Supply Chains Act

Introduction

This report has been prepared by Metrolinx in accordance with the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Act) to outline the steps taken during the 2024– 25 fiscal year to address the risks of forced and child labour in its supply chain.

Metrolinx remains committed to ensuring its procurement practices and supply chains are free from forced and child labour, and that suppliers uphold internationally recognized human rights standards. This report provides an overview of Metrolinx’s organizational structure, supply chains, policies, risk assessments, and continued efforts to address and mitigate these risks.

Structure and Activities

Metrolinx is an agency of the Government of Ontario with a legislated mandate to lead the planning, coordination, development, financing, implementation, and delivery of new transit infrastructure to the Greater Toronto and Hamilton Area, in alignment with provincial growth and transportation policies.

Metrolinx delivers regional transit services through three service brands:

• GO Transit, providing regional rail and bus services;
• UP Express, offering direct service between Toronto Pearson International Airport and downtown Toronto; and
• PRESTO, an electronic fare payment system used by 11 local transit agencies.

Supply Chains

Metrolinx continues to engage in a wide range of procurements, including for vehicles, infrastructure components, and professional services. The majority of suppliers are Ontario-based, with a limited share from other provinces and international sources.

In the fiscal year 2024–25, Metrolinx’s supply chain expenditures included:

• Construction: Rail track materials, construction services, and facility maintenance.
• Transportation and Logistics: Railcars, buses, and parts for maintenance.
• Professional Services: Consulting, engineering, legal, and project management.
• IT & Telecom: Digital infrastructure, cybersecurity solutions, and fare collection systems.
• Office Management: Promotional merchandise and printed materials.

Low-Risk Sourcing Practices

Metrolinx’s reliance on Canadian suppliers contributes to a low-risk profile for forced and child labour. International suppliers primarily operate from jurisdictions with strong labour and human rights protections, including the United States and countries within Western Europe. During fiscal year 2024–25, less than 0.1% of procurement activities involved higher-risk industry sectors.

Policies and Due Diligence Processes

Procurement Policy

Metrolinx’s Procurement Policy ensures ethical, transparent, and consistent practices in acquiring goods and services.

Vendor Code of Conduct

This Code outlines expectations of Metrolinx’s suppliers related to ethical labour practices, sustainability, and integrity. It explicitly prohibits the use of forced labour, human trafficking, or child labour. Compliance with the Code is required throughout all tiers of a supplier’s operations.

Risk Assessment and Identification

Metrolinx maintains a full Enterprise Risk Management (ERM) Policy and framework to ensure robust processes for risk identification, mitigation, monitoring and reporting at all levels up to and including Senior Management and the Board. The ERM Policy is based on the Committee of Sponsoring Organizations of the Treadway Commission (COSO) ERM Integrated Framework 2017 and International Organization for Standardization (ISO) 31000.

In 2024–25, Metrolinx spent $7.6 billion on goods and services. Risk identification focused on two main indicators:

• Country of Origin: Suppliers from regions with elevated risks of forced or child labour were subject to further review.
• Industry Sector: Industries with historically high exposure to labour abuses, such as textile and raw materials, were flagged.

Third-Party Resources and Tools

Metrolinx used several respected external resources to inform its assessments, including:

• Walk Free Foundation’s Global Slavery Index
• U.S. Department of State’s Responsible Sourcing Tool
• U.S. Department of Labor’s List of Goods Produced by Child Labor or Forced Labor

This assessment identified a small number of lower-value procurement activities (under 0.1%) as potentially carrying elevated risks, particularly in promotional items linked to global textile supply chains.

Contractual Obligations

Metrolinx continues to require suppliers to acknowledge and adhere to the Vendor Code of Conduct in contractual agreements. These agreements grant Metrolinx the right to terminate contracts should suppliers be found in violation of human rights standards.

Addressing Forced or Child Labour Incidents

If forced or child labour is identified in Metrolinx’s supply chain, the organization is committed to taking immediate, appropriate action, including:

• Collaborating with the supplier to develop and implement a corrective action plan.
• Terminating contracts where compliance is not achieved.
• Engaging with Non-Government organizations or authorities to support affected workers and ensure their rights are protected.

Preventing Income Loss for Vulnerable Workers

Recognizing the risks of unintended harm to vulnerable workers, Metrolinx takes a remediationfocused approach. As part of its remediation measures, Metrolinx seeks to minimize the negative impact on workers by collaborating with suppliers to transition affected workers to more ethical employment.

Steps Taken

Training

Metrolinx has started to develop training materials to reflect the Act, emerging trends in forced and child labour risks, and best practices in avoiding potential high-risk suppliers.

Consolidated Purchasing

After conducting a competitive procurement process, Metrolinx awarded its promotional materials business to a new provider, where sustainable sourcing was a key element in evaluating bids. The contract will come into effect in the 2025-26 fiscal year.

Forward-Looking Statement

Metrolinx continues to strengthen its response to forced and child labour risks. For the 2025–26 fiscal year, the organization plans to:

• Enhance training: Expand and update procurement staff training to reflect the latest legal obligations, risk trends, and mitigation best practices.
• Streamline sourcing: Consolidate suppliers for certain merchandise categories to improve oversight and reduce exposure to high-risk sectors.

Metrolinx remains firmly committed to advancing human rights across its supply chains and will continue to evolve its practices in line with global standards and regulatory requirements.

Attestation

In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for Metrolinx. 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 period listed above.

Signature:

I have the authority to bind Metrolinx.

Full Name: Nick Simone

Title: Metrolinx Board Chair

Date: