Migrant workers are the backbone of the Canadian food system. In the agri-food sector, migrant workers are widely employed in crop production and food and beverage manufacturing. In 2017, one in five workers employed in crop production was a foreign worker. In Ontario, that same year, 41.6% of the agricultural workers were Temporary Foreign Workers. In 2020, half of all foreign workers in the sector were employed by meat product manufacturers, bakeries and tortilla manufacturers. Migrant workers in the Canadian agri-food sector face increasingly hazardous and precarious working conditions. The COVID-19 pandemic has only exacerbated the widespread abuse migrant workers in the food supply chain face, including: wage theft, racial profiling, inadequate housing, exploitation and discrimination. Migrant workers have also seen a dramatic and dangerous intensification in work. According to the Migrant Workers Alliance for Change, during the pandemic, many migrant workers in Canada reported “working for weeks without a day off, being forced to work long hours, and suffering increased strains, injuries and sickness due to increased pace of work.” In its 2020 Corporate Responsibility Report, Loblaw stated that it is: “principally committed to sourcing from Canadian suppliers and those who support a sustainable future.” Its Commitment to Human Rights and Supplier Code of Conduct obligates suppliers to uphold human rights within their operations. However, despite the severity of the human rights abuses alleged in the Canadian food supply chain, Loblaw does not provide clear explanations on how its policies and practices prevent and mitigate risks and harms to migrant workers employed by its suppliers. In addition, the Company’s disclosure falls short in demonstrating the effectiveness of these policies and practices through the disclosure of key meaningful metrics. The lack of transparency regarding migrant workers in Loblaw’s supply chain is concerning, as it may indicate that Loblaw underestimates serious human rights issues within its domestic supply chain. Loblaw’s failure to implement a robust human rights due diligence process to mitigate migrant workers harms and rights violations may represent material, reputational, sourcing, legal and regulatory risk. Therefore, to allow shareholders to perform their due diligence in accordance with their fiduciary duty, it is key for Loblaw to demonstrate a higher level of commitment and due diligence regarding migrant workers’ rights in its supply chain. An independent Assessment would help Loblaw identify any adverse impacts of its activities to 1) ensure the fundamental rights of migrant workers in its supply chain are respected and protected; 2) and ensure alignment of its existing policies and practices with the UN Guiding Principles on Business and Human Rights.