Well.ca's Statement on the Prevention
of Modern Slavery and Forced Labour
Introduction
This report has been prepared by BH Water HoldCo Ltd. DBA Well.ca ("Well.ca") in accordance with Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act (the "Act") for our financial year ending March 31st, 2026.
Well.ca has met the asset and revenue-related thresholds of the Canadian Act for the two most recent financial years. As such, Well.ca qualifies as an "entity" under the Canadian Act. This is the second year of Well.ca submitting this report under the new legal entity name of BH Water Holdco Ltd. DBA Well.ca.
Well.ca has always been and continues to be committed to curating a selection of environmentally conscience products, making it easy for our customers to make choices that align with their sustainable goals, a healthier planet and a greener future.
Our Structure and Operations
Well.ca is a Canadian e-commerce retailer based in Guelph, Ontario that specializes in health, beauty, baby, home, and green and natural products.
Beginning as an online pharmacy, and as one of the first Canadian online retailers, Well.ca was born in 2008 out of a vision to bring wellness to every Canadian's home.
Well.ca carries over 40,000 products from 2800 brands across a variety of suppliers. Well.ca employs approximately 306 individuals in Guelph and Toronto, Ontario, and Calgary, Alberta. We occasionally hire contractors and temporary workers from reputable employment and recruitment agencies.
Today, we continue to be the online destination our customers can count on for everything from trending products and emerging brands to their wellness essentials. And we hope to continue to empower our customers to make choices that align with their own values and goals with ease.
We've always been committed to finding amazing, local brands that we know our customers will love and making them accessible to all of Canada. Today, we still apply that same principle, building and fostering relationships with local artisans, entrepreneurs and more to bring our customers the very best of Canadian innovation.
Our Mission and Values
Our mission is to offer a one-stop destination where our customers can find better-for-you everyday essentials and discover Canada's newest wellness brands and coveted products. We strive to provide our customers with choice, dependability, and ease every time they visit.
Our customers are at the heart of everything we do at Well.ca; they can rest assured that when they need help with an order, guidance on a choice or an opinion on a product, they'll be speaking with one of our local customer care team members - who know our business, our brand and are as excited as our customers about our products.
From our humble beginnings to who we are today, our team is a collection of passionate individuals who have their hands in every aspect of our business. From our product buyers to the person signing their name on our customers' next delivery, we believe in the power and delight of a curated shopping experience.
Risks of Forced Labour and Child Labour in Well.ca's Operations and Supply Chains
Our People Risk
At Well.ca, our people are essential to deliver on our purpose and value promise to our customers. The overall risk that our operations may cause or contribute to modern slavery is minimal, given that our workforce is comprised of skilled and experienced Canadian workers. Our commitment to provide a safe, fair, and respectful working environment and our wide range of human resources policies and procedures support the protection of human rights.
We have an all-encompassing document set of policies, including policies regarding diversity, discrimination, harassment, and health and safety. These policies are contained within our online employee portal. Our employees are required to acknowledge these policies at the time they are onboarded as well as when there are any changes made to a particular policy. Well.ca employees are encouraged to report any violations of our policies directly to our Human Resources Team.
Well.ca has not identified any risks of forced or child labour in our activities or operations.
Our Supply Chain
Well.ca purchases finished goods for resale from both Canadian and US suppliers. Well.ca is committed to monitoring the social and ethical standards of our supply chain. Through our vendor relationships and contractual terms, we require our suppliers to hold their own contractors and suppliers to the same standards.
Well.ca carries many Natural Health Products and food products which are regulated in Canada under the Food and Drugs Act and Natural Health Products Regulation. Health Canada, the Natural and Non-Prescription Health Products Directorate (NNHPD) and the Canadian Food Inspection Agency (CFIA) play an active role in ensuring product efficacy, safety, and quality.
Well.ca anticipates that the new Canadian reporting requirements under the Act will lead to greater transparency in Canada's supply chain. As new information becomes available, we have continued to assess our policies and processes and engage with our suppliers to prevent and assess the use of forced labour and child labour. During the reporting period, Well.ca updated its vendor agreements to include provisions requiring suppliers to confirm compliance with applicable forced labour laws and standards. Failure to comply with these requirements may result in termination of vendor relationships.
As part of our ongoing review, Well.ca recognizes that potential risks of forced labour and child labour may exist within global supply chains, particularly in certain product categories or regions where goods are manufactured outside of Canada and the United States. While we have not identified specific instances of forced or child labour within our supply chain, we continue to evolve our approach to better understand and assess potential risk areas.
Progress Since Last Report
Since our initial report, Well.ca has taken the following steps to strengthen our approach to addressing risks of forced labour and child labour:
- Updated vendor agreements to include forced labour compliance provisions
- Continued internal review of supplier practices and expectations
- Advanced development of training programs for key internal stakeholders, including buying and vendor management teams
Steps to prevent and reduce risks of forced labour and child labour
Well.ca continues to evolve our practices as they relate to modern slavery and human rights. We will continue to monitor our supply chain in relation to forced labour and human trafficking through regular reviews of our own suppliers and vendors.
Well.ca takes social responsibility seriously and is strongly committed to respecting applicable international human rights and fair labour practices and explicitly condemns all kinds of modern slavery, including forced or child labour, and human trafficking.
As part of this commitment, Well.ca is working to strengthen its supplier governance practices and integrate modern slavery considerations into vendor management processes over time.
Training
Well.ca prioritizes health and safety for our employees and has provided training on our compliance standards and identifying hazards and indicators of unsafe working conditions. During the reporting period, Well.ca advanced the development of targeted training materials addressing the risks of forced labour and child labour in our supply chains and our obligations under the Act. These training programs are intended for key teams, including senior leadership, buying, and vendor management, and will be implemented on issues relating to forced labour, child labour, and the business' obligations under the Act.
Our buying team understands the importance of keeping forced labour at the forefront of the relationship between Well.ca and our vendors. Well.ca expects to roll out formal training programs during the next reporting period to our buying teams on our obligations and responsibilities to mitigate modern slavery risk in our businesses and supply chains as well as plans to implement responsible sourcing policies at Well.ca.
Remediation Measures
Given that Well.ca has not identified any instances of child or forced labour in our own supply chains and operations, no steps have been taken to eliminate the use of forced or child labour. As such, Well.ca has not identified any loss of income to the most vulnerable families resulting from any measures taken to eliminate the use of child or forced labour.
Well.ca will continue to map and monitor our supply chains to further build out our processes and procedures. We will continue to review and update our vendor agreements and practices to ensure that all vendors and suppliers are operating to the standards of the Act and the expectations of Well.ca.