Introductory Section
Steps taken to prevent and reduce the risks of forced labour and child labour
Structure, activities, and supply chains
Policies and due diligence processes
Forced labour and child labour risks in our business operations and supply chains and steps taken to assess and manage these risks
Training
Assessing the effectiveness of our actions
Approval and Attestation
This report (“Report”) is made by Sephora Beauty Canada, Inc. (hereafter referred to as “Sephora Canada”) pursuant to the Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “Act”). This Report outlines the steps taken by Sephora Canada to prevent and reduce the risk that forced labour or child labour is used at any step of the production of goods, in Canada or elsewhere, or of goods imported into Canada by Sephora Canada for the financial year which ended December 31, 2024 (“Reporting Period”).
In general terms, Sephora Canada took the following steps during the Reporting Period to prevent and reduce the risk of forced labour or child labour in its business and supply chains:
continued to implement due diligence policies and processes for identifying, addressing and prohibiting the use of forced labour and/or child labour in the organization’s activities and supply chains;
continued to request that suppliers comply with policies and procedures for identifying and prohibiting the use of forced labour and/or child labour in their activities and supply chains;
included anti-forced labour and/or anti-child labour contractual clauses in supplier agreements;
implemented an updated and enhanced Supplier and Business Partner Code of Conduct (implemented and maintained by Sephora Canada’s parent company, LVMH), which strictly prohibits child labour, forced labour, human trafficking, and illegal, clandestine, and undeclared employment. This code is publicly available on LVMH’s website at https://www.lvmh.com/en/ethics-and-compliance/lvmh-supplier-code-of-conduct;
implemented an updated Employee Code of Conduct (implemented and maintain by Sephora Canada’s parent company, LVMH), which includes a “Respecting fundamental rights” section, outlining the Group’s commitment to “the fundamental principles, rights and freedoms adopted by the international community, and in particular the Universal Declaration of Human Rights, the International Covenants on Civil and Political Rights and on Economic, Social, and Culture Rights, the United Nations Guiding Principles on Business and Human Rights, the fundamental conventions of the International Labor Organization, and the OECD’s Guidelines for Multinational Enterprises, especially Chapter IV.” This code is also publicly available on LVMH’s website at https://www.lvmh.com/en/ethics-and-compliance/the-lvmh-code-of-conduct; and
prepared a Modern Slavery Awareness training module in late 2024; and
trained all employees responsible for purchasing in Sephora Canada in early 2025.
Details of these actions are set out further in the following sections of this Report.
Structure
Sephora Canada, incorporated pursuant to the Canada Business Corporations Act in 2004, is a wholly owned subsidiary of Louis Vuitton Moet Hennesey, Inc., based in New York, NY in the United States of America. Sephora Canada maintains one corporate office in Toronto, Canada. The corporate office’s primary function is to provide support and guidance to its retail locations. Overall, Sephora Canada employs approximately 4,800 employees in Canada.
Sephora Canada does not own or control any entities (meaning it does not have any subsidiaries).
Activities
As of the date of this filing, Sephora Canada operates 138 beauty retail stores across Canada. Sephora Canada sells make-up, skincare, fragrance, haircare and other beauty related products, tools and accessories to retail customers and consumers in Canada. Sephora Canada also maintains an online presence and customers can buy products directly from its website.
Supply Chains
Sephora Canada works with a variety of suppliers of goods and services who work in countries around the world. Its products are sourced mostly from France and the United States which have minimum wage requirements and various worker protection laws in effect.
Policies
Sephora Canada is committed to acting with integrity in all its business dealings and to promoting ethical conduct, compliance with applicable laws, and providing guidance to its employees with respect to appropriate and ethical business conduct. Sephora Canada incorporates several policies that are relevant to this commitment, which set out what Sephora Canada expects from both its internal business stakeholders and its external suppliers. Relevant policies include:
LVMH’s Employee Code of Conduct
The LVMH Employee Code of Conduct (“LVMH Code of Conduct”) outlines the values and principles that is designed to guide the actions and decisions of all employees working for LVMH or any of its subsidiaries, including Sephora Canada. The LVMH Code of Conduct covers topics such as respect for human rights, diversity and inclusion, environmental responsibility, business ethics, data protection, and compliance with laws and regulations. It further explains how employees can raise concerns or report violations of the LVMH Code of Conduct through various channels, including an anonymous hotline. The LVMH Code of Conduct also outlines the Group’s commitment to the fundamental principles, rights and freedoms adopted by the international community, and in particular the Universal Declaration of Human Rights, the International Covenants on Civil and Political Rights and on Economic, Social, and Culture Rights, the United Nations Guiding Principles on Business and Human Rights, the fundamental conventions of the International Labor Organization, and the OECD’s Guidelines for Multinational Enterprises, especially Chapter IV.
As part of this code, employees are made aware of LVMH’s confidential reporting hotline (the “Alert Line”), an online interface that provides a fully confidential and secure way of reporting in good faith violations of laws, regulations, or internal principles of conduct.
LVMH’s Supplier and Business Partner Code of Conduct
The LVMH Supplier Code of Conduct (“LVMH Supplier Code”) defines the standards and expectations that LVMH and its subsidiaries, including Sephora Canada, have for their suppliers and business partners in terms of social, environmental, corporate, and ethical responsibility. The LVMH Supplier Code covers topics such as labour rights, health and safety, environmental protection, anti-corruption, fair competition, and data privacy. The LVMH Supplier Code sets out several labour standards and social responsibilities with which it expects its suppliers to comply. These include the prohibition of child labour, forced labour, illegal, clandestine, and undeclared employment, harassment and abuse and discrimination. Suppliers are also expected to guarantee the payment of at least minimum wages, comply with legal requirements around working hours, respect freedom of association, and provide a safe and healthy workplace environment. The LVMH Supplier Code also details our expectation that our suppliers will comply with all applicable laws and regulations, as well as to adhere to the principles of the United Nations Global Compact and the Universal Declaration of Human Rights.
Sephora Canada puts suppliers on notice that if it becomes aware of any breach of the LVMH Supplier Code, Sephora Canada reserves the right to audit the supplier, to implement remedial steps to address and rectify the concerns, and/or to terminate its relationship with that supplier. Additionally, the LVMH Supplier Code notifies suppliers and business partners that they have access to the LVMH Alert Line, an online reporting hotline that provides a fully confidential and secure way of reporting violations of the laws, regulations, or internal principles of conduct. When submitting a report, an individual can choose whether to remain anonymous. The LVMH Alert Line is made available to suppliers at onboarding and information about the Alert Line is included on LVMH’s public-facing website at https://www.lvmh.com/lvmh-alert-line/.
Due Diligence Processes
Prior to engaging any new contractual relationship with a supplier, Sephora Canada’s process is to provide each new supplier with a copy of the LVMH Supplier Code and sets out our expectation that each supplier will agree not to use forced labour and/or child labour.
In addition, Sephora Canada’s supplier template contracts are expected to include clauses informing suppliers of the LVMH Supplier Code and Sephora Canada’s expectation that the suppliers will comply with the LVMH Supplier Code. Sephora Canada’s expectations of compliance from its suppliers include, but are not limited to, suppliers adopting similar anti-slavery standards and practices. Sephora Canada also runs periodic checks to identify whether any of its suppliers are listed on an international sanctions list.
Sephora Canada reserves the right to evaluate its supplier’s adherence to the principles set out in the LVMH Supplier Code and to conduct compliance audits at any time without notice. Accordingly, as part of our supplier relationships, our suppliers understand that Sephora Canada expects:
that they will keep proper records to demonstrate their compliance with the LVMH Supplier Code, including complete, original, and accurate files (“Records”);
that upon reasonable request, they will be expected to supply the necessary information, including the Records, to a representative of Sephora Canada; and
that they will grant access to representatives of Sephora Canada to evaluate compliance with the requirements of the LVMH Supplier Code.
Upon reasonable request, suppliers must improve and correct any deficiency discovered during any such audits.
Forced labour and child labour risks in our Canadian business operations
Given that the entirety of Sephora Canada’s workforce is employed or contracted in Canada, we consider the risk of forced labour or child labour to be low in our direct operations. In addition, Sephora Canada’s Human Resources team verifies that new employees are legally authorized to work in Canada. As a general practice, Sephora Canada does not hire any employees under the age of 18. To promote compliance with this general practice, the Human Resources team has enacted processes to confirm that our employees are over the age of 18 and legally authorized to work in Canada.
Forced labour and child labour risks in our supply chains
As Sephora Canada procures many goods and services from a wide range of domestic and international suppliers, we acknowledge that there is a risk that forced labour and/or child labour may be used in our extended supply chains. However, we make it well known to our vendors and suppliers that such practices are strictly prohibited by Sephora Canada.
As Sephora Canada has not identified any instances of forced labour or child labour in its business or supply chains in the Reporting Period, it has not had to take any measures to remediate any forced labour or child labour or to remediate any loss of income to vulnerable families resulting from measures taken to eliminate the use of forced labour or child labour in our activities or supply chains.
Sephora Canada utilizes the processes and policies as described in this Report to assess and manage these risks.
Notwithstanding the above, Sephora Canada is committed to investigating reports of potential incidences of forced labour and/or child labour occurring anywhere in its operations or supply chains. Our processes include taking all appropriate steps to rectify any confirmed incidences of forced labour or child labour in our operations or supply chains. This is designed to be a collaborative process where Sephora Canada works with its suppliers and, if necessary, their suppliers, to remediate the issue. If, for any reason, an acceptable resolution was not possible, Sephora Canada’s process includes steps, as indicated above, up to and including severing its connections with the offending supplier or sub-supplier.
Sephora Canada employees, whether they work in retail stores or at the corporate office, receive periodic trainings regarding anti-corruption, the company’s anonymous reporting hotline, and Sephora Canada’s commitment to ethical behaviour including its fight against forced labour and child labour.
Additionally, in 2024, Sephora Canada created a training for all individuals involved in Canadian purchasing decisions. This training was conducted in January 2025, and included members of the Canadian Purchasing team, Supply Chain team, and several Canadian executives and members of Sephora’s Global Legal team from France.
Sephora Canada's aim is to eliminate any risk of forced labour and child labour in its business operations and in its supply chains.
Sephora Canada recognizes that in order to identify and address the risks of forced labour and child labour in our operations and throughout our supply chains, we must continually analyse and evaluate our actions. Sephora Canada is committed to advancing this process. Accordingly, as we continue to evaluate Sephora Canada’s compliance measures that are designed to prevent and reduce the risk of forced and child labour, we intend to consider, where appropriate, implementing measures to assess the effectiveness of any of our processes used to identify and address the risks of forced labour and child labour in our supply chains and operations.
This Report was approved by the Board of Directors of Sephora Beauty Canada, Inc. for the financial year which ended December 31, 2024, pursuant to paragraph 11(4)(a) of the Act.
President and CEO
Sephora Beauty Canada, Inc. and Sephora North America
I have authority to bind Sephora Beauty Canada, Inc.
