Labor in Canadian Supply Chains Report

REPORT – BILL S-211 FORCED LABOR IN CANADIAN SUPPLY CHAINS

This report is intended to cover the operations of Full Swing Golf, Inc. (FSG) based in Carlsbad, California, USA and the entity it controls, Visual Sports System, Inc. (VSS) based in Concord, Ontario, Canada.  This is the first report filed on behalf of FSG and covers the fiscal year 2024.

FSG operates a business to design, manufacture, market and sell sports technology, including but not limited to hardware and software for sports simulators and portable golf launch monitors.  As part of this business, FSG has sourced and suppliers both domestic and global to fulfill the business needs.  The end product is sold and operated worldwide.

FSG has a variety of suppliers that produce finished goods for FSG or furnish materials that are inputs to other FSG suppliers.  This supply chain is global – FSG has domestic Tier 1 suppliers located in Canada and the USA, as well as international Tier 1 suppliers in Asia (Vietnam, Thailand and China).   All FSG Tier 1 suppliers have their own supply chains that extend further.

The major contract manufacturers used by FSG have undergone in-person supplier audits as well as ad-hoc site visits for business purposes that include a review of the production facilities.  The auditing and monitoring of major suppliers is accomplished through these in-person visits.  Scheduling of visits will vary as dictated by business needs.

FSG has a written policy to maintain the highest standards of workplace ethics, honesty and integrity in conducting its daily business. Individuals can report real or perceived serious wrongdoings under the umbrella of a “whistle blower” policy.  This includes suspected abuse, harassment or discrimination of anyone working at or visiting FSG, unlawful acts of any kind (whether criminal or civil) or violations of professional standards of care.

Individuals reporting issues are protected under the policy, which specifies FSG will not discharge, demote, suspend, threaten, harass, or in any other manner discriminate or retaliate against any team member for submitting a good faith complaint.

FSG also has a written policy addressing honest and ethical conduct. As part of the policy, all team members have a duty to FSG to always act ethically and with the highest degree of integrity and honesty. Competitive advantages or profits must not be sought through unlawful, dishonest or unethical business practices.

Operating with a global footprint, FSG has suppliers operating in highly competitive spaces which can be subject to financial pressures that may increase the risk of forced labor or child labor.  Suppliers in different geographic locations are working in different regulatory environments that may also modify this risk.  Tier 1 suppliers have their own global supply chains established that carry risk as well and FSG has limited visibility into those risks.

Part of the process used by FSG to manage its global supply chain is through in-person visits to select suppliers.  New policies are under development to ask selected suppliers to self-declare their own efforts in regards to forced labor or child labor and to adhere to a supplier code of conduct and ethics.  Before new suppliers to FSG are added to the internal ERP system that controls purchasing sources, the change must pass through a Change Control Board process which notifies the Director of Supply Chain to ensure visibility and awareness of changes to the FSG supply chain.

To date, FSG has not found any issues in its supply chain to require action or remediation, and as such no actions and/or remediation steps have been applicable to eliminate the use of forced labor or child labor in its activities and supply chains.

Although specific, directed training in regards to forced labor or child labor is not a part of FSG employee onboarding, many issues related to forced labor or child labor are integrated into the policies in place to address illegal and/or unethical conduct.