2024 Forced Labour & Child Labour Report
Part I: VitalAire Canada Inc. (“VitalAire”)’s Activities
VitalAire is incorporated under the laws of New Brunswick and is part of the Air Liquide group of companies (“Air Liquide Group”). It is a subsidiary of Air Liquide Canada Inc. (“Air Liquide Canada”).
VitalAire operates home oxygen, pulmonary health, respiratory health, and sleep medicine businesses. As part of those businesses, VitalAire (1) distributes cylinder gases produced by Air Liquide Canada in compressed or in liquid form; (2) imports and distributes medical devices and associated devices, parts, or equipment; (3) contracts with or employs healthcare professionals such as registered respiratory therapists and others.
Medical devices and associated devices, parts, or equipment VitalAire distributes are mostly imported by VitalAire from the United States or the European Union from suppliers based there, but the goods may originate from all across the world. The European Union and the United States both have robust laws in place that prevent the importation from elsewhere of goods made from forced labour or child labour.
Part II: Policies & HR
Supplier Code of Conduct
VitalAire is part of the Air Liquide Group, which has in place a Supplier Code of Conduct (https://www.airliquide.com/sites/airliquide.com/files/2023-09/en-air-li…) to which suppliers may be required to adhere. Sections 3 and 4 of the Supplier Code of Conduct require external suppliers to be compliant with Air Liquide principles in human, social and labour rights. Whenever possible, VitalAire uses Air Liquide Canada master purchasing agreements to make purchases for goods, and those master purchasing agreements of Air Liquide Canada almost always reference the Supplier Code of Conduct of the Air Liquide Group.
Code of Conduct
VitalAire has in place a Code of Conduct. The Code of Conduct applicable to all employees requires employees in their areas of responsibility to protect human rights, which includes, among others, health, security and safety, non-discrimination, freedom of opinion, expression and association, working under decent and fair conditions, and the prohibition of child labour or and any form of modern slavery. As part of their onboarding with VitalAire, all employees must complete Code of Conduct training. Furthermore, there is annual mandatory training addressing various selected topics in the Code of Conduct.
HR
VitalAire has a strong human resources (“HR”) team in place to ensure compliance with applicable employment and labour laws in Canada, and to the extent VitalAire has students under the age of 18, the HR team will ensure that work hours are conducive for their concurrent educational pursuit.
Part III: Supply Chain
Due Diligence
VitalAire’s direct suppliers of goods are situated in Canada, the United States or the European Union. VitalAire uses Air Liquide Canada master purchasing agreements whenever possible.
Risk Identification
It is extremely unlikely that any internal VitalAire activities in Canada involve any form of forced labour or child labour.
It is unlikely that medical devices and associated devices, parts, or equipment imported by VitalAire are manufactured or produced or handled by forced labour or child labour.
Part IV: Conclusion
Measures taken by VitalAire, notably in using Air Liquide Canada master purchasing agreements or dealing mostly only with suppliers in Canada, United States or Europe allow VitalAire to more easily manage the supply chain and ensure the quality of VitalAire products. In VitalAire’s opinion, measures undertaken by VitalAire should be effective to filter out forced labour and child labour in VitalAire’s supply chain. It is further VitalAire’s belief that our Code of Conduct and our robust HR team ensures that VitalAire’s internal activities should not be subject to child labour or forced labour. That being said, VitalAire is in the view that there is no objective mechanism to assess effectiveness of measures, and as such the effectiveness is not assessed.
As measures undertaken by VitalAire are specifically targeted, they minimize potential impact on vulnerable families that may result from contract termination. As such, no specific remediation measures are taken to address the loss of income for vulnerable families caused by any measures to eliminate the use of forced or child labour.