. We monitor suppliers on an ongoing basis and update risk criteria based on emerging regulatory guidance and global supply chain developments. Armour Valve may engage independent third parties to support audits or risk assessments when appropriate.
Armour Valve also assesses risks within our own operations and labor supply chain to ensure compliance with this policy. We respond to identified risks on an ongoing basis and use these insights to drive continual improvement.
Remediation
In the event a supplier, vendor, or contractor is found to be in violation of this policy, Armour Valve will take prompt action to address the issue. Measures may include investigating the incident, pausing or suspending the business relationship, working with the organization to resolve the concern, engaging with affected workers to ensure their protection, and, if necessary, ending the business relationship. All actions taken will be documented and reviewed to ensure they are effective.
Remediation will prioritize the safety, well‑being, and rights of affected workers. Suppliers must cooperate fully with investigations and implement corrective actions. Armour Valve participates in or provides remedy when adverse human‑rights impacts occur within our supply chain.
Training & Awareness
Armour Valve does not provide formal reoccurring training related to forced labor or child labor. Instead, employees involved in procurement and quality assurance receive role‑appropriate awareness guidance to help them understand this policy, recognize basic indicators of forced labor and child labor, and escalate concerns within the supply chain.
Workers responsible for supply chain management and sourcing receive guidance on identifying and mitigating risks related to forced labor, child labor, and human trafficking.
Evaluating Policy Effectiveness
To ensure continuous improvement, Armour Valve will evaluate the effectiveness of this policy and its due diligence measures by:
- Reviewing reported incidents, remediation outcomes, and corrective actions taken.
- Updating supplier risk assessment criteria as part of our supplier approval and review process, in response to emerging regulatory guidance and global supply chain developments.
- We also review supplier certifications, audit results, and risk indicators to ensure ongoing compliance.
Reporting & Contact Information
Establishing supply chains free from forced labor and child labor is a shared effort, and we are committed to working with the necessary parties to make it a reality.
Workers, suppliers, and partners may report concerns without fear of retaliation. Armour Valve maintains internal accountability procedures to address violations by employees, contractors, or suppliers. We may publicly disclose information related to our human rights due diligence and policy effectiveness when required by law or requested by customers.
If you have questions about this policy or need to report a concern, please reach out to Armour Valve’s Operations & Quality Manager at bkarimpour@armourvalve.com.