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Hyundai Supply Chains Act Report

 

Report Under the Fighting Against Forced Labour and Child Labour in Supply Chains Act

 

(For the fiscal year ending December 31, 2025)

 

 

Introduction

This report is submitted jointly on behalf of Hyundai Auto Canada Corp. ("HACC") and Hyundai Motor America ("HMA"), which wholly-owns HACC (collectively, "Hyundai"), in accordance with the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the "Act") for the fiscal year ending December 31, 2025.

Hyundai affirms its continued commitment to enforcing strict environmental, social, and governance standards throughout its supply chain, including to prevent and reduce the risk that forced labour or child labour is used at any step in Hyundai's supply chains.

Both HACC and HMA import and distribute vehicles and parts produced by affiliated and non-affiliated companies, including, their ultimate parent company, Hyundai Motor Company ("HMC") and other Hyundai affiliates. As importers of vehicles and parts with a limited number of sources for vehicles and vehicle parts, both HACC and HMA rely on the compliance mechanisms of their related party vendors to prevent and reduce the risk of forced labour and child labour in Hyundai's supply chains.

Structure, Activities and Supply Chains

HACC is an importer and distributor of Hyundai and Genesis-branded vehicles in Canada. HACC is headquartered in Markham, Ontario. It is wholly owned by HMA. HACC primarily distributes Hyundai-branded vehicles and parts through a network of independent dealerships across Canada. HACC sells Genesis-branded vehicles through a network of independent distributors across Canada. HACC does not design or manufacture any vehicles. HMA does not produce or manufacture any vehicles, only purchasing vehicles from Hyundai and Genesis factories.

HMA is headquartered in Fountain Valley, California. HMA imports, markets, and distributes Hyundai and Genesis-branded vehicles throughout the United States, through a network of independent dealers. HMA does not distribute or sell vehicles in Canada. HMA does not have an office or operations in Canada.

HACC and HMA are both subsidiaries of HMC, which is headquartered in Seoul, Republic of Korea ("South Korea").

Supply Chains

HACC purchases the vehicles and vehicle parts that it imports and sells in Canada through four supply chains:

 

  1. Vehicles manufactured by HMC in South Korea
  2. Vehicles manufactured by Hyundai Motor Manufacturing Alabama, LLC ("HMMA"), a wholly owned subsidiary of HMA
  3. Vehicles manufactured by KIA México, S.A. de C.V. ("Kia Mexico") manufactured in Mexico; and
  4. Vehicle parts sold by its supplier in Canada, Mobis Parts Canada Corp. ("Mobis Parts Canada") that are purchased primarily from Mobis Parts Canada's parent company in South Korea, Hyundai Mobis.

 

HMA has similar sources for the vehicles and vehicle parts it sells:

 

  1. Vehicles manufactured by HMC in South Korea
  2. Vehicles manufactured by HMMA
  3. Vehicles manufactured by Hyundai Motor Group Metaplant America, LLC ("HMGMA"); and
  4. After sale vehicle parts and replacement parts from Mobis Parts, America, LLC (“Mobis Parts America”).

Due to the role of Mobis Parts Canada, Mobis Parts America and Hyundai Mobis in the above-described supply chains, HACC and HMA obtained information from Mobis Parts Canada regarding the supply chain due diligence policies and procedures of the Mobis companies and provide this information in this report.

Policies and Due Diligence Processes

The supply chain due diligence policies and processes applicable to HACC, HMA, HMC, HMMA, Kia Mexico, HMGMA, and the Mobis companies are described in the below sections.

HACC's Operations

HACC Internal Policies

HACC has a number of internal policies that provide for safe working environments for its employees. This includes a "Health and Safety" policy that provides the requirements for safe workplace environments for HACC employees, an "Overtime Work" policy that sets guidelines on overtime work, an "Hours of Work" policy that offers flexible schedules for better work life balance, and a "Disconnecting from Work" policy to support wellness, and minimize excessive sources of stress.

HACC's "Business Ethics and Conflict of Interest Disclosure" policy defines the standards of conduct in relationships with all stakeholders with whom HACC does business. This policy applies to all HACC employees and requires that all employees comply with both the letter and spirit of all laws, regulations and legal requirements that apply where HACC operates. HACC employees are obligated to inform themselves of the abovementioned laws and requirements that are relevant to their particular position or activities.

HACC Supplier Due Diligence Practices

As set out in further detail below, HMC's Supplier Code of Conduct requires its suppliers to conduct specific due diligence and training to ensure they do not employ forced labour and child labour. The Supplier Code of Conduct applies to the suppliers of goods that HACC sources from HMC, HMA, HMMA, and Kia Mexico. The Supplier Code of Conduct must be adhered to by all existing and prospective Hyundai Suppliers and states that suppliers should:

(1) prohibit all forms of forced and child labour in their supply chains; and

(2) ensure that they do not produce or provide to Hyundai goods, products, or materials made, in whole or in part, with forced labour.

 

In regards to goods purchased from Mobis Parts Canada, HACC is aware that Hyundai Mobis has developed and applied an “ESG evaluation toolkit,” and through a third party auditor, conducted multiple audits of global manufacturing facilities, which focused on identifying and eliminating any risk of forced labour in its supply chains.

Through the implementation of supplier self-assessments, Hyundai Mobis identified certain Tier 1 suppliers were considered "high-risk" and conducted on site-assessments of all suppliers to ensure that forced labour and child labour was not present at these suppliers' sites.

HACC Ethics Complaint Procedure

HACC maintains a complaint procedure for business ethics violations which is set out in its Business Ethics Policy and Conflict of Interest Disclosure. A HACC employee that believes someone at the company is violating this policy is encouraged to discuss the matter with a supervisor or Director, HR and Administration, or General Counsel and if they still have concerns or do not feel comfortable discussing this issue with any of the above individuals, may contact HACC's third party ethics reporting hotline, "Integrity Counts" by phone, fax, email, anonymous web report, or written letter. While this reporting process is available to all employees, supervisors and managers are required to report suspected violations of this ethics policy to HACC's Director, HR and Administration.

HACC ensures that any reported complaint is investigated, and appropriate corrective action is taken. HACC is committed to ensuring that there is no retaliation against any employee who reports a suspected violation of law, ethical standards, safety concern or policy in good faith.

 

Risks of Forced Labour or Child Labour

Given the large number of components and inputs that go into a finished motor vehicle and the complexity of automotive global supply chains, there is a risk of forced labour and child labour within automotive supply chains. Both HMA and HACC purchase and source vehicles from international supply chains, and specifically from HMC. In 2025, HMC's suppliers were mostly located in Asia, with a significant percentage of suppliers located in Europe and in the Americas. HMC identifies and manages risks of forced labour and child labour in its supply chains by identifying the following factors and reviewing related information disclosed by government, research and media organizations:

 

  1. Country of supplier;
  2. Business type;
  3. Supplied part; and
  4. Raw or subsidiary material.

 

HMC uses a document-based assessment using an online evaluation system where suppliers respond to evaluation indicators by means of a self-diagnosis and submit documentary evidence. In 2025 HMC conducted document-based ESG assessments of all Tier 1 suppliers, key Tier 2 suppliers, as well as other non-parts suppliers. HMC selected certain of these suppliers for further on-site due diligence, using ESG consulting and due diligence experts to do so.

 

Where in the course of its compliance reviews and on-site audits HMC identified any non-conformities, it required that those suppliers develop CAPs, and HMC continuously monitors these suppliers post audit to ensure compliance.

 

As noted above, HMC, together with HMA, HMGMA, HMMA, Kia Mexico and Mobis, work as part of the Global Anti-Forced Labor Working Group to develop best practices regarding mitigation of forced labour and child labour risks in Hyundai's supply chains.

 

HMA, in conjunction with HMC, monitors emerging risks to its supply chain. This includes, but is not limited to, tracking reports and developments that could signal forced labour risks in the supply chain. For example, in 2025, HMC commissioned an independent third-party due diligence firm to conduct on-site audits of mines and smelters located in various countries in order to strengthen the company's risk management within the battery critical minerals supply chain. At the conclusion of these audits, HMC requested that the relevant suppliers establish corrective action plans. HMC continues to regularly monitor their implementation progress.

HMA, in conjunction with HMC, proactively addressed potential supply chain risks by working with HMMA, HMGMA, and Hyundai’s other suppliers to impose stronger contractual and due diligence requirements with their suppliers.

On November 13, 2025, Jobs to Move America (JMA) filed a lawsuit against HMA in the Superior Court of California, County of Los Angeles. The lawsuit alleges that HMA used "unconscionable" labour practices within their U.S. supply chain, including child labour and coerced prison labour. HMA disputes these claims and contends that they are without merit, but as that litigation has caused it to further review its supply chain processes, HMA notes the existence of this review activity for the purpose of this report.

Remediation Measures

Hyundai understands the importance of addressing any instances or allegations of forced labour or child labour involving itself, its parents and affiliates, or its suppliers, in order to remediate any issues and prevent their recurrence.

HACC, HMA, and their affiliates are constantly working to identify any new forced labour or child labour risks in their supply chains and have committed to undertaking remediation efforts when necessary.

 

Training

Hyundai companies have conducted multiple training sessions regarding their affiliates' obligations in regards to supply chain due diligence in 2025.

In 2025, HACC provided an internal update to its executive team, building on and refreshing the training provided in 2024.

In March 2025 HMC conducted supply chain due diligence training covering relevant supply chain regulations and compliance requirements for 182 participants from 132 of HMC's domestic and overseas suppliers. This training took place at the company's Global Supplier Day 2025 event, which HMC's Procurement Division hosted in Singapore. 

 

HMA educates and trains its stakeholders to recognize and address forced labour risks. In May 2025, HMA hosted the Hyundai Motor Global Anti-Forced Labor Working Group Live Meeting; a multi-day, in person training, conducted in collaboration with HMC, HMMA and other global Hyundai affiliates. The training was attended by legal and procurement representatives from major affiliates, including affiliated Korean suppliers based in North America, and supported by outside counsel. Training focused on best practices in risk assessment, supply chain mapping, supplier engagement strategies and remediation protocols. HMA and HMC also reviewed each participating company’s compliance programs, using key metrics and standards. This training was intended to raise awareness of the Act’s requirements and facilitate knowledge sharing to ensure that HMA and its partners are equipped to identify and mitigate potential forced labour issues in their supply chains.

 

Throughout 2025, HMA delivered regular updates to senior management on forced labour prevention and supply chain compliance. In late 2025, HMA reinforced internal awareness by delivering live, end-of-year compliance training to executives on supply chain compliance focusing on forced labour prevention. The training was recorded and is available to all HMA employees.

 

In November 2025, HMMA Legal & Compliance held its annual legal seminar for HMMA and HMMA's suppliers' team members, at which HMMA provided training on the subject of child labour and Intellicheck, with attorneys speaking on best employment practices. HMMA's outside counsel, which represents a significant number of HMMA suppliers, continued to provide legal training throughout the year, including training on child labour compliance.

In 2025, Hyundai Mobis conducted ESG compliance training for key personnel, including overseas subsidiary CEOs, expatriates, and affiliate staff. This training was delivered in English and Korean. Hyundai Mobis supports its suppliers by offering improvement support programs which help these companies address ESG risks and strengthen their compliance with ESG standards.

Mobis Parts Canada provided compliance training to employees in 2025 on topics including child and forced labour, anti-money laundering, anti-bribery, antitrust, fair trade, conflicts of interest, human rights policy and whistleblowing.

Assessing Effectiveness

The Hyundai group of companies assesses the effectiveness of its compliance measures intended to prevent, identify and eliminate the presence of forced labour and child labour in its supply chains in different ways. HMA worked with HMC to develop and launch HMC's new supply chain visualization system, a digital platform that improves visibility into sub-supplier relationships and risk indicators. Using the visualization system, HMA affiliates can better identify all suppliers, including indirect suppliers, that may pose a forced labour risk.  In 2025, HMMA and HMGMA conducted on-site audits of their suppliers, which resulted in improved governance practices related to forced labour and child labour prevention. Going forward, Hyundai intends to engage in further testing of its supply chains' compliance readiness.