Ballard Power : 2024 Forced Labour and Child Labour in the Supply Chains Act Report
BLDP.TO
Published on 06/03/2025 at 15:03
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Introduction
This Modern Slavery Act Report (the "Report") has been prepared pursuant to Section 11 of the Fighting Against Forced Labour and Child Labour in Supply Chains Act, S.C. 2023, c.9 (the "Act"). This Report provides transparency on the continued efforts being taken by Ballard Power Systems Inc. (herein referred to as "Ballard", the "Company", "we", "us", or "our") to prevent and reduce the risk that forced labour or child labour is used at any step of the production of goods into Canada or the import of goods into Canada, for the financial year ending December 31, 2024.
This Report has been prepared by the management of Ballard and approved by Ballard's Board of Directors.
Ballard is a public corporation (NASDAQ: BLDP; TSX: BLDP) listed on the Nasdaq Stock Market ("NASDAQ") and on the Toronto Stock Exchange ("TSX"). At this time, we do not currently have mandatory reporting obligations related to modern slavery in any other jurisdictions and are not filing a joint report.
In March 2023, Ballard became a signatory to the United Nations Global Compact ("UNGC"), reflecting our commitment to align our corporate strategy and business practices with the UNGC's Ten Principles on human rights, labour, environment, and anti-corruption. As part of our UNGC commitment, Ballard will submit a Communication on Progress (CoP), to the UNGC, outlining our status and ongoing activities.
Our Structure, Activities, and Supply Chain Business Structure
Ballard is primarily engaged in the design, development, manufacture, sale, and servicing of Proton Exchange Membrane ("PEM") fuel cell products. These products are used in various applications, with a core focus on heavy-duty motive markets including buses, trucks, rail, and marine, as well as material handling and stationary power generation. In addition, Ballard provides technology solutions such as engineering services, product and systems integration, and technology transfer for diverse PEM fuel cell applications.
Ballard's supply chain and procurement activities form part of its global operations function, which is overseen by the Senior Vice President and Chief Operating Officer. The Company's workforce and human capital management are the responsibility of the Senior Vice President and Chief People Officer. These organizational roles are key to supporting compliance with ethical sourcing standards, including the prevention of forced and child labour.
The Board of Directors provides overall risk oversight, including human rights-related risks. Oversight of risks specifically associated with modern slavery, forced labour and child labour falls within the mandate of the Board's Sustainability and Governance Committee ("SGC").
As of December 31, 2024, Ballard employed 708 individuals in Canada plus 129 employees in international locations.1The Company aims to uphold human rights across its operations and supply chains, and regularly reviews its policies, procedures, and supplier relationships to support alignment with the objectives of ethical practices, as well as the principles of the UNGC and Bill S-211.
Ballard engages in the development, importation, manufacturing, assembly, testing, sale, distribution, and aftermarket servicing of PEM fuel cell products and their components. These activities are supported by a global procurement network that sources both direct and indirect materials and services.
1In line with Canadian common law, employees include people employed on a full-time, part-time, or temporary basis in Canada or in any other jurisdiction, and do not include independent contractors.
Direct materials and services are those procured for the development, production, assembly, and sale of Ballard's core fuel cell products. These procurement activities are centrally managed within the global operations function by a centralized procurement team, which oversees purchases made in Canada and with international suppliers.
Indirect materials and services, which support corporate functions such as information technology, finance and administration, and marketing are managed within each of Ballard's individual functional groups and are coordinated with dedicated purchasing support. Further information on policies and procedures related to responsible sourcing and human rights due diligence can be found in section 3 of this Report.
Ballard's direct material inputs are used to manufacture products across three primary categories:
These products rely on a range of components, including electronic boards, valves, heating elements, graphite sheets, catalysts, connectors, and other hardware sourced from a wide array of commercial suppliers. Ballard functions as a downstream company, as defined by the Organization for Economic Co-operation and Development Due Diligence Guidance. As such, Ballard typically does not procure raw materials directly but instead relies on complex supply chains involving multiple intermediaries between component manufacturers and raw material sources.
The raw materials most commonly used in Ballard's upstream supply chain include steel, magnesium, plastic, and electronic modules. Indirect materials and services primarily include those necessary for equipment operation, maintenance and repair, as well as IT services, hardware and software procurement, office management, and professional consulting services.
Ballard continues to work toward identifying and addressing risks of forced and child labour within its supply chains and is taking steps to improve supplier engagement and oversight practices.
Our supply chain flow, displayed in figure 1, consists of three primary segments supporting the procurement of direct or indirect materials, services, or employment.
Figure 1: Ballard's Supply Chain Flow
During 2024, Ballard's supply base for direct materials and services included an estimated 585 active and approved suppliers providing a range of goods and services located in the following regions:
Region
# of Suppliers
% of Total Spend
Canada
333
31%
Europe
48
26%
Asia
52
25%
USA
152
18%
Our Policies and Due Diligence Processes
Ballard has implemented a comprehensive set of policies and procedures that clearly define expectations for all employees, contractors, and third parties acting on the Company's behalf. These frameworks are designed to ensure that all business activities are conducted ethically, responsibly, and in full compliance with applicable laws and regulations.2These policies and systems include:
2Where no link has been provided, such policies and procedures are made available to the Company's employees on an internal intranet site.
Ballard has established due diligence policies and procedures that set clear expectations for the recruitment of all employees, whether permanent or temporary. These policies are intended to promote fair, transparent, and ethical hiring practices and to help prevent the use of forced, child, or exploitative labour at any stage of the recruitment process. These include:
Ballard has a set of established due diligence policies and procedures that outline our expectations of our suppliers and those advising, working, or producing on behalf of Ballard. These include:
Disclaimer
Ballard Power Systems Inc. published this content on June 03, 2025, and is solely responsible for the information contained herein. Distributed via Public Technologies (PUBT), unedited and unaltered, on June 03, 2025 at 19:02 UTC.