statement_id,sentence_orig_idxs,sentence,Approval,Signature,C1 (reporting entity),C2 (structure),C2 (operations),C2 (supply chains),C3 (risk description),C4 (risk mitigation),C4 (remediation),C5 (effectiveness),C6 (consultation)
SID_201,82,"2023 Supply Chain Act Annual Report This Annual Report (the Report) is produced in accordance with section 11(1) of the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Supply Chains Act or the Act) and is filed for the following entities, each a member of the Burnbrae Farms corporate group (Burnbrae Farms)",0,0,0,1,0,0,0,0,0,0,0
SID_201,83,Burnbrae Farms Limited,0,0,0,1,0,0,0,0,0,0,0
SID_201,84,Ferme St-Zotique Ltée; and,0,0,0,1,0,0,0,0,0,0,0
SID_201,85,"Burnbrae FarmCo 19 Inc, (each a Reporting Entity and collectively, the Reporting Entities, we, us or our) covering the twelve-month financial year ended August 31st, 2023 (the Reporting Period)",0,0,0,1,0,0,0,0,0,0,0
SID_201,86,"Burnbrae Farms has embraced sustainability practices over the years to ensure the long-term success of our business, our employees, our suppliers and other various stakeholders",0,0,0,0,0,0,0,0,0,0,0
SID_201,87,"At its core, sustainability is about both the environment and human rights",0,0,0,0,0,0,0,0,0,0,0
SID_201,88,Forced labour and child labour are contrary to human rights and against our vision and values,0,0,0,0,0,0,0,0,0,0,0
SID_201,89,At Burnbrae Farms one of our values centres around Leading Responsibly which entails abiding by our Code of Conduct as well as our other policies,0,0,0,0,0,0,0,0,0,0,0
SID_201,90,"It is also contrary to one of our five key areas of sustainability focus, namely the health and wellbeing of our employees and by extension the health and wellbeing of people employed by our suppliers",0,0,0,0,0,0,0,0,0,0,0
SID_201,91,This report constitutes our first report under the Act and provides a summary of our objectives and progress in regards to the elimination of forced labour and child labour in our supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_201,92,"Our structure, operations and supply chain Burnbrae Farms is a sixth-generation, Canadian familyowned and operated company",0,0,0,0,0,0,0,0,0,0,0
SID_201,93,"We offer world-class products such as shell eggs, hard-boiled and liquid eggs, and fully cooked omelets and patties",0,0,0,0,1,0,0,0,0,0,0
SID_201,94,"Burnbrae Farms is committed to providing Canadians from coast to coast with safe, affordable, accessible, nutritious eggs and egg products",0,0,0,0,1,0,0,0,0,0,0
SID_201,95,"We market to retail, industrial, and food service clients across Canada and select US and international markets",0,0,0,0,1,0,0,0,0,0,0
SID_201,96,"Burnbrae Farms produces, grades and processes its products only in Canada, where it employs over 1,700 people and partners with over 400 farmers",0,0,0,1,1,0,0,0,0,0,0
SID_201,97,"Burnbrae Farms operates five farms, eight grading facilities and three processing plants located in Quebec, Ontario, Manitoba, Alberta and British-Columbia",0,0,0,1,1,0,0,0,0,0,0
SID_201,98,"The Reporting Entities are either producing goods in Canada, selling goods in Canada or into the United States, distributing goods in Canada or abroad, or importing into Canada goods produced outside of Canada",0,0,0,1,1,0,0,0,0,0,0
SID_201,99,"All Reporting Entities are wholly-owned subsidiaries of holdings corporations, themselves held by the Hudson family trust",0,0,0,1,0,0,0,0,0,0,0
SID_201,100,"The Hudson family established the original Burnbrae Farm in Lyn, Ontario in 1891 and still owns and operates Burnbrae Farms",0,0,0,1,0,0,0,0,0,0,0
SID_201,101,"In Canada, the Reporting Entity operates many prominent and valued brands including Egg Creations!, Simply Egg Whites, Egg Bakes!, EGG Bites and EGGS2go",0,0,0,1,0,0,0,0,0,0,0
SID_201,102,The steps we have taken in 2023 to prevent and reduce the risk of forced labour and child labour Our focus in 2023 was on conducting an internal assessment of risks of forced and/or child labour within the Reporting Entities activities and supply chains,0,0,0,0,0,0,0,1,0,0,0
SID_201,103,We carried out a prioritization exercise,0,0,0,0,0,0,0,1,0,0,0
SID_201,104,and focused due diligence efforts on the most severe risks of forced and child labour,0,0,0,0,0,0,0,1,0,0,0
SID_201,105,This prioritization exercise has lead to the identification of various tasks that will be undertaken in 2024,0,0,0,0,0,0,0,0,0,0,0
SID_201,106,"Some of these tasks will include performing training, adding clauses to our Supplier Agreements, distributing a survey tool to our largest and most at risk suppliers, analysing and adjusting our temporary foreign workers agency contracts and practices and partnering with provincial and federal Egg Marketing Boards to ensure egg farmers are also in compliance",0,0,0,0,0,0,0,1,0,0,0
SID_201,107,"Policies, due diligence and controls Burnbrae Farms has, in recent years, adopted several tools aimed at furthering its sustainability goals which include the topics of forced labour and child labour",0,0,0,0,0,0,0,1,0,0,0
SID_201,108,"(a) Sustainability Reports Burnbrae Farms is proud to have published, in 2022, its very first sustainability report covering the efforts we have undertaken in the previous two years in the fields of environment, animal care, health and wellbeing, safe nourishing food and community spirit (our Key Areas of Focus)",0,0,0,0,0,0,0,0,0,0,0
SID_201,109,"This initiative was repeated in 2023 (together with the sustainability report published in 2022, the Sustainability Reports)",0,0,0,0,0,0,0,0,0,0,0
SID_201,110,"Going forward on an annual basis, we plan to publish our updated Sustainability Reports",0,0,0,0,0,0,0,0,0,0,0
SID_201,111,"In our Sustainability Reports, we adopt the reporting framework recommended by the United Nations Sustainable Development Goals (SDGs)",0,0,0,0,0,0,0,0,0,0,0
SID_201,112,"Burnbrae Farms supports the direction and approach of the SDGs, which represent a universal call to action to end poverty, protect the planet, and ensure prosperity for all",0,0,0,0,0,0,0,0,0,0,0
SID_201,113,"In our Sustainability Reports, our goal is to establish clear links between our efforts and specific SDGs that are most affected by our industry, and where we feel we have a unique opportunity to leverage our scale and expertise for positive change",0,0,0,0,0,0,0,0,0,0,0
SID_201,114,We do so by identifying which SDGs are targeted in each of our Key Areas of Focus,0,0,0,0,0,0,0,0,0,0,0
SID_201,115,"We align our sustainability disclosure with the SDGs, including goal 8 which aims to promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all, and its target 8.7 the objective of which is to take immediate and effective measures to eradicate forced labour, end modern slavery and human trafficking and secure the prohibition and elimination of the worst forms of child labour, including recruitment and use of child soldiers, and by 2025 end child labour in all its forms",0,0,0,0,0,0,0,0,0,0,0
SID_201,116,"Our metrics and key performance indicators are informed by the standards outlined in the Global Reporting Initiative, an independent, international organization providing language and metrics to help communicate businesses impacts",0,0,0,0,0,0,0,0,0,0,0
SID_201,117,"Amongst other topics, our Sustainability Reports outline and track Burnbrae Farms progress in its Key Areas of Focus in the form of a Sustainability Report Card",0,0,0,0,0,0,0,0,0,0,0
SID_201,118,"For each area covered in the Sustainability Report Card, we set ourselves targets and we monitor our progress year over year",0,0,0,0,0,0,0,0,0,0,0
SID_201,119,"For more information on our Sustainability Report Card, please refer to section 4 of this Report",0,0,0,0,0,0,0,0,0,0,0
SID_201,120,(b) Employee Code of Conduct The Burnbrae Farms Employee Code of Conduct (the Code) sets high standards for conducting business in a legal and ethical manner and serves as the foundation of our corporate policies and procedures,0,0,0,0,0,0,0,0,0,0,0
SID_201,121,"The Code, which all employees, officers and directors are required to abide by and sign, was updated in 2022",0,0,0,0,0,0,0,1,0,0,0
SID_201,122,"The Code states that Burnbrae Farms and all people covered by the Code are required to abide by all laws in the jurisdictions where they operate, which includes the Act",0,0,0,0,0,0,0,1,0,0,0
SID_201,123,The Code applies the,0,0,0,0,0,0,0,1,0,0,0
SID_201,124,"same requirement independent of whether we conduct business with international customers, suppliers, contractors or government agencies",0,0,0,0,0,0,0,1,0,0,0
SID_201,125,(c) Confidential Reporting System Burnbrae Farms has established a Confidential Reporting System so that any signatory of the Code can question an action taken by a colleague and report a situation where the signatory suspects an ethics violation or a breach of the Code,0,0,0,0,0,0,0,1,0,0,0
SID_201,126,The Confidential Reporting System takes the form of a phone hotline which signatories can reach at anytime,0,0,0,0,0,0,0,1,0,0,0
SID_201,127,"If a signatory reports potential wrongdoing, every effort will be made to protect their confidentiality, as applicable laws permit, and Burnbrae Farms will ensure that no retaliation occurs",0,0,0,0,0,0,0,1,0,0,0
SID_201,128,Risk Assessment Methodology and Results of Assessment We use the Sustainability Report Card contained in our Sustainability Reports to set ourselves targets and to monitor our progress,0,0,0,0,0,0,0,0,0,0,0
SID_201,129,We see our goal of eradicating forced labour and child labour from our supply chain as fitting within the Health and Wellbeing Area of Focus of our Sustainability Report,0,0,0,0,0,0,0,1,0,0,0
SID_201,130,"In 2022, in this Area of Focus, we were on track to meet two targets, we achieved two targets and we established four new targets",0,0,0,0,0,0,0,0,0,1,0
SID_201,131,In 2024 we will add progress updates on our goals that address action items following our risk analysis regarding forced and child labour,0,0,0,0,0,0,0,0,0,1,0
SID_201,132,The identification of targets in the Sustainability Report Card forms the heart of our risk assessment methodology,0,0,0,0,0,0,0,0,0,0,0
SID_201,133,"When new risks are identified, we set ourselves goals related to the management and elimination of those risks",0,0,0,0,0,0,0,0,0,0,0
SID_201,134,"Every year, we assess our goals and decide whether the previous years identified targets are achieved or on track to be met",0,0,0,0,0,0,0,0,0,0,0
SID_201,135,"Risks of forced labour and child labour in our operations and supply chains Since 2021, Burnbrae Farms participates in the Temporary Foreign Worker Program (the TFWP) which allows Canadian employers to hire foreign nationals to fill jobs in cases where qualified Canadians arent available",0,0,0,0,1,0,0,0,0,0,0
SID_201,136,"We launched the program in our Lyn, Ontario facilities and due to its success, we have expanded it to other grading locations in Ontario and British Columbia as well as our further processing facilities in Upton, Quebec and Brockville, Ontario",0,0,0,0,1,0,0,0,0,0,0
SID_201,137,We recognize the forced labour risks associated with migrant workers participating in the TFWP,0,0,0,0,0,0,1,0,0,0,0
SID_201,138,Migrant workers face heightened susceptibility to exploitative recruitment tactics,0,0,0,0,0,0,0,0,0,0,0
SID_201,139,"When recruitment fees are imposed on migrant workers by recruiters and employment agents, migrant workers can become indebted to them",0,0,0,0,0,0,0,0,0,0,0
SID_201,140,"Non-repayment of these dues can lead to dire repercussions, including prolonged work hours and wage deductions",0,0,0,0,0,0,0,0,0,0,0
SID_201,141,"This burden of debt, compounded by the uncertainty surrounding job security and residency status, renders migrant workers exceptionally prone to various manifestations of modern slavery",0,0,0,0,0,0,0,0,0,0,0
SID_201,142,"In its participation in the TFWP, Burnbrae Farms carefully selects the recruiters and employment agents it contracts with",0,0,0,0,0,0,0,1,0,0,0
SID_201,143,"In fiscal 2023, seventy percent (70% of the t6ask associated with recruiting candidates was performed in-house by Burnbrae Farms HR team",0,0,0,0,0,0,0,0,0,1,0
SID_201,144,We aim to avoid the use of employment agents to ensure we are following best practices and to develop the expertise internally,0,0,0,0,0,0,0,1,0,0,0
SID_201,145,Burnbrae Farms only deals with reputable service providers and commits to terminating its relationship with any recruiter or employment agent immediately upon discovery of any kind of predatory behaviour described above,0,0,0,0,0,0,0,0,1,0,0
SID_201,146,"To our knowledge, we have not uncovered any",0,0,0,0,0,0,1,0,0,0,0
SID_201,147,indications of forced labour or child labour within our operations and supply chain,0,0,0,0,0,0,1,0,0,0,0
SID_201,148,"Our ongoing review of our risk assessment procedures, conducted annually, aims to detect any potential shortcomings in our evaluations",0,0,0,0,0,0,0,0,0,0,0
SID_201,149,"Remedial Action Taken during the Reporting Period During the Reporting Period, Burnbrae Farms did not perform any remediation actions with respect to forced labour and child labour",0,0,0,0,0,0,0,0,1,0,0
SID_201,150,"Our remediation processes Given that no remediation measures were taken during the Reporting Period, we did not adopt any remediation process to deal with possible occurrences of forced labour and child labour in our operations and/or supply chains",0,0,0,0,0,0,0,0,1,0,0
SID_201,151,"Remediation actions for the loss of income to the most vulnerable families that results from any measure taken to eliminate forced labour and child labour from our operations and supply chains Given that we have not taken any remediation during the Reporting Period, we consequently did not perform any remediation actions for the loss of income to the most vulnerable families",0,0,0,0,0,0,0,0,1,0,0
SID_201,152,Our Training One of the goals we set ourselves in our Sustainability Report Card under the Health and Wellbeing Area of Focus pertains to the training of our workforce,0,0,0,0,0,0,0,0,1,0,0
SID_201,153,"In 2024, we aim to integrate sections on forced labour and child labour into the technical training, on-boarding, cross training and coaching programs we are developing",0,0,0,0,0,0,0,1,0,0,0
SID_201,154,New employees in key roles will receive training through in person or virtual sessions and through our training video project,0,0,0,0,0,0,0,1,0,0,0
SID_201,155,"The topics covered include animal care, equipment safety, food safety, diversity and inclusion",0,0,0,0,0,0,0,0,0,0,0
SID_201,156,All employees have signed a copy of the Code,0,0,0,0,0,0,0,1,0,0,0
SID_201,157,This demonstrates that they have read and understood its contents which include sections relating to abidance to laws of the jurisdictions in which employees are located,0,0,0,0,0,0,0,1,0,0,0
SID_201,158,"Seeing that all of our production, grading, farming and processing activities are located in Canada, the laws to which employees abide include the Act",0,0,0,0,1,0,0,1,0,0,0
SID_201,159,Assessing our effectiveness We are committed to continually evaluating and enhancing our key performance indicators to gauge the effectiveness of the implementation of the objectives outlined in our Sustainability Reports as well as to continuously refine our human rights approach,0,0,0,0,0,0,0,0,0,0,0
SID_201,160,"The efficiency of each Reporting Entity's industry-specific due diligence process is regularly assessed to ensure its relevance and alignment with our business operations, regulatory changes, industry norms, and best practices",0,0,0,0,0,0,0,0,0,1,0
SID_201,161,"Through these measures, each entity ensures compliance with all pertinent laws and regulations across our operational jurisdictions, including those addressing forced labour and child labour risks",0,0,0,0,0,0,0,1,0,0,0
SID_201,162,"We engage in constructive dialogue with suppliers whenever corrective actions are necessary, we diligently monitor the progress of these actions from initiation to completion",0,0,0,0,0,0,0,0,1,0,0
SID_201,163,"Notably, no issues requiring review were identified in fiscal 2023, and there were no incidents of forced labour or child labour associated with our suppliers through our monitoring processes",0,0,0,0,0,0,1,0,0,0,0
SID_201,164,"In evaluating the efficacy of our corporate social responsibility risk management approach, we solicit feedback from relevant internal and external stakeholders",0,0,0,0,0,0,0,0,0,1,0
SID_201,165,"Our consultation and governance process In preparing this Report, each Reporting Entity engaged other entities it owns or controls",0,0,0,0,0,0,0,0,0,0,0
SID_201,166,"It also consulted with key areas of our organization to prepare this Report, including departments or teams dealing with procurement, human resources, government relations, legal and contractual issues, our sustainability specialists and our external legal counsel",0,0,0,0,0,0,0,0,0,0,0
SID_201,167,"These teams operate across our enterprise, including across the subsidiaries to which this Report applies",0,0,0,0,0,0,0,0,0,0,0
SID_201,168,This consultation process has supported our business-wide approach to human rights which include forced labour and child labour,0,0,0,0,0,0,0,0,0,0,0
SID_201,169,"Approval This Report was approved by the sole shareholders of each Reporting Entity acting as the governing body of each Reporting Entity on May 20, 2024",1,0,0,0,0,0,0,0,0,0,0
SID_201,170,Conclusion Each Reporting Entity steadfastly upholds its dedication to eliminating the occurrence of forced labour and child labour within our operations and throughout our supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_201,171,"We remain resolute in the ongoing examination of our policies, protocols, and operational methodologies, periodically reviewing and fortifying our defenses against forced labour, child labour, and all manifestations of human rights violations",0,0,0,0,0,0,0,0,0,0,0
SID_201,172,-20,0,0,0,0,0,0,0,0,0,0,0
SID_201,173,"Attestation (Public Safety Canada) In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the Report for the entity or entities listed above",0,0,0,0,0,0,0,0,0,0,0
SID_201,174,"Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above",0,0,0,0,0,0,0,0,0,0,0
SID_201,175,"Dated this 20th day of May, 2024 Burnbrae FarmCo 19 Inc Burnbrae Farms Limited Per: Margaret Hudson Per: Margaret Hudson Director of the sole shareholder of Burnbrae FarmCo 19 Inc., I have the authority to bind Burnbrae FarmCo 19 Inc",0,1,0,0,0,0,0,0,0,0,0
SID_201,176,"Director of the sole shareholder of Burnbrae Farms Limited, I have the authority to bind Burnbrae Farms Limited",0,1,0,0,0,0,0,0,0,0,0
SID_201,177,"Ferme St-Zotique Lte Per: Margaret Hudson Director of the sole shareholder of Ferme St-Zotique Lte, I have the authority to bind Ferme St-Zotique Lte",0,1,0,0,0,0,0,0,0,0,0
SID_209,1007,REPORT PERSUANT TO THE FIGHTING AGAINST FORCED LABOUR AND CHILD LABOUR IN SUPPLY CHAINS ACT (CANADA) FOR THE YEAR 2023,0,0,0,0,0,0,0,0,0,0,0
SID_209,1008,"Introduction This report (the Report"") is produced by TRX Gold Corporation (the Corporation or TRX Gold) for the financial year starting September 1, 2022 and ending August 31, 2023 (the Reporting Period) and sets out the steps taken by TRX Gold and its subsidiaries, TRX Gold Tanzania Limited (TRX TZ), Tancan Mining Company Limited and Buckreef Gold Company Limited, to prevent and reduce the risk that forced labour or child labour is used at any step during the production of goods in Tanzania or elsewhere, or for goods imported into Canada by the Corporation",0,0,0,1,1,0,0,0,0,0,0
SID_209,1009,This Report constitutes the first report prepared by the Corporation pursuant to Canadas new Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Act),0,0,0,0,0,0,0,0,0,0,0
SID_209,1010,"Structure, activities and supply chains TRX Gold is a Canadian gold mining company focused on operating, developing and exploring its interest in the Buckreef Gold Project (Buckreef) in the United Republic of Tanzania (Tanzania"")",0,0,0,0,1,0,0,0,0,0,0
SID_209,1011,The Corporations shares are listed on the Toronto Stock Exchange and the NYSE American Exchange,0,0,0,0,0,0,0,0,0,0,0
SID_209,1012,"Buckreef is a joint venture partnership that is 55% owned by TRX TZ, a wholly owned subsidiary of the Corporation, and 45% owned by STAMICO, an enterprise wholly-owned by the government of Tanzania",0,0,0,1,0,0,0,0,0,0,0
SID_209,1013,"The primary product that is mined, milled and produced at Buckreef is gold dor, which is sold to customers in Europe and the United States of America",0,0,0,0,1,0,0,0,0,0,0
SID_209,1014,"During the Reporting Period, the mine produced 20,759 ounces of gold",0,0,0,0,1,0,0,0,0,0,0
SID_209,1015,TRX Gold conducted business with close to 700 contractors at the end of the Reporting Period,0,0,0,0,0,1,0,0,0,0,0
SID_209,1016,"Our supply chain includes suppliers of traded and non-traded goods and services, and maritime services (inbound and outbound)",0,0,0,0,0,1,0,0,0,0,0
SID_209,1017,Our relationships with suppliers vary from one-off engagements through to long- term contractual agreements,0,0,0,0,0,1,0,0,0,0,0
SID_209,1018,We source a diverse range of goods and services through our global supply chain,0,0,0,0,0,0,0,0,0,0,0
SID_209,1019,"The primary categories of goods and services purchased include: support services; equipment consumables, tools and spare parts; utilities; industrial engineering; chemicals; construction and materials; and general industrials",0,0,0,0,0,1,0,0,0,0,0
SID_209,1020,"While our supply chain reaches beyond the African continent, over ninety percent of our suppliers come from within our operating country of Tanzania",0,0,0,0,0,1,0,0,0,0,0
SID_209,1021,"Policies, Governance and Due Diligence Process TRX Gold is committed to embedding human rights considerations into its policies, governance framework and decision making",0,0,0,0,0,0,0,0,0,0,0
SID_209,1022,"As such, TRX Gold sees the management of environmental, social and governance (ESG) risks and opportunities as an inherent part of TRX Golds success",0,0,0,0,0,0,0,0,0,0,0
SID_209,1023,TRX Gold regularly tracks the potential sustainability-related risks that are shaping its operating environment and develops and implements strategies to progress its performance across sustainability areas,0,0,0,0,0,0,0,0,0,0,0
SID_209,1024,"All of these actions are framed by the Corporations Environmental, Sustainability, Health & Safety Policy which outlines its commitment to full compliance, applicable legislation, government requirements and best practices to",0,0,0,0,0,0,0,1,0,0,0
SID_209,1025,"protect all stakeholders, which in turn ensures compliance to the Corporations Code of Ethics Policy",0,0,0,0,0,0,0,1,0,0,0
SID_209,1026,TRX Gold is currently drafting its inaugural ESG Report for its 2023 fiscal year,0,0,0,0,0,0,0,0,0,0,0
SID_209,1027,"This report will include an annual update on the Corporations corporate social responsibility performance and its ESG practices, partially aligned with the 2023 Sustainability Accounting Standards Board (SASB) Metals & Mining Industry Standard and inspired by the Stakeholder Capitalism Metrics (SCM) of the World Economic Forum (WEF)",0,0,0,0,0,0,0,0,0,0,0
SID_209,1028,"At TRX Gold, being a responsible miner is at the core of everything we do",0,0,0,0,0,0,0,0,0,0,0
SID_209,1029,"From exploration to construction and operations through to mine closure, we act in accordance with leading international industry practice, meet regulatory requirements and always strive for continuous improvement",0,0,0,0,1,0,0,0,0,0,0
SID_209,1030,"Code of Ethics TRX Golds Code of Ethics and Business Conduct Policy applies to all members of the TRX Gold community, including the Board of Directors, officers, employees and consultants at every level, in every country and from every TRX Gold legal entity",0,0,0,0,0,0,0,1,0,0,0
SID_209,1031,"It addresses ethical conduct in our work environment, business practices and relationships with external stakeholders",0,0,0,0,0,0,0,1,0,0,0
SID_209,1032,The principles set out in the Code of Ethics and Business Conduct Policy reflect TRX Golds belief that honesty and integrity foster a positive work environment that strengthens the confidence of all stakeholders,0,0,0,0,0,0,0,0,0,0,0
SID_209,1033,The policy details the standards of behaviour expected from everyone to whom it applies in their daily activities and in dealings with others,0,0,0,0,0,0,0,0,0,0,0
SID_209,1034,It also outlines the key responsibilities of TRX Gold leaders who are to provide a model of high standards of ethical conduct and to create a work environment reflecting both the content and the spirit of the Code of Ethics,0,0,0,0,0,0,0,0,0,0,0
SID_209,1035,"Among other things, our Code of Ethics requires compliance with laws and regulations, and recognized industry standards respecting safety and the environment in accordance with TRX Golds Environmental, Sustainability, Health & Safety Policy which specifically includes provisions addressing forced labour and child labour, as follows: The Company commits to ensure that its activities do not directly cause or contribute to human rights violations and shall respect and comply with human rights covenants related to labour, economics, social, culture, health, safety and security, environment and land, modern slavery, cultural heritage, and Indigenous peoples",0,0,0,0,0,0,0,1,0,0,0
SID_209,1036,"The Code of Ethics applies at all times, without exception, to all members of the Board of Directors, officers, employees and consultants",0,0,0,0,0,0,0,1,0,0,0
SID_209,1037,"The Company expects all Representatives to uphold and comply with human rights covenants related to labour, economics, social, culture, health, safety and security, environment and land, modern slavery, cultural heritage, and Indigenous peoples",0,0,0,0,0,0,0,1,0,0,0
SID_209,1038,All Representatives have an obligation to report any violation of human rights in accordance with the Companys Whistleblower Policy and Procedures,0,0,0,0,0,0,0,1,0,0,0
SID_209,1039,The Code of Ethics can be found here: https://wp-trxgold-2024.s3.ca-central-1.amazonaws.com/media/2024/03/TRX-Gold-Corp-Code-of-Ethics-and- Business-Conduct-2022-FINAL_Formatted.pdf,0,0,0,0,0,0,0,0,0,0,0
SID_209,1040,"Whistleblower Policy and Procedures In accordance with our Code of Ethics, our Whistleblower Policy and Procedures (https://wp-trxgold- 2024.s3.ca-central-1.amazonaws.com/media/2024/03/TRX-Gold-Corp-Whistleblower-Policy-and- Procedures-2022-FINAL_Formatted.pdf) is available should employees or suppliers have concerns regarding forced labour or child labour, or other matters, they have a responsibility to report their suspicions without fear of dismissal or retaliation of any kind",0,0,0,0,0,0,0,1,0,0,0
SID_209,1041,Steps to prevent and reduce risks of forced labour and child labour We consider the respect of human rights to be a fundamental corporate responsibility and a value governing all our activities,0,0,0,0,0,0,0,0,0,0,0
SID_209,1042,We place the highest importance on respecting human rights while conducting our business activities everywhere we operate,0,0,0,0,0,0,0,0,0,0,0
SID_209,1043,We expect the same of our business partners,0,0,0,0,0,0,0,0,0,0,0
SID_209,1044,Training Employees of TRX Gold receive regular tailored training on ethical topics and our policies,0,0,0,0,0,0,0,1,0,0,0
SID_209,1045,All new office employees are assigned a mandatory onboarding training package which includes training on our Code of Ethics,0,0,0,0,0,0,0,1,0,0,0
SID_209,1046,"On an annual basis, all employees are required to certify their abidance by our Code of Ethics",0,0,0,0,0,0,0,1,0,0,0
SID_209,1047,"Supplier Due Diligence The Corporation is currently assessing due diligence measures that will flag any of our suppliers who may carry a risk of introducing any forced labour or child labour into our supply chain, as well as the implementation of a risk monitoring system that will notify us of a breach of our future Supplier Code of Conduct",0,0,0,0,0,0,0,1,0,0,0
SID_209,1048,Assessing and Managing Our Risk TRX Gold uses a risk-based approach to assess and manage the risk of forced labour and child labour being utilized in its supply chain,0,0,0,0,0,0,0,1,0,0,0
SID_209,1049,Our approach helps us prioritize our efforts and adjust our actions,0,0,0,0,0,0,0,0,0,0,0
SID_209,1050,"In practice, this has resulted in a heightened level of understanding and awareness of the potential risks faced at Buckreef",0,0,0,0,0,0,0,0,0,0,0
SID_209,1051,"Furthermore, our methodology to identify risks in our supply chain through the development of a Supplier Due Diligence process, will combine country risk and event risk indicators as well as the development of a risk database of adverse media, sanctions, watchlists, and politically exposed persons",0,0,0,0,0,0,0,1,0,0,0
SID_209,1052,"To date, the due diligence conducted by TRX Gold has not identified a material risk within our supply chain regarding the presence of forced labour or child labour",0,0,0,0,0,0,1,0,0,0,0
SID_209,1053,"Assessing Effectiveness TRX Gold has in place a number of measures to identify, prevent and reduce the risk that forced labour or child labour is used in our activities and supply chain",0,0,0,0,0,0,0,0,0,0,0
SID_209,1054,"While we have not yet taken any actions to assess the effectiveness of those actions, TRX Gold intends to assess its effectiveness in preventing and reducing risks of forced labour and child labour in its activities and supply chain at a later stage",0,0,0,0,0,0,0,0,0,1,0
SID_209,1055,"Remediation Measures Our Code of Ethics and Whistleblower Policy and Procedures offer a reporting mechanism for our employees and suppliers to report ethical or legal violations, among other concerns",0,0,0,0,0,0,0,1,0,0,0
SID_209,1056,"In accordance with our policies, if a situation of non-compliance is identified, TRX Gold will work to develop and implement a corrective plan to improve and remedy the situation",0,0,0,0,0,0,0,0,1,0,0
SID_209,1057,"To date, TRX Gold has not identified any material risk of the presence of forced labour or child labour used in its activities or supply chain and therefore has not",0,0,0,0,0,0,1,0,1,0,0
SID_209,1058,undertaken any measures to: (i) remediate forced labour or child labour in its activities and supply chain; or (ii) remediate loss of income that results from any measure taken to eliminate the use of forced labour or child labour in its activities and supply chain,0,0,0,0,0,0,0,0,1,0,0
SID_209,1059,Forward Looking Information Certain information in this Report may constitute forward-looking information within the meaning of applicable securities legislation,0,0,0,0,0,0,0,0,0,0,0
SID_209,1060,"Specific forward-looking information in this Report includes, without limitation, statements relating to TRX Golds policies and practices with respect to modern slavery risk management, including statements of current intention and expectation and statements of opinion",0,0,0,0,0,0,0,0,0,0,0
SID_209,1061,"Forward-looking information may also include information regarding our future plans or objectives or other information that is not comprised of historical fact and includes statements that contain words such as could, should, expect, believe, plan, intend, will, may, and similar expressions suggesting future outcomes or events",0,0,0,0,0,0,0,0,0,0,0
SID_209,1062,"Any such forward-looking information is based on information currently available to us and is based on assumptions we believe are appropriate in the circumstances, including those but not limited to the effectiveness of any of our policies and practices with respect to modern slavery risk management",0,0,0,0,0,0,0,0,0,0,0
SID_209,1063,"However, such forward-looking information involves significant risks and uncertainties",0,0,0,0,0,0,0,0,0,0,0
SID_209,1064,A number of factors could cause actual results to differ materially from those discussed in the forward-looking information,0,0,0,0,0,0,0,0,0,0,0
SID_209,1065,"These risks are more fully discussed in our most recent managements discussion and analysis and annual information form which are available at www.TRXgold.com, our SEDAR+ profile at www.sedarplus.ca or from the SECs website at http://www.sec.gov/edgar.shtml",0,0,0,0,0,0,0,0,0,0,0
SID_209,1066,We caution readers not to place undue reliance on any such forward-looking information,0,0,0,0,0,0,0,0,0,0,0
SID_209,1067,Such information is current only as of the date on which it was made,0,0,0,0,0,0,0,0,0,0,0
SID_209,1068,"Unless otherwise required by applicable securities laws, we do not intend, nor do we undertake any obligation, to update or revise any forward-looking information contained in this Report",0,0,0,0,0,0,0,0,0,0,0
SID_209,1069,Approval and Attestation This Report was approved pursuant to subparagraph 11(4)(b)(ii) of the Act by the Board of Directors of TRX Gold Corporation,1,0,0,0,0,0,0,0,0,0,0
SID_209,1070,"In my capacity as a Director of TRX Gold Corporation, and not in my personal capacity, I make this attestation in accordance with the requirements of the Act",0,0,0,0,0,0,0,0,0,0,0
SID_209,1071,"In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the Report for the entities listed above",0,0,0,0,0,0,0,0,0,0,0
SID_209,1072,"Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the Report is true, accurate and complete in all material respects for the purposes of the Act, for the Reporting Period",0,0,0,0,0,0,0,0,0,0,0
SID_209,1073,I have the authority to bind TRX Gold Corporation,0,0,0,0,0,0,0,0,0,0,0
SID_209,1074,Per: /s/ Shubo Rakhit,0,1,0,0,0,0,0,0,0,0,0
SID_209,1075,"Name: Shubo Rakhit Chair and Director of TRX Gold Corporation May 28, 2024",0,1,0,0,0,0,0,0,0,0,0
SID_213,1215,REPORT UNDER THE FIGHTING AGAINST FORCED LABOUR AND CHILD LABOUR IN SUPPLY CHAINS ACT,0,0,0,0,0,0,0,0,0,0,0
SID_213,1216,"FINANCIAL YEAR ENDED DECEMBER 31, 2023",0,0,0,0,0,0,0,0,0,0,0
SID_213,1217,"Introduction This report (the Report), prepared pursuant to the Fighting Against Forced Labour and Child Labour in Supply Chains Act (Canada)(the Act), is prepared by and made on behalf of PrairieSky Royalty Ltd and its wholly-owned subsidiaries Tenax Energy Inc., Hayden Resources Ltd.1 and NV Resources Corporation Ltd (collectively, PrairieSky or the Company or our or we)",0,0,0,1,0,0,0,0,0,0,0
SID_213,1218,"The Report constitutes PrairieSkys first report under the Act and will detail the steps that PrairieSky has taken to assess forced labour and child labour risks in its activities and supply chain during the previous financial year ended December 31, 2023",0,0,0,0,0,0,0,0,0,0,0
SID_213,1219,"Where applicable, the Report will also identify the preventative measures that have been implemented by PrairieSky in order to prevent and reduce the risk that forced labour and child labour is used at any step in its business",0,0,0,0,0,0,0,0,0,0,0
SID_213,1220,PrairieSky does not have any other additional reporting requirements under supply chain legislation in jurisdictions outside of Canada,0,0,0,0,0,0,0,0,0,0,0
SID_213,1221,"Measures to Prevent and Reduce the Risks of Forced Labour and/or Child Labour in PrairieSkys Supply Chain In the previous financial year, PrairieSky took the following measures to prevent and reduce the risk of forced labour or child labour in its activities and supply chain",0,0,0,0,0,0,0,1,0,0,0
SID_213,1222,"reviewed and updated the Business Code of Conduct, the Human Rights Policy, and the Supplier Code of Conduct to include language relating to the implementation and development of anti-forced labour and anti-child labour principles",0,0,0,0,0,0,0,1,0,1,0
SID_213,1223,expanded our employee and contractor training to include guidance with respect to PrairieSkys expectations and obligations relating to forced labour and child labour legislation and outlined the procedures available to all employees and contractors to report concerns arising out of human rights impacts,0,0,0,0,0,0,0,1,0,0,0
SID_213,1224,conducted a preliminary initial internal assessment of the risks of forced labour and/or child labour in our supply chain generally; and,0,0,0,0,0,0,0,1,0,0,0
SID_213,1225,continued process to obtain sign off from all of PrairieSkys suppliers on the Supplier Code of Conduct,0,0,0,0,0,0,0,1,0,0,0
SID_213,1226,"Structure, Activities and Supply Chain Structure PrairieSky is incorporated under the Alberta Business Corporations Act (the ABCA)",0,0,0,1,0,0,0,0,0,0,0
SID_213,1227,"The Company was incorporated under the ABCA under the name ""1786071 Alberta Ltd."" on November 27, 2013",0,0,0,1,0,0,0,0,0,0,0
SID_213,1228,"In December 2013 and January 2014, the Company undertook a reorganization",0,0,0,0,0,0,0,0,0,0,0
SID_213,1229,"On April 11, 2014, the Company changed its name to ""PrairieSky Royalty Ltd."" Prior to the Companys initial public offering on May 29, 2014, the Company was a wholly-owned subsidiary of Encana",0,0,0,1,0,0,0,0,0,0,0
SID_213,1230,"Effective January 1, 2024, Tenax Energy Inc amalgamated with its wholly-owned subsidiary, Hayden Resources Ltd, and continued under the name Tenax Energy Inc",0,0,0,1,0,0,0,0,0,0,0
SID_213,1231,"Corporation, PrairieSkys common shares are listed and trade on the Toronto Stock Exchange under the symbol PSK",0,0,0,0,0,0,0,0,0,0,0
SID_213,1232,"Activities PrairieSkys headquarters, and only business location, are in Calgary, Alberta",0,0,0,1,1,0,0,0,0,0,0
SID_213,1233,The Company carries on business exclusively in Canada and owns assets in Western Canada specifically,0,0,0,0,1,0,0,0,0,0,0
SID_213,1234,PrairieSky currently has one of the largest independently owned portfolios of fee simple mineral title and oil and gas royalty interests in Canada,0,0,0,0,1,0,0,0,0,0,0
SID_213,1235,"PrairieSky is focused on encouraging third parties to actively develop royalty properties while strategically seeking additional crude oil and natural gas royalty assets that provide the Company with medium-term to long-term value enhancement potential, including the acquisition of Crown interest lands for purposes of complementing the Company's fee title land base and pursuing prospective farmout strategies",0,0,0,0,1,0,0,0,0,0,0
SID_213,1236,The Company does not conduct any drilling activity and is not responsible for making any capital expenditures with respect to its royalty properties,0,0,0,0,1,0,0,0,0,0,0
SID_213,1237,The Company does not have an operators license and does not own any oil and natural gas well bores or other related infrastructure,0,0,0,0,1,0,0,0,0,0,0
SID_213,1238,"The Company receives royalty revenue based on the production performance of wells, with the calculation of such royalty revenues payable based, in part, on the market price of oil and/or natural gas and allowances, if any, for certain deductions",0,0,0,0,1,0,0,0,0,0,0
SID_213,1239,Supply Chain,0,0,0,0,0,0,0,0,0,0,0
SID_213,1240,"Sale of Goods Within Canada Because PrairieSky is a pure-play royalty company with all of its operations in Canada, and given the nature of PrairieSkys business generally, its supply chain is limited",0,0,0,0,1,0,0,0,0,0,0
SID_213,1241,"PrairieSky does not directly conduct operations to explore for, develop or produce petroleum or natural gas",0,0,0,0,1,0,0,0,0,0,0
SID_213,1242,It does not own or operate any oil and gas wells and as a result has no capital expenditures or operating costs related to oil and gas development,0,0,0,0,1,0,0,0,0,0,0
SID_213,1243,"Through certain contractual arrangements with third parties, the Company may, at its election, choose to receive its royalty percentage share of production from its royalty properties as a physical or ""in-kind"" delivery of hydrocarbons",0,0,0,0,1,0,0,0,0,0,0
SID_213,1244,"Currently, the Company takes a limited amount of crude oil royalty volumes in-kind. It is through this limited activity that PrairieSky sells goods exclusively in Canada to third party commodity marketing firms under spot contracts",0,0,0,0,1,0,0,0,0,0,0
SID_213,1245,These sales constituted approximately 10% of PrairieSkys total revenue for 2023,0,0,0,0,1,0,0,0,0,0,0
SID_213,1246,"In 2023, PrairieSky sold certain select volumes of hydrocarbons to thirteen separate marketing entities, twelve of which are incorporated in Canada (one marketing organization was American and incorporated under Minnesota law with a Canadian subsidiary headquartered in Calgary, Alberta)",0,0,0,0,1,0,0,0,0,0,0
SID_213,1247,Purchase of Services Within Canada PrairieSky directly engages a number of professional services provided almost exclusively by Canadian entities,0,0,0,0,0,1,0,0,0,0,0
SID_213,1248,"These services include the provision of IT support, audit, tax and reserve engineering services, legal services, and other administrative and office services",0,0,0,0,0,1,0,0,0,0,0
SID_213,1249,These services are provided exclusively within Canada,0,0,0,0,0,1,0,0,0,0,0
SID_213,1250,These professional service providers are governed by PrairieSkys Supplier Code of Conduct (discussed below),0,0,0,0,0,0,0,1,0,0,0
SID_213,1251,These in-kind sales transactions as well as office rent and the professional services described above constitute the vast majority of PrairieSkys activities as contemplated under the Act,0,0,0,0,1,0,0,0,0,0,0
SID_213,1252,"Policies, Governance and Due Diligence Processes Environmental, Social and Governance Processes and Initiatives PrairieSky is committed to the protection of the environment, good governance and human rights",0,0,0,0,0,0,0,0,0,0,0
SID_213,1253,"The Company supports the Ten Principles of the United Nations Global Compact with respect to human rights, labour, environment and anti-corruption and is a signatory thereto",0,0,0,0,0,0,0,1,0,0,0
SID_213,1254,"The Company summarizes the sustainability of its business model, reports annually on its corporate social responsibility performance, and discloses its environment, social and governance (ESG) practices through the publication of its 2024 Sustainability Report for the year ended December 31, 2023, which is available on its website at Our Approach | PrairieSky Royalty Ltd PrairieSkys Board of Directors has oversight of ESG issues as the Company is committed to the highest standards of corporate governance",0,0,0,0,0,0,0,0,0,0,0
SID_213,1255,"Human rights considerations play a prominent role in PrairieSkys ESG reporting, and the Company and its Board are dedicated to continuous improvement efforts in the areas of ESG generally and human rights specifically",0,0,0,0,0,0,0,0,0,0,0
SID_213,1256,"Business Code of Conduct PrairieSkys Business Code of Conduct (found on our website here: Governance | PrairieSky Royalty Ltd.) was developed in alignment with the principles from the United Nations Global Compact, the Universal Declaration of Human Rights, the United Nations Guiding Principles on Business and Human Rights, and the International Labor Organizations Declaration of Fundamental Principles and Rights at Work",0,0,0,0,0,0,0,1,0,0,0
SID_213,1257,"The Business Code of Conduct expressly states that PrairieSky will comply with all applicable employment, labour and human rights law and regulations. It further states: PrairieSky will endeavor to conduct business withthird parties who share our values and business principles. It refers to PrairieSkys Supplier Code of Conduct and the Human Rights Policy specifically and the roles these policies play in PrairieSkys implementation and development of anti-forced labour and/or anti-child labour principles",0,0,0,0,0,0,0,1,0,0,0
SID_213,1258,Human Rights Policy PrairieSkys Human Rights Policy (found on our website here: Governance | PrairieSky Royalty Ltd.) articulates PrairieSkys commitment to ensuring that it is not complicit in human rights abuses and that the avoidance of infringing on the rights of others and engaging in activities that directly or indirectly violate human rights will not be tolerated,0,0,0,0,0,0,0,1,0,0,0
SID_213,1259,"Specifically, the Human Rights Policy addresses child labour as well as forced labour, modern slavery, and human trafficking",0,0,0,0,0,0,0,1,0,0,0
SID_213,1260,The Human Rights Policy governs the scope of PrairieSkys human rights due diligence and recognizes the need to focus on PrairieSkys own business operations as well as its material third party business relationships,0,0,0,0,0,0,0,0,0,0,0
SID_213,1261,"Supplier Code of Conduct PrairieSkys Supplier Code of Conduct (found on our website here: Governance | PrairieSky Royalty Ltd.) aligns with the principles from the United Nations Global Compact, the Universal Declaration of Human Rights, the United Nations Guiding Principles on Business and Human Rights, and the International Labor Organizations Declaration of Fundamental Principles and Rights at Work",0,0,0,0,0,0,0,1,0,0,0
SID_213,1262,"The Supplier Code of Conduct mandates that all suppliers to PrairieSky must not, directly or indirectly, use child labour, forced labour or enslaved labour under any circumstances, whether in the form of compulsory or trafficked labour, indentured labour, bonded labour or other forms",0,0,0,0,0,0,0,1,0,0,0
SID_213,1263,"The Supplier Code of Conduct defines child labour and forced labour as follows, based on the language of the Act: child labour means labour or services provided or offered to be provided by persons under the age of 18 years and that (a) are provided or offered to be provided in Canada under circumstances that are contrary to the laws applicable in Canada; (b) are provided or offered to be provided under circumstances that are mentally, physically, socially or morally dangerous to them; (c) interfere with their schooling by depriving them of the opportunity to attend school, obliging them to leave school prematurely or requiring them to attempt to combine school attendance with excessively long and heavy work; or (d) constitute the worst forms of child labour as defined in article 3 of the Worst Forms of Child Labour Convention, 1999, adopted at Geneva on June 17, 1999",0,0,0,0,0,0,0,1,0,0,0
SID_213,1264,"forced labour means labour or service provided or offered to be provided by a person under circumstances that (a) could reasonably be expected to cause the person to believe their safety or the safety of a person known to them would be threatened if they failed to provide or offer to provide the labour or service; or (b) constitute forced or compulsory labour as defined in article 2 of the Forced Labour Convention, 1930, adopted in Geneva on June 28, 1930",0,0,0,0,0,0,0,0,0,0,0
SID_213,1265,"The Supplier Code of Conduct prohibits mental and physical coercion, human trafficking, and all other forms of modern slavery",0,0,0,0,0,0,0,1,0,0,0
SID_213,1266,Suppliers are obligated to employ personnel who meet the applicable minimum legal age requirement to work in the country or countries in which they operate,0,0,0,0,0,0,0,1,0,0,0
SID_213,1267,Suppliers must also cooperate with PrairieSky in the Companys preparation of regulatory disclosures in respect of forced labour in supply chains,0,0,0,0,0,0,0,1,0,0,0
SID_213,1268,The Supplier Code of Conduct outlines the process for reporting violations under the Code and requires suppliers of PrairieSky to cooperate in PrairieSky investigations regarding potential violations thereunder,0,0,0,0,0,0,0,1,1,0,0
SID_213,1269,"PrairieSky also reserves the right to assess and monitor a suppliers practices with respect to the Supplier Code of Conduct, including through self-assessment questionnaires",0,0,0,0,0,0,0,1,0,0,0
SID_213,1270,Suppliers must also be able to demonstrate compliance under the Code upon request,0,0,0,0,0,0,0,1,0,0,0
SID_213,1271,"Commencing in 2021, PrairieSky began to implement a process whereby it provided all of its existing suppliers with the Supplier Code of Conduct and requested that each supplier review the policy and acknowledge that they agreed with its terms and conditions",0,0,0,0,0,0,0,1,0,0,0
SID_213,1272,PrairieSky intends to,0,0,0,0,0,0,0,1,0,0,0
SID_213,1273,continue this proactive step with any new suppliers that it engages with as a means of mitigating risks relating to the existence of forced labour or child labour practices within its supply chain,0,0,0,0,0,0,0,1,0,0,0
SID_213,1274,Training of Employees and Contractors Employee and contractor mandatory training occurs annually in relation to PrairieSkys Business Code of Conduct,0,0,0,0,0,0,0,1,0,0,0
SID_213,1275,"As a part of the mandatory training, PrairieSky includes guidance to its employees and contractors with respect to PrairieSkys expectations and obligations relating to forced labour and child labour legislation and outlines the procedures available to all employees and contractors to report concerns arising out of human rights impacts",0,0,0,0,0,0,0,1,0,0,0
SID_213,1276,"Identifying, Assessing and Remediating Risks PrairieSky has started the process of identifying risks through the process of filing this Report under the Act",0,0,0,0,0,0,0,1,0,0,0
SID_213,1277,"As gaps are identified through the assessment process, PrairieSky intends to address those gaps by implementing processes and checklists in an effort to improve the monitoring of its supply chain to eliminate elements of forced and child labour in its supply chain if identified, nor any heightened risks of the potential for such elements to exist",0,0,0,0,0,0,0,1,0,0,0
SID_213,1278,"To date, PrairieSky has not identified any part of its activities and supply chain that carries a risk of forced labour or child labour being used",0,0,0,0,0,0,1,0,0,0,0
SID_213,1279,Approval and Attestation This Report was approved by the Board of Directors of PrairieSky pursuant to subparagraph 11(4)(b)(ii) of the Act,1,0,0,0,0,0,0,0,0,0,0
SID_213,1280,"In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the Report for the entity or entities listed above",0,0,0,0,0,0,0,0,0,0,0
SID_213,1281,"Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above",0,0,0,0,0,0,0,0,0,0,0
SID_213,1282,PRAIRIESKY ROYALTY LTD,0,0,0,0,0,0,0,0,0,0,0
SID_213,1283,"___________________________ Andrew Phillips Director, President and Chief Executive Officer I have authority to bind PrairieSky Royalty Ltd., Tenax Energy Inc, and NV Resources Corporation Ltd Date: May 22, 2024",0,1,0,0,0,0,0,0,0,0,0
SID_223,2139,"Report on Forced Labour and Child Labour Risks For the Fiscal Year ended March 31, 2024",0,0,0,0,0,0,0,0,0,0,0
SID_223,2140,Introduction This is a report prepared pursuant to the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Act) that pertains to BioNorth Holdings Limited Partnership (BioNorth),0,0,0,0,0,0,0,0,0,0,0
SID_223,2141,"The above-mentioned entity hereby reports to the Minister of Public Safety and Emergency Preparedness on the various measures taken during its previous financial year ended March 31, 2024 to prevent and reduce the risks that forced labour or child labour is used in their supply chains",0,0,0,0,0,0,0,0,0,0,0
SID_223,2142,"This report is not a revised version of a report previously submitted for BioNorths financial year ended March 31, 2024",0,0,0,0,0,0,0,0,0,0,0
SID_223,2143,BioNorth is engaged in the business of producing clean energy,0,0,0,0,1,0,0,0,0,0,0
SID_223,2144,"The companys a 40-mega-watt biomass power generation plant utilizes forest waste to produce clean energy, employing 30 full-time employees",0,0,0,1,1,0,0,0,0,0,0
SID_223,2145,The primary forest waste utilized at its facility includes: Bush Grind: Leftover materials after trees have been harvested,0,0,0,0,0,1,0,0,0,0,0
SID_223,2146,Mill Residuals: Unusable pieces leftover after milling,0,0,0,0,0,1,0,0,0,0,0
SID_223,2147,Bio Logs: Utilized when other fuel sources have been exhausted,0,0,0,0,0,1,0,0,0,0,0
SID_223,2148,"Structure, Operations and Supply Chain BioNorth Holdings Limited Partnership is a joint venture under a limited partnership agreement among the following",0,0,0,1,0,0,0,0,0,0,0
SID_223,2149,Nakazdli Development Corporation,0,0,0,1,0,0,0,0,0,0,0
SID_223,2150,Unlimited Liability Company,0,0,0,1,0,0,0,0,0,0,0
SID_223,2151,Arrow Northern Services Inc,0,0,0,1,0,0,0,0,0,0,0
SID_223,2152,BioNorth Services Ltd,0,0,0,1,0,0,0,0,0,0,0
SID_223,2153,Policies and Due Diligence Processes BioNorth is governed by its board of directors comprising of stakeholders from the various ownership groups,0,0,0,0,0,0,0,0,0,0,0
SID_223,2154,The company deploys and utilizes policies and procedures established by its board of directors,0,0,0,0,0,0,0,0,0,0,0
SID_223,2155,These include the following,0,0,0,0,0,0,0,0,0,0,0
SID_223,2156,"Policy Manuals/Guidelines Core Values, Principles, and guidelines its policy manual, set expectations for employee behavior and decision-making",0,0,0,0,0,0,0,0,0,0,0
SID_223,2157,Employment Age and Young-Worker Safety Policy,0,0,0,0,0,0,0,0,0,0,0
SID_223,2158,All employes are hired in accordance with the applicable provincial laws and regulations,0,0,0,0,0,0,0,1,0,0,0
SID_223,2159,Employees under the age of 25 are considered a young worker,0,0,0,0,0,0,0,1,0,0,0
SID_223,2160,There are additional requirements for employees classified as a young worker (refer to our training section below),0,0,0,0,0,0,0,1,0,0,0
SID_223,2161,Work Safe BC Our operating practices across our business are designed to comply with applicable laws and standards established by Work Safe BC,0,0,0,0,0,0,0,0,0,0,0
SID_223,2162,Environmental & Social Practices BioNorth utilizes a sustainability roadmap developed by ATSI,0,0,0,0,0,0,0,0,0,0,0
SID_223,2163,An annual sustainability report containing goals and progress made towards meeting those goals is produced as part of the Arrow Groups reporting process,0,0,0,0,0,0,0,0,0,0,0
SID_223,2164,Risk of Modern Slavery in our Operations and Supply Chain BioNorth follows the policies and procedures established by its board of directors,0,0,0,0,0,0,0,0,0,0,0
SID_223,2165,The process of identifying risks is ongoing and BioNorth considers the risks of forced labour or child labour to be low in its own operations and supply chains in the jurisdiction in which it operates,0,0,0,0,0,0,1,0,0,0,0
SID_223,2166,"These risks are managed by a variety of policies, processes, and practices, which are outlined in this report",0,0,0,0,0,0,0,0,0,0,0
SID_223,2167,"All employees are hired in accordance with, at a minimum, the applicable laws and regulations, and checks are conducted to ensure that individuals have the right to work and are choosing to work on their own volition",0,0,0,0,0,0,0,1,0,0,0
SID_223,2168,Remediation Measures BioNorth has not identified risks related to forced labour or child labour in its supply chains and within its own operations,0,0,0,0,0,0,1,0,0,0,0
SID_223,2169,"As a result, no remediation measures were necessary",0,0,0,0,0,0,0,0,1,0,0
SID_223,2170,"Steps to Prevent and Reduce Risks of Forced Labour and Child Labour Over the course of the financial year ended March 31, 2024, BioNorth has conducted its own internal and external assessments of the risks of forced labour and child labour and concluded that the risk is low",0,0,0,0,0,0,1,1,0,0,0
SID_223,2171,"Remediation of Loss of Income As BioNorth has not yet identified any instances of forced labour or child labour in its activities or supply chains, measures to remediate the loss of income to the most vulnerable families that results from measures taken to eliminate the use of forced labour or child labour, have not been required",0,0,0,0,0,0,1,0,0,0,0
SID_223,2172,Training Understanding and complying with our policies and procedures outlined in our policy manuals is a condition of working at BioNorth,0,0,0,0,0,0,0,1,0,0,0
SID_223,2173,All new hires must acknowledge that they have read and understood BioNorths policies,0,0,0,0,0,0,0,0,0,0,0
SID_223,2174,"In addition to our new hire orientation training on the contents of BioNorths policy manual, our Employment Age and Young-Worker Safety Policy contains additional responsibilities for employees under the age of 25",0,0,0,0,0,0,0,1,0,0,0
SID_223,2175,Participate and complete all provided young worker training,0,0,0,0,0,0,0,0,0,0,0
SID_223,2176,Ask for additional training if you do not feel confident completing your task,0,0,0,0,0,0,0,0,0,0,0
SID_223,2177,Follow all workplace health and safety policies and procedures,0,0,0,0,0,0,0,0,0,0,0
SID_223,2178,Work safely always and never endangering themselves or others,0,0,0,0,0,0,0,0,0,0,0
SID_223,2179,Report all real and potential workplace hazards and/or unsafe conditions,0,0,0,0,0,0,0,0,0,0,0
SID_223,2180,Wear personal protective equipment when required,0,0,0,0,0,0,0,0,0,0,0
SID_223,2181,"Prevention of Workplace Bullying, Harassment and Violence",0,0,0,0,0,0,0,0,0,0,0
SID_223,2182,"BioNorths has developed a process for employees to report matters relating to bullying, harassment and violence",0,0,0,0,0,0,0,0,0,0,0
SID_223,2183,All applicable compliant procedures and follow-up processes are clear,0,0,0,0,0,0,0,0,0,0,0
SID_223,2184,Assessing Our Effectiveness The effectiveness of BioNorths policies and processes will be periodically evaluated,0,0,0,0,0,0,0,0,0,0,0
SID_223,2185,"Consultation & Governance Process In preparing this report, BioNorth engaged with its joint-venture partners and departments responsible for establishing and monitoring its policies and procedures",0,0,0,0,0,0,0,0,0,0,0
SID_223,2186,Approval and Attestation This report was approved pursuant to subparagraph 11(4)(b)(ii) of the Act by the Board of Directors of BioNorth Holdings Limited partnership,1,0,0,0,0,0,0,0,0,0,0
SID_223,2187,"In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in this report for the entity listed above",0,0,0,0,0,0,0,0,0,0,0
SID_223,2188,"Based on my knowledge, and having exercised reasonable diligence, I attest that the information in this report is true, accurate and complete in all material respects, for the purposes of the Act, for the reporting year listed above",0,0,0,0,0,0,0,0,0,0,0
SID_223,2189,"______________________________ Mitchell Zulinick CEO BioNorth Services Ltd May 30, 2024 I have the authority to bind BioNorth Holdings Limited Partnership",0,1,0,0,0,0,0,0,0,0,0
SID_224,2190,"Rustica Foods 10301, rue Colbert Montral (Qubec) Canada, H1J 2G5 Email: smorgante@rusticafoods.com",0,0,0,0,0,0,0,0,0,0,0
SID_224,2191,"Date: May 22, 2024",0,0,0,0,0,0,0,0,0,0,0
SID_224,2192,To Whom It May Concern,0,0,0,0,0,0,0,0,0,0,0
SID_224,2193,Subject: Attestation of Approval for Report Bill S-211,0,0,0,0,0,0,0,0,0,0,0
SID_224,2194,To whom it may concern,0,0,0,0,0,0,0,0,0,0,0
SID_224,2195,"I, Sonia Morgante one of the governing bodies of Rustica Foods, hereby affirm and attest that we have thoroughly reviewed and approved the contents of the Report",0,0,0,0,0,0,0,0,0,0,0
SID_224,2196,"The report encompasses all necessary evaluations, analyses, and recommendations pertinent to its scope",0,0,0,0,0,0,0,0,0,0,0
SID_224,2197,"After careful consideration and due diligence, we confirm that the report accurately reflects the findings and complies with our standards and objectives",0,0,0,0,0,0,0,0,0,0,0
SID_224,2198,"Please consider this letter as a formal approval and endorsement of the Bill S-211 report for, An Act to enact the Fighting Against Forced Labour and Child Labour in Supply Chains Act for the financial year ending November 30th, 2023",0,0,0,0,0,0,0,0,0,0,0
SID_224,2199,Sincerely,0,0,0,0,0,0,0,0,0,0,0
SID_224,2200,Sonia Morgante Director of Human Resource On behalf of the Governing Body Rustica Foods,0,0,0,0,0,0,0,0,0,0,0
SID_224,2201,"BILL S-211 An Act to enact the Fighting Against Forced Labour and Child Labour in Supply Chains Act and to amend the Customs Tariff This report is made pursuant to Bill S-211, outlining the approach and initiatives by Rustica Foods Inc and joint entities to identify and address the risks of forced labour and child labour in its business operations and supply chains during the financial year commencing December 1st, 2022, and ending November 30th, 2023",0,0,0,0,0,0,0,0,0,0,0
SID_224,2202,"Rusticas Group Structure Rustica Foods has a rich professional history in food production, transportation and warehousing",0,0,0,0,1,0,0,0,0,0,0
SID_224,2203,We take pride in our Company Code of Conduct on Combating Child Labor and Forced Labor in Supply Chains,0,0,0,0,0,0,0,1,0,0,0
SID_224,2204,"In summary, to support this important initiative, our Code of Conduct contains the following",0,0,0,0,0,0,0,1,0,0,0
SID_224,2205,Prohibition of Child Labor,0,0,0,0,0,0,0,1,0,0,0
SID_224,2206,Our company strictly prohibits the use of child labor,0,0,0,0,0,0,0,1,0,0,0
SID_224,2207,No person under the legal working age (as defined by federal and provincial laws) shall be employed by the company,0,0,0,0,0,0,0,1,0,0,0
SID_224,2208,Age Verification,0,0,0,0,0,0,0,0,0,0,0
SID_224,2209,Adequate documentation (such as birth certificates or government-issued IDs) must be maintained to prove workers' age,0,0,0,0,0,0,0,1,0,0,0
SID_224,2210,Any discrepancies or concerns regarding age verification are promptly addressed,0,0,0,0,0,0,0,0,0,0,0
SID_224,2211,Working Hours and Conditions,0,0,0,0,0,0,0,0,0,0,0
SID_224,2212,"We adhere to legal working hours limits and ensure that workers, including young workers, do not work excessive hours",0,0,0,0,0,0,0,1,0,0,0
SID_224,2213,"Young workers (if legally allowed) must not be engaged in hazardous work or work that jeopardizes their health, safety, or education",0,0,0,0,0,0,0,1,0,0,0
SID_224,2214,We provide a safe and healthy working environment for all employees,0,0,0,0,0,0,0,0,0,0,0
SID_224,2215,Reporting and Whistleblower Protection,0,0,0,0,0,0,0,0,0,0,0
SID_224,2216,Any suspicion or evidence of child labor is reported immediately,0,0,0,0,0,0,0,1,0,0,0
SID_224,2217,We encourage workers and stakeholders to report violations without fear of retaliation,0,0,0,0,0,0,0,1,0,0,0
SID_224,2218,Whistleblower protection mechanisms are in place to safeguard those who report violations,0,0,0,0,0,0,0,1,0,0,0
SID_224,2219,Supply Chain Supplier Audits and Due Diligence,0,0,0,0,0,0,0,0,0,0,0
SID_224,2220,Child labor risk assessments are part of our due diligence process,0,0,0,0,0,0,0,1,0,0,0
SID_224,2221,Significant questions related to their qualifications as a main supplier are inquired in our form (TR-FO-04) Supplier Approval Program,0,0,0,0,0,0,0,1,0,0,0
SID_224,2222,Agencies for temporary workers,0,0,0,0,0,0,0,0,0,0,0
SID_224,2223,Any agency we recruit for temporary work must ensure steps are taken to align with the requirements of Bill S-211,0,0,0,0,0,0,0,0,0,0,0
SID_224,2224,Risk Assessment Internal Assessment: Annual review of existing policies and procedures related to labor practices,0,0,0,0,0,0,0,0,0,1,0
SID_224,2225,Human Resources,0,0,0,0,0,0,0,0,0,0,0
SID_224,2226,Background or reference checks are conducted for new hires,0,0,0,0,0,0,0,0,0,0,0
SID_224,2227,"Examination is made of the background of all staff as appropriate to their position, considering candidates' access to sensitive areas of the facility and the degree to which they will be supervised",0,0,0,0,0,0,0,0,0,0,0
SID_224,2228,Agency recruiters,0,0,0,0,0,0,0,0,0,0,0
SID_224,2229,Letter acknowledging their commitment to our standards Conducted interviews with relevant departments,0,0,0,0,0,0,0,0,0,0,0
SID_224,2230,Quality,0,0,0,0,0,0,0,0,0,0,0
SID_224,2231,GFSI yearly audits for suppliers Procurement,0,0,0,0,0,0,0,1,0,0,0
SID_224,2232,Training with the procurement department to ensure proper documentation is completed prior to approving the supplier,0,0,0,0,0,0,0,1,0,0,0
SID_224,2233,Production,0,0,0,0,0,0,0,1,0,0,0
SID_224,2234,"Transparency in the production department is presented as to whether the conduct of employees is in adherence to the policies (Code of Conduct, Code of Ethics and Human Resource policy)",0,0,0,0,0,0,0,1,0,0,0
SID_224,2235,"Evaluations are done on a yearly basis to ensure employees are treated fairly, and complaints are managed appropriately",0,0,0,0,0,0,0,1,0,0,0
SID_224,2236,Supplier Engagement Rustica requests information on their labor policies and due diligence processes,0,0,0,0,0,0,0,1,0,0,0
SID_224,2237,TR-FO-04 section (9) is dedicated to their CODE OF CONDUCT DISCLOSURE,0,0,0,0,0,0,0,1,0,0,0
SID_224,2238,(Prohibit the placement of children and forced labor in all sectors of the supply chain),0,0,0,0,0,0,0,1,0,0,0
SID_224,2239,This section confirms their engagement to the Bill S-211 Remediation,0,0,0,0,0,0,0,1,0,0,0
SID_224,2240,Non-compliance may result in termination of the business relationship (Supplier),0,0,0,0,0,0,0,0,1,0,0
SID_224,2241,Reference to the Remediation Policy,0,0,0,0,0,0,0,0,0,0,0
SID_224,2242,Training,0,0,0,0,0,0,0,0,0,0,0
SID_224,2243,"Annual and ongoing training in the review of company policies, including awareness campaigns",0,0,0,0,0,0,0,1,0,0,0
SID_224,2244,Key Performance Indicators (KPIs) Quality Department,0,0,0,0,0,0,0,0,0,0,0
SID_224,2245,The Quality Department has measures in place with a monthly KPI containing a score card to ensure the supplier policy is effective,0,0,0,0,0,0,0,0,0,1,0
SID_224,2246,Human Resources Department,0,0,0,0,0,0,0,0,0,0,0
SID_224,2247,Regular meetings with staff and their supervisors,0,0,0,0,0,0,0,0,0,0,0
SID_224,2248,Employee engagement surveys,0,0,0,0,0,0,0,0,0,1,0
SID_224,2249,Absenteeism Rate,0,0,0,0,0,0,0,0,0,0,0
SID_224,2250,Turnover Ratio,0,0,0,0,0,0,0,0,0,0,0
SID_227,2631,2023 Forced Labor Report,0,0,0,0,0,0,0,0,0,0,0
SID_227,2632,2023 Forced Labor Report Table of Contents Introduction,0,0,0,0,0,0,0,0,0,0,0
SID_227,2633,Steps to Prevent and Reduce Risks of Forced Labour and Child Labour,0,0,0,0,0,0,0,0,0,0,0
SID_227,2634,"Structure, Activities and Supply Chains",0,0,0,0,0,0,0,0,0,0,0
SID_227,2635,"Governance, Policies and Due Diligence",0,0,0,0,0,0,0,0,0,0,0
SID_227,2636,Oversight,0,0,0,0,0,0,0,0,0,0,0
SID_227,2637,Policies,0,0,0,0,0,0,0,0,0,0,0
SID_227,2638,Supplier Policy,0,0,0,0,0,0,0,0,0,0,0
SID_227,2639,Code of Business Conduct and Ethics,0,0,0,0,0,0,0,0,0,0,0
SID_227,2640,Whistleblower Protections,0,0,0,0,0,0,0,0,0,0,0
SID_227,2641,Additional Due Diligence Measures,0,0,0,0,0,0,0,0,0,0,0
SID_227,2642,Assessing and Managing Our Risk,0,0,0,0,0,0,0,0,0,0,0
SID_227,2643,Remediation Measures,0,0,0,0,0,0,0,0,0,0,0
SID_227,2644,Training,0,0,0,0,0,0,0,0,0,0,0
SID_227,2645,Assessment of Efficiency,0,0,0,0,0,0,0,0,0,0,0
SID_227,2646,"Introduction This report (the Report) is produced by The Lion Electric Company (Lion Electric or the Company or our or we) for the financial year ended December 31, 2023 (the Reporting Period) and sets out the steps taken to prevent and reduce the risk that forced labour or child labour is used at any step of the production of goods, in Canada or elsewhere, or of goods imported into Canada by the Company",0,0,0,0,0,0,0,0,0,0,0
SID_227,2647,This Report constitutes the first report prepared by the Company pursuant to the Fighting Against Forced Labour and Child Labour in Supply Chains Act (Canada) (the Act) and the California Transparency in Supply Chains Act,0,0,0,0,0,0,0,0,0,0,0
SID_227,2648,"Note that while Company is the only entity within the Companys corporate group required to file a report under the Act, the infor- mation provided herein generally applies to all entities the Company controls",0,0,0,1,0,0,0,0,0,0,0
SID_227,2649,"2023 Forced Labor Report Steps to Prevent and Reduce Risks of Forced Labour andChild Labour As a responsible company and corporate citizen, we are dedicated to acting ethically and conducting our affairs with integrity, honesty, fairness, and professionalism",0,0,0,0,0,0,0,0,0,0,0
SID_227,2650,"In general terms, we took the following steps during the Reporting Period, to prevent and reduce the risk of forced labour or child labour in our activities and supply chains",0,0,0,0,0,0,0,0,0,0,0
SID_227,2651,"implemented a Supplier Policy, which includes, among others, requirements aimed at monitoring and preventing forced labour or child labour risks in our supply chains",0,0,0,0,0,0,0,1,0,0,0
SID_227,2652,"updated our model supply agreement, which now requires our new suppliers, or those entering into new commitments with us, to adhere to our Supplier Policy",0,0,0,0,0,0,0,1,0,0,0
SID_227,2653,"conducted due diligence on certain potential suppliers before entering into contracts, taking into account various criteria including forced labour or child labour risks",0,0,0,0,0,0,0,1,0,0,0
SID_227,2654,Details of the above actions are set out in this Report,0,0,0,0,0,0,0,0,0,0,0
SID_227,2655,"2023 Forced Labor Report Structure, Activities and Supply Chains The Company is incorporated under the Business Corporations Act (Quebec)",0,0,0,1,0,0,0,0,0,0,0
SID_227,2656,The Companys common shares are listed on the New York Stock Exchange and the Toronto Stock Exchange under the symbol LEV,0,0,0,0,0,0,0,0,0,0,0
SID_227,2657,"The Companys head and registered office is located at 921 chemin de la Riviere-du-Nord, Saint-Jerome, Quebec, Canada, J7Y 5G2",0,0,0,1,0,0,0,0,0,0,0
SID_227,2658,"Lion Electrics business focuses on the design, development, manufacturing, and distribution of all-electric medium and heavy- duty urban vehicles (EV)",0,0,0,0,1,0,0,0,0,0,0
SID_227,2659,"Each Lion Electric vehicle is purpose-built for electric and entirely designed and assembled in-house, with its own chassis, truck cabin or bus body, proprietary battery technology with modular energy capacity and Lion software integration",0,0,0,0,1,0,0,0,0,0,0
SID_227,2660,"For certain specialized truck applications, Lion Electric has also established partnerships and other relationships with third-party suppliers to enable it to offer to its clients a variety of vehicle configurations, upfit equipment options and applications which range from classic boxes for box trucks to other specialized applications such as all-electric ambulances and utility trucks",0,0,0,0,0,1,0,0,0,0,0
SID_227,2661,"Since 2023, Lion Electric manufactures its own battery modules and packs that integrate battery cells sourced from third-party suppliers",0,0,0,0,1,1,0,0,0,0,0
SID_227,2662,"Lion Electric also complements its product offering with various services available on site at Lion Electrics Experience Centers including sales support, full-service training, charging infrastructure assistance and maintenance support",0,0,0,0,1,0,0,0,0,0,0
SID_227,2663,"As of April 18, 2024, the Company had approximately 1,150employees in Canada and the United States across all functions, including manufacturing, vehicle research & development, sales & marketing, service, corporate andadministrative",0,0,0,1,1,0,0,0,0,0,0
SID_227,2664,"Lion Electrics products are available to purchase in Canada and in the United States and are distributed by truck and rail, either directly to Lion Electrics customers or to the third-party upfitters Lion Electric partners with",0,0,0,0,1,0,0,0,0,0,0
SID_227,2665,"Lion Electric has adopted a sales model that is generally based on direct-to-customer sales tailored for EVs, thereby generally avoiding reliance on third-party dealerships whenever possible",0,0,0,0,1,0,0,0,0,0,0
SID_227,2666,Lion Electrics products are manufactured in Canada and the United States,0,0,0,0,1,0,0,0,0,0,0
SID_227,2667,"The Company has a vehicle manufacturing facility located in Saint-Jerome, Quebec, where a majority of the vehicles sold by the Company are produced, and a manufacturing facility located in Joliet, Illinois to address the increasing demand for Made in America zero-emission vehicles",0,0,0,0,1,0,0,0,0,0,0
SID_227,2668,"Lion Electric also has a battery plant and Innovation Center situated in Mirabel, Quebec, which is currently being used for various purposes such as a testing and certification center for vehicles and batteries, a pre-delivery in- spection site, a showroom and delivery center, and as warehousing space, in order to leverage space available and optimize operational efficiency",0,0,0,0,1,0,0,0,0,0,0
SID_227,2669,"Finally, Lion Electric has additional facilities across Canada and the United States which mainly serve as Lion Electrics Experience Centers strategically located in key markets",0,0,0,0,1,0,0,0,0,0,0
SID_227,2670,"Lion Electrics supply chain consists of suppliers provi ding battery cells, battery packs, modules, vehicle parts and components, and raw materials such as aluminum, steel, composite, non-ferrous metals (such as copper) as well as other materials and minerals used to manu- facture lithium-ion batteries and certain other parts and components of Lion Electrics vehicles",0,0,0,0,0,1,0,0,0,0,0
SID_227,2671,"In certain cases, Lion Electric has entered into long-term contractual arrangements with suppliers with respect to the supply of certain key components of its vehicles, including, lithium-ion batteries and cells",0,0,0,0,0,1,0,0,0,0,0
SID_227,2672,The Company strives to obtain components from multiple sources whenever possible,0,0,0,0,0,0,0,0,0,0,0
SID_227,2673,"However, some of the components used in Lion Electrics vehicles, including key battery systems components, are purchased from a single source sup- plier or limited source suppliers",0,0,0,0,0,1,0,0,0,0,0
SID_227,2674,"Lion Electric currently does business with approximately 1,600 direct suppliers located in 17 countries",0,0,0,0,0,1,0,0,0,0,0
SID_227,2675,The majority of Lion Electrics suppliers are located in Canada and the United States,0,0,0,0,0,0,0,0,0,0,0
SID_227,2676,"2023 Forced Labor Report Governance, Policies and Due Diligence Processes Oversight Lion Electrics board of directors (the Board) is respon- sible for the overall stewardship of the Company and overseeing the management of the Companys business and affairs",0,0,0,0,0,0,0,0,0,0,0
SID_227,2677,"The Board has delegated to its Nominating and Corporate Governance Committee oversight of sustainability and corporate social responsibility, inclu ding monitoring of the Companys environmental, social and governance (ESG) plan, practices, related policies, and disclosure with respect to same as well as moni- toring and ensuring compliance with the Companys Code of Business Conduct and Ethics (the Code)",0,0,0,0,0,0,0,1,0,0,0
SID_227,2678,"The Audit Committee and the Human Resources and Compensation Committee of the Board of Directors also oversee certain elements pertaining to ESG-related matters and disclosures, including assisting the Board with the monitoring of compliance with the Code",0,0,0,0,0,0,0,1,0,0,0
SID_227,2679,"For additional information regarding the Companys governance and ESG matters, PLEASE REFER TO OUR WEBSITE: ir.thelionelectric.com",0,0,0,0,0,0,0,0,0,0,0
SID_227,2680,"2023 Forced Labor Report Policies We are committed to responsible business conduct and human rights protection and to acting ethically and with integrity in all our business dealings, and we strive to require the same from our supply chain partners",0,0,0,0,0,0,0,0,0,0,0
SID_227,2681,"In support of such commitment, Lion Electric has put in place several codes and policies that address international human rights standards, including the risk of forced and child labour in its supply chain",0,0,0,0,0,0,0,0,0,0,0
SID_227,2682,These codes and policies are reviewed annually by theCompany,0,0,0,0,0,0,0,0,0,1,0
SID_227,2683,Supplier Policy The Supplier Policy of the Company (the Supplier Policy) sets standards of ethical conduct which Lion Electric requires of its suppliers when they do business with or on behalf of Lion Electric,0,0,0,0,0,0,0,1,0,0,0
SID_227,2684,"The Supplier Policy details our expectations of suppliers in respect of hu- man rights, labour, employment practices, integrity and business ethics, and more",0,0,0,0,0,0,0,1,0,0,0
SID_227,2685,"Notably, the Supplier Policy specifically includes provisions prohibiting child labour and forced labour, and requires our suppliers to comply with specific hiring and employment practices that are aimed at promoting fair and ethical work conditions",0,0,0,0,0,0,0,1,0,0,0
SID_227,2686,"The Supplier Policy further requires suppliers to identify risks and actual adverse human rights impacts related to their activities and take appropriate steps to reduce such risks and remedy any impact directly caused, or contributed to, by their activities or through business relationships",0,0,0,0,0,0,0,1,0,0,0
SID_227,2687,"While we require our suppliers to implement the Supplier Policys requirements in a manner that is both appro- priate and proportional to the nature and scale of their business, as well as the goods and services they provide, we expect them to reflect these requirements in their own supply chains and go beyond legal compliance to advance in social and environmental responsibility and business ethics",0,0,0,0,0,0,0,1,0,0,0
SID_227,2688,"We require our new suppliers, or those or those en- tering into new commitments with us, to contractually adhere to, and comply with, the Supplier Policy, either Governance, Policies and Due Diligence Processes through a standalone certification or through our model supply agreement",0,0,0,0,0,0,0,1,0,0,0
SID_227,2689,"Our model supply agreement further includes a right for Lion Electric to perform audits, which may include requests for information, site visits, employee interviews and review of records",0,0,0,0,0,0,0,1,0,0,0
SID_227,2690,"The Supplier Policy includes a mechanism for anyone who believes that a supplier has engaged in illegal, unethical or otherwise improper conduct, or conducted any other activity in violation of the Supplier Policy to report such conduct using LionElectrics Whistleblower Line",0,0,0,0,0,0,0,1,0,0,0
SID_227,2691,"Lion Electric strongly encourages anyone witnessing such practices to speak up and demands that suppliers prohibit any retaliation against any person for reporting, in good faith, contraventions of the Supplier Policy or for filing a complaint or testifying, assisting, or partici- pating in any manner in any investigation, proceeding, or hearing conducted by a government enforcement agency",0,0,0,0,0,0,0,1,0,0,0
SID_227,2692,"If the expectations or requirements of the Supplier Policy are not met by our suppliers, the business relationships may be reviewed, and corrective action pursued, or alternatively, terminated",0,0,0,0,0,0,0,0,1,0,0
SID_227,2693,"2023 Forced Labor Report Policies Whistleblower Protections We have established robust whistleblower procedures, through our Whistleblower Policy, our Supplier Policy and our Code, all of which contain provisions encou raging anyone to report wrong-doings or suspected wrong-doings confidentially and anonymously (if so desired) without fear of victimization, subsequent discrimination, or disadvantage",0,0,0,0,0,0,0,0,1,0,0
SID_227,2694,"These policies offer several methods for reporting violations, including our Human Resources and Legal departments, and a confidential Whistleblower Line available on our website",0,0,0,0,0,0,0,0,1,0,0
SID_227,2695,"Lion Electric is committed to deal with any report expeditiously, investigate thoroughly and if necessary, take remedial measures in a timely manner",0,0,0,0,0,0,0,0,1,0,0
SID_227,2696,Lion Electric will also further examine and implement the means of ensuring that such wrongdoings can be prevented infuture,0,0,0,0,0,0,0,0,0,0,0
SID_227,2697,"Additional Due Diligence Measures To effectively manage risks associated with its supply chain, including risks related to forced labour and child labour, Lion Electric employed the following measures",0,0,0,0,0,0,0,1,0,0,0
SID_227,2698,"Completing due diligence on key potential suppliers based on publicly available information and due diligence requests, including manufacturing plans and country of origin information",0,0,0,0,0,0,0,1,0,0,0
SID_227,2699,"Negotiating strong contractual provisions with our suppliers, including adherence to the Supplier Policy and audit rights (allowing us to perform, as needed, independent or unannounced audits); and",0,0,0,0,0,0,0,1,0,0,0
SID_227,2700,Performing site visits of certain of our new and current suppliers which allow individuals conducting these visits to report on business practices and quality standards,0,0,0,0,0,0,0,1,0,0,0
SID_227,2701,"Governance, Policies and Due Diligence Processes Code of Business Conduct and Ethics The Code applies to all directors, officers, and emplo yees of the Company without exception",0,0,0,0,0,0,0,1,0,0,0
SID_227,2702,"All business partners, contractors, consultants, service providers and suppliers of the Company are held, where appro- priate, to the standards of this Code to the same extent as employees of the Company and are expected to en- force policies and/or practices that are consistent with the Code, and all new suppliers, or those entering into new commitments with us, are expected to confirm, in writing, through their contract with Lion Electric or otherwise, that they agree to and will comply with the terms of the Code",0,0,0,0,0,0,0,1,0,0,0
SID_227,2703,Our Code provides a set of ethical standards to guide everyone to whom it applies and constitutes condi- tions of employment or engagement and continuing relationship with the Company,0,0,0,0,0,0,0,1,0,0,0
SID_227,2704,"The Code helps focus the Board and management of the Company on areas of ethical risk, provides guidance to the employees of the Company to help them recognize and deal with ethical issues, provides mechanisms to report unethical conduct through our Whistleblower Policy, and helps to foster a culture of honesty and accountability",0,0,0,0,0,0,0,1,0,0,0
SID_227,2705,"The Code details the guidelines of expected conduct in numerous areas including compliance with laws, rules and regulations",0,0,0,0,0,0,0,0,0,0,0
SID_227,2706,The Code is available on our website at ir.thelionelectric.com,0,0,0,0,0,0,0,0,0,0,0
SID_227,2707,"If the expectations or requirements of the Code are not met by our suppliers, the business relationships may be reviewed, and corrective action pursued, or alternatively, terminated",0,0,0,0,0,0,0,0,1,0,0
SID_227,2708,2023 Forced Labor Report Assessing and Managing Our Risk Remediation Measures Training Assessment of Efficiency We use a risk-based approach to assess and manage risks of forced labour and child labour in our supply chain,0,0,0,0,0,0,0,1,0,0,0
SID_227,2709,"When there are doubts that one of our suppliers or potential suppliers is not respecting our policies or commitments, the supplier will be further investigated in order to clarify any concerns and act where appropriate",0,0,0,0,0,0,0,0,1,0,0
SID_227,2710,"We remain committed to further developing and conti nuously refining our policies, procedures, and programs as we learn more about the risks in our supply chain and ways to mitigate them",0,0,0,0,0,0,0,0,0,0,0
SID_227,2711,"To assess the effectiveness of actions related to ensuring that forced labour and child labour are not being used in our business and supply chains, we commit to",0,0,0,0,0,0,0,1,0,0,0
SID_227,2712,monitor and annually review compliance with theAct and report the results internally to the LionElectric management team; and,0,0,0,0,0,0,0,0,0,1,0
SID_227,2713,regularly review the content of the Code and Supplier Policy to ensure it is current and fit forpurpose,0,0,0,0,0,0,0,0,0,1,0
SID_227,2714,Lion Electric is committed to providing remediation for any confirmed instances of forced or child labour in its supply chain should such an event arise,0,0,0,0,0,0,0,0,1,0,0
SID_227,2715,"During the Reporting Period, Lion Electric did not identify, nor was it alerted to, any instances of forced labour or child labour in its supply chain",0,0,0,0,0,0,1,0,0,1,0
SID_227,2716,"Therefore, there has not been any opportunities to provide remediation during the Reporting Period",0,0,0,0,0,0,0,0,1,0,0
SID_227,2717,"Although the Company does not currently provide training to employees on forced labour or child labour, every employee and director of Lion Electric is required to sign a certification that they have read and clearly understood the Code",0,0,0,0,0,0,0,1,0,0,0
SID_227,2718,All employees are further re- quired to review and confirm compliance with the Code at least once per year,0,0,0,0,0,0,0,1,0,0,0
SID_227,2719,"Additionally, we intend to offer targeted training sessions addressing forced labour and child labour to relevant employees in the future",0,0,0,0,0,0,0,1,0,0,0
SID_227,2720,"Any failure by an employee to respect the Code may result in disciplinary action and sanctions up to and including dismissal, and certain failures to respect the Code may result in legal action",0,0,0,0,0,0,0,0,1,0,0
SID_227,2721,"As discussed in this Report, Lion Electric has taken steps during the Reporting Period aimed at reducing the risk that forced labour or child labour will be used in our activities or supply chains",0,0,0,0,0,0,0,0,0,0,0
SID_227,2722,We have not taken any measures yet to assess the efficiency of these steps,0,0,0,0,0,0,0,0,0,1,0
SID_227,2723,We are committed to continuously improving our approach to human rights including forced labour and child labour issues,0,0,0,0,0,0,0,0,0,0,0
SID_227,2724,"In that respect, we intend to iden- tify key performance indicators to help us measure the progress of the actions we are taking",0,0,0,0,0,0,0,0,0,0,0
SID_227,2725,"Despite our efforts to take actions to ensure our supply chain is free of any forced labour or child labour, there may nonetheless remain a risk of forced labour or child labour within our global supply chain, specifically when it comes to indirect suppliers where Lion Electric has little control or visibility",0,0,0,0,0,0,1,0,0,0,0
SID_227,2726,"To address this potential risk, Lion Electric expects its business partners and suppliers to uphold the standards and principals outlined in the Supplier Policy within their operations and within their own supply chain",0,0,0,0,0,0,0,0,0,0,0
SID_227,2727,"During the Reporting Period, we have identified certain countries in which some of our suppliers are located that are considered to be at greater risk of forced labour or child labour being used",0,0,0,0,0,0,1,0,0,0,0
SID_227,2728,"Whenever reasonably possible, we make efforts to limit, or reduce, as applicable, our supply chain exposure to these countries, in addition to completing enhanced due diligence on suppliers located in these countries",0,0,0,0,0,0,0,0,0,0,0
SID_227,2729,"2023 Forced Labor Report 2024-05-14 thelionelectric.com This Report was approved on May 15, 2024 by the Board of Directors of The Lion Electric Company pursuant to subparagraph11(4)(a) of the Act",1,0,0,0,0,0,0,0,0,0,0
SID_227,2730,"In accordance with the requirements of the Act, and in particular section11 thereof, I attest that I have reviewed the information contained in the Report for the entity listed above",0,0,0,0,0,0,0,0,0,0,0
SID_227,2731,"Based on my knowledge, and having exer- cised reasonable diligence, I attest that the information in the Report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above",0,0,0,0,0,0,0,0,0,0,0
SID_227,2732,"Marc Bdard Chief Executive Officer and Founder May 15, 2024 I have the authority to bind The Lion Electric Company",0,1,0,0,0,0,0,0,0,0,0
SID_232,2919,Robert Half Canada Inc - Modern Slavery Report 2023 1 Modern Slavery Report 2023 Robert Half Canada Inc,0,0,0,0,0,0,0,0,0,0,0
SID_232,2920,"This Modern Slavery Report (the Report) addresses the period from January 1, 2023 to December 31, 2023 and has been prepared in compliance with the Fighting Against Forced Labour and Child Labour in Supply Chains Act (Canada) (the Act)",0,0,0,0,0,0,0,0,0,0,0
SID_232,2921,"This Report is made on behalf of Robert Half Canada Inc (RH Canada, we, us or our)",0,0,0,0,0,0,0,0,0,0,0
SID_232,2922,A French version of this Report may be requested from RH Canada by emailing rhcomplianceandethics@roberthalf.com,0,0,0,0,0,0,0,0,0,0,0
SID_232,2923,"Introduction Forced labour and child labour, each as defined in the Act, are crimes and serious violations of human rights",0,0,0,0,0,0,0,0,0,0,0
SID_232,2924,"RH Canada strives to act ethically and with integrity in all our business dealings and relationships, including implementing policies and procedure with the aim of identifying and preventing forced labour and child labour in our supply chain",0,0,0,0,0,0,0,0,0,0,0
SID_232,2925,This Report sets out the steps we have taken during the fiscal year 2023 to prevent and reduce the risk that forced labour or child labour is used at any step in the production of goods imported into Canada by RH Canada,0,0,0,0,0,0,0,0,0,0,0
SID_232,2926,"We are committed to providing transparency in our business and addressing modern slavery risks in our supply chains, consistent with our disclosure obligations under the Act",0,0,0,0,0,0,0,0,0,0,0
SID_232,2927,"We expect the same standards and commitment from our suppliers, contractors and other third parties",0,0,0,0,0,0,0,0,0,0,0
SID_232,2928,"Our Business RH Canada, a company incorporated under the laws of British Columbia, is a provider of talent solutions and business consulting solutions under the Robert Half and Protiviti brands in multiple provinces in Canada",0,0,0,1,1,0,0,0,0,0,0
SID_232,2929,"We are a member of the Robert Half corporate group, owned by the ultimate parent company Robert Half Inc (NYSE: RHI) which has its corporate headquarters operations in Menlo Park and San Ramon, California, USA",0,0,0,1,0,0,0,0,0,0,0
SID_232,2930,"Our branch offices in Canada provide talent solutions for permanent, contract and temporary placements in the following areas",0,0,0,0,1,0,0,0,0,0,0
SID_232,2931,Finance & Accounting,0,0,0,0,1,0,0,0,0,0,0
SID_232,2932,Creative and Marketing,0,0,0,0,1,0,0,0,0,0,0
SID_232,2933,Technology,0,0,0,0,1,0,0,0,0,0,0
SID_232,2934,"Administrative & Customer Support, and",0,0,0,0,1,0,0,0,0,0,0
SID_232,2935,Legal,0,0,0,0,1,0,0,0,0,0,0
SID_232,2936,"We also provide consulting and managed solutions in the areas of finance, technology, operations, data, analytics, digital, marketing, legal, HR, governance, risk and internal audit through the Protiviti brand",0,0,0,0,1,0,0,0,0,0,0
SID_232,2937,"Given our industry and operations, we do not have an extensive supply chain network",0,0,0,0,0,0,0,0,0,0,0
SID_232,2938,We do not manufacture goods or handle raw materials,0,0,0,0,1,0,0,0,0,0,0
SID_232,2939,"Our supply chains include, among others: office supplies including stationery; IT hardware and software; cleaning and catering services; advertising and print services; office build out and building maintenance services; and professional services such as those provided by our external financial auditors",0,0,0,0,0,1,0,0,0,0,0
SID_232,2940,"Most procurement activities are centralized out of headquarters in the United States and we substantially rely on our parent company, Robert Half Inc, for the purpose of DocuSign Envelope ID: 93141219-7BAA-42E7-936D-30E5C0F3954B",0,0,0,1,0,1,0,0,0,0,0
SID_232,2941,Robert Half Canada Inc - Modern Slavery Report 2023 2 managing our supply chain,0,0,0,0,0,0,0,0,0,0,0
SID_232,2942,"For example, Robert Half Inc is our supplier for certain technology and related equipment used by us in Canada",0,0,0,0,0,1,0,0,0,0,0
SID_232,2943,We source our other goods and services primarily from suppliers in Canada and the United States,0,0,0,0,0,1,0,0,0,0,0
SID_232,2944,"Our Policies Corporate Governance Policies Robert Half Inc.s Code of Business Conduct and Ethics (the Code of Conduct) sets out basic principles of ethics and integrity to guide all employees, agents and representatives of the Robert Half corporate group, including RH Canada and its employees, agents and representatives",0,0,0,0,0,0,0,0,0,0,0
SID_232,2945,"Robert Half Inc has formally set out its position on, and commitment to, human rights for all in its Global Human Rights Policy (the Global Human Rights Policy), including its firm stances against human trafficking, human-trafficking related activities, slavery and child labour",0,0,0,0,0,0,0,1,0,0,0
SID_232,2946,"Accordingly, we prohibit",0,0,0,0,0,0,0,1,0,0,0
SID_232,2947,using any type of slavery or forced labour in the performance of any work,0,0,0,0,0,0,0,1,0,0,0
SID_232,2948,engaging in any form of human trafficking for the performance of any work; and,0,0,0,0,0,0,0,1,0,0,0
SID_232,2949,"destroying, concealing, confiscating or otherwise denying access to any temporary or full-time employees documents relating to immigration or work authorization issued by any government entity or issuing authority",0,0,0,0,0,0,0,1,0,0,0
SID_232,2950,We seek relationships with suppliers whose values and principles align with ours,0,0,0,0,0,0,0,0,0,0,0
SID_232,2951,Robert Half Inc.s Supplier Code of Conduct (the Supplier Code of Conduct) outlines the expectations of suppliers in North America,0,0,0,0,0,0,0,0,0,0,0
SID_232,2952,"As a condition to doing business with us, suppliers must comply with the Supplier Code of Conduct, Global Human Rights Policy and Code of Conduct",0,0,0,0,0,0,0,1,0,0,0
SID_232,2953,"Due Diligence and Risk Reduction & Mitigation We seek to work with suppliers that can meet our business requirements for scale, quality and service levels; bring value through competitive pricing and innovation; and align with our values and principles",0,0,0,0,0,0,0,0,0,0,0
SID_232,2954,We expect third parties with which we work to adhere to business principles and values similar to our own and to comply with all applicable laws and regulations,0,0,0,0,0,0,0,0,0,0,0
SID_232,2955,"To that end, we have embedded responsible business conduct into our policies and management systems",0,0,0,0,0,0,0,0,0,0,0
SID_232,2956,See above Section 3,0,0,0,0,0,0,0,0,0,0,0
SID_232,2957,Our Policies for more information on relevant policies and the section below for more information regarding due diligence steps and risk mitigation,0,0,0,0,0,0,0,0,0,0,0
SID_232,2958,We acknowledge that purchasing goods/services could involve the risk of forced or child labour in our supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_232,2959,"In order to mitigate this risk, we have implemented measures including the following",0,0,0,0,0,0,0,0,0,0,0
SID_232,2960,"In fiscal year 2023, strategic and critical suppliers were assessed on a variety of factors which may include ethics and compliance, business continuity, and environmental, social and governance matters, which include human rights and labour",0,0,0,0,0,0,0,1,0,0,0
SID_232,2961,"In fiscal year 2023, Robert Half Inc.s strategic and critical suppliers in the United States were also required to agree to comply with the Supplier Code of Conduct, or provide their own code of conduct or similar document addressing these risks and concerns",0,0,0,0,0,0,0,1,0,0,0
SID_232,2962,"During 2024, Robert Half Inc began applying this requirement to a larger population of new and existing suppliers in the US based on the associated risks and may consider further expanding the scope as appropriate",0,0,0,0,0,0,0,1,0,0,0
SID_232,2963,"Contractual terms in the majority of our supplier contracts include, as appropriate, contractual obligations on the supplier to comply with all applicable human rights and labour laws and regulations governing the industries and regions in which we and they DocuSign Envelope ID: 93141219-7BAA-42E7-936D-30E5C0F3954B",0,0,0,0,0,0,0,1,0,0,0
SID_232,2964,Robert Half Canada Inc - Modern Slavery Report 2023 3 operate and/or termination clauses which may be triggered upon failure to comply or breach of relevant terms,0,0,0,0,0,0,0,1,0,0,0
SID_232,2965,"Any violation of the provisions of the Global Human Rights Policy with respect to forced or child labour is subject to removal from the contract, reduction in benefits, and/or disciplinary action up to and including termination, subject to applicable law",0,0,0,0,0,0,0,0,1,0,0
SID_232,2966,"Suppliers, employees or any other concerned parties may report concerns or potential issues using the Robert Half Ethics and Compliance Online Reporting Tool",0,0,0,0,0,0,0,1,0,0,0
SID_232,2967,"Assessing Our Risk As a services-based company, we consider our supply chains to be low-risk with respect to modern slavery",0,0,0,0,1,0,1,0,0,0,0
SID_232,2968,"Given the nature of our business, we do not have an extensive supply chain network",0,0,0,0,0,0,0,0,0,0,0
SID_232,2969,See above Section 1,0,0,0,0,0,0,0,0,0,0,0
SID_232,2970,Our Business,0,0,0,0,0,0,0,0,0,0,0
SID_232,2971,The risk of forced and child labour being present in our supply chains increases in the lower tiers of the supply chain where may have limited visibility,0,0,0,0,0,0,1,0,0,0,0
SID_232,2972,"Nonetheless, we endeavour to manage and limit these risks by engaging suppliers based primarily in the United States and Canada, both of which are reported to have a low prevalence of forced labour, according to the Global Slavery Index",0,0,0,0,0,1,1,0,0,0,0
SID_232,2973,"If our due diligence processes establish that risks related to forced and child labour exist, we would conduct further diligence to assess such risk to determine if risk mitigation or remediation is required",0,0,0,0,0,0,0,1,0,0,0
SID_232,2974,We are open to exploring the possibility of implementing additional assessment procedures and mechanisms moving forward,0,0,0,0,0,0,0,0,0,0,0
SID_232,2975,"Our Commitments We prohibit our employees, temporary employees, contractors, subcontractors, agents, and vendors from engaging in any form of human trafficking, slavery, or use of child labour in the performance of any work",0,0,0,0,0,0,0,1,0,0,0
SID_232,2976,"We expect our suppliers to adhere to these same standards, create and support a sustainable procurement function with regards to environmental, human rights and labour, and business ethics and governance",0,0,0,0,0,0,0,0,0,0,0
SID_232,2977,"During 2023, we took a number of steps, including due diligence and other measures, to prevent and reduce risk that forced labour or child labour is used in the production of goods we purchased or imported into Canada as described in Section 3",0,0,0,0,0,0,0,0,0,0,0
SID_232,2978,Our Policies - Due Diligence and Risk Reduction & Mitigation above,0,0,0,0,0,0,0,0,0,0,0
SID_232,2979,"Remediation Measures In 2023, no incidents of forced or child labour were reported within RH Canada",0,0,0,0,0,0,0,0,0,1,0
SID_232,2980,"As a result, remediation measures did not need to be taken to correct an incident of modern slavery or to compensate for loss of income to vulnerable families",0,0,0,0,0,0,0,0,0,0,0
SID_232,2981,"However, the Code of Conduct, Supplier Code of Conduct, Global Human Rights Policy, and Robert Half Ethics and Compliance Online Reporting Tool provide a framework for employees to report unethical conduct, including concerns related to forced or child labour",0,0,0,0,0,0,0,1,0,0,0
SID_232,2982,"Training Every new employee must, upon joining, and all of our employees, annually, are required to complete mandatory training on the Code of Conduct and re-certify that they have read and understand key policies, including the Code of Conduct and Global Human Rights Policy",0,0,0,0,0,0,0,1,0,0,0
SID_232,2983,These trainings include information on how to report misconduct via the Robert Half Ethics and Compliance Online Reporting Tool,0,0,0,0,0,0,0,1,0,0,0
SID_232,2984,"As these trainings do not currently include dedicated training on forced and child labour, we may need to assess whether and how the curriculum and materials may require amending or supplementing to better manage our business and supply chain risks related to the potential risks of the use of forced and child labour",0,0,0,0,0,0,0,1,0,0,0
SID_232,2985,DocuSign Envelope ID: 93141219-7BAA-42E7-936D-30E5C0F3954B,0,0,0,0,0,0,0,0,0,0,0
SID_232,2986,Robert Half Canada Inc - Modern Slavery Report 2023 4,0,0,0,0,0,0,0,0,0,0,0
SID_232,2987,"Our Progress and Effectiveness Although we have put in place measures to prevent and reduce the risk of forced and child labour in our business and supply chains, we have not yet implemented a system to assess the effectiveness of these measures",0,0,0,0,0,0,0,0,0,1,0
SID_232,2988,"However, if relevant reports or concerns come to our attention through the Robert Half Ethics and Compliance Online Reporting Tool or other channels, whether from employees, clients, candidates, members of the public, or law enforcement agencies, that information will be reviewed and taken into consideration in the review of our policies and procedures related to forced and child labour, which may include the development and implementation of a system to assess effectiveness, if appropriate",0,0,0,0,0,0,0,0,0,1,0
SID_232,2989,"Approval & Signature In accordance with paragraph 11(4)(a) of the Act, this Report was approved by Robert Half Canada Inc.s Board of Directors on ____________ and has been submitted to the Minister of Public Safety and Emergency Preparedness in Canada",1,0,0,0,0,0,0,0,0,0,0
SID_232,2990,This Report is also available on our company website at www.roberthalf.ca,0,0,0,0,0,0,0,0,0,0,0
SID_232,2991,"In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in this Report for RH Canada",0,0,0,0,0,0,0,0,0,0,0
SID_232,2992,"Based on my knowledge, and having exercised reasonable diligence, I attest that the information in this Report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above",0,0,0,0,0,0,0,0,0,0,0
SID_232,2993,Michael C,0,1,0,0,0,0,0,0,0,0,0
SID_232,2994,"Buckley Director, ____________ I have the authority to bind Robert Half Canada Inc DocuSign Envelope ID: 93141219-7BAA-42E7-936D-30E5C0F3954B 5/24/2024 5/24/2024",0,1,0,0,0,0,0,0,0,0,0
SID_236,3252,"600 3rd Avenue SW Calgary, Alberta T2P 0G5 May 21, 2024",0,0,0,0,0,0,0,0,0,0,0
SID_236,3253,MODERN SLAVERY REPORT 2023 HIGHWOOD ASSET MANAGEMENT LTD,0,0,0,0,0,0,0,0,0,0,0
SID_236,3254,"This Modern Slavery Report (the Report) addresses the period from January 1, 2023, to December 31, 2023, and has been prepared in compliance with Bill S-211, an act to enact the Fighting Against Forced Labour and Child Labour in Supply Chains (Canada) (the Act)",0,0,0,0,0,0,0,0,0,0,0
SID_236,3255,This report is made on behalf of Highwood Asset Management Ltd (Highwood or the Company),0,0,0,0,0,0,0,0,0,0,0
SID_236,3256,Introduction: Highwood understands the importance of preventing and reducing the risk of forced labour and child labour in our supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_236,3257,"Forced labour and child labour, as defined in the Act, are serious crimes and violations of human rights",0,0,0,0,0,0,0,0,0,0,0
SID_236,3258,Highwood recognizes the important role the Company has in ensuring our operations and supply chain adhere to the upmost ethical standards,0,0,0,0,0,0,0,0,0,0,0
SID_236,3259,This Report described the steps Highwood has taken in 2023 to prevent and reduce the risk that forced labour or child labour is used at any step in the production of goods in Canada or elsewhere by Highwood or of any good imported into Canada by Highwood or third parties supplying the Company,0,0,0,0,0,0,0,0,0,0,0
SID_236,3260,"Preventative measures taken to prevent and reduce the risk that forced labour or child labour is used at any step of the production of goods in Canada, or elsewhere by the entity of good imported into Canada by the entity: This section will summarize the steps the entity has taken during this previous financial year to prevent and reduce the risk that forced labour or child labour is used at any step of the production of goods in Canada or elsewhere by the entity or of goods imported into Canada by the entity",0,0,0,0,0,0,0,1,0,0,0
SID_236,3261,"These steps include, but are not limited to",0,0,0,0,0,0,0,0,0,0,0
SID_236,3262,"Developing due diligence policies and processes for identifying, addressing and prohibiting the use of forced labour and/or child labour in Highwoods activities and supply chains",0,0,0,0,0,0,0,1,0,0,0
SID_236,3263,Promoting the importance to all individuals with Highwood of preventing forced labour and child labour,0,0,0,0,0,0,0,1,0,0,0
SID_236,3264,Discussing with suppliers the policies and procedures that the suppliers have in place for identifying and prohibiting the used of forced labour and/or child labour in their activities and supply chains,0,0,0,0,0,0,0,1,0,0,0
SID_236,3265,"Reviewed documentation from third party experts who assessed the legislative frameworks to determine additional steps the Company should take to meet, or exceed, expectations",0,0,0,0,0,0,0,1,0,0,0
SID_236,3266,Highwood is committed to conducting business at the highest levels of ethical business practice and conduct,0,0,0,0,0,0,0,0,0,0,0
SID_236,3267,"Structure, Activities and Supply Chains: Structure and Activities Highwood is an oil and gas company headquartered in Calgary, Alberta, Canada",0,0,0,1,1,0,0,0,0,0,0
SID_236,3268,Highwoods primary business is the exploration and development of our oil and gas properties in the Western Canadian Sedimentary Basis,0,0,0,0,1,0,0,0,0,0,0
SID_236,3269,"Highwood currently has properties located in Alberta, Saskatchewan and British Columbia",0,0,0,0,1,0,0,0,0,0,0
SID_236,3270,Highwoods current operations are primarily focused in the Brazeau and Wilson Creek areas located in Alberta,0,0,0,0,1,0,0,0,0,0,0
SID_236,3271,"Additional information regarding the corporate structure, operations, and the industry conditions related to Highwood is available in the Companys Annual Information Form (the AIF) for the year ended December 31, 2023",0,0,0,0,0,0,0,0,0,0,0
SID_236,3272,The AIF is available on the Companys website www.highwoodmgmt.com or on SEDAR+ www.sedarplus.com,0,0,0,0,0,0,0,0,0,0,0
SID_236,3273,"Supply Chain Highwoods supply chain includes businesses that supply goods and services to the Company, which includes several trusted vendors, suppliers, contractors and subcontractors (collectively the Suppliers) involved in procuring goods and services that are required for Highwood operations",0,0,0,0,0,1,0,0,0,0,0
SID_236,3274,"Highwood strives to build relationships with Suppliers who align with the Companys values and operate legally, ethically, and responsibly",0,0,0,0,0,0,0,0,0,0,0
SID_236,3275,Highwood has over 300 Suppliers that are engaged to provide goods and services to the Company,0,0,0,0,0,0,0,1,0,0,0
SID_236,3276,"The Suppliers Highwood obtains goods and services from are primarily local and adhere to regulations in Canada for oil and gas production, which are among the highest standards in the world",0,0,0,0,0,0,0,1,0,0,0
SID_236,3277,Highwood has not identified any forced labour or child labour in our activities and supply chains,0,0,0,0,0,0,1,0,0,0,0
SID_236,3278,Policies and Due Diligence Policies Highwoods corporate governance policies communicate our high values and expectations of ourselves and our Suppliers,0,0,0,0,0,0,0,0,0,0,0
SID_236,3279,"Highwood emphasized that we do not tolerate any form of forced labour or child labour at Highwood, nor with any of our Suppliers",0,0,0,0,0,0,0,0,0,0,0
SID_236,3280,"Highwoods staff and Suppliers all play a role in ensuring that we carry out our business activities in an ethical, legal, and responsible manner",0,0,0,0,0,0,0,0,0,0,0
SID_236,3281,We have an expectation that staff and Suppliers will uphold our corporate governance policies which are available on our website,0,0,0,0,0,0,0,0,0,0,0
SID_236,3282,Policies in place at Highwood include,0,0,0,0,0,0,0,0,0,0,0
SID_236,3283,"Code of Business Conduct and Ethics o Highwood is committed to conducting our business in an ethical, legal, and responsible manner",0,0,0,0,0,0,0,0,0,0,0
SID_236,3284,"Our Code of Business Conduct and Ethics is the building block of Highwoods policies and sets out guiding principles on professional conduct and establishes that in performing their job duties, Highwood employees should always act ethically, legally, and responsibly in the best interests of Highwood",0,0,0,0,0,0,0,0,0,0,0
SID_236,3285,Whistleblower Policy o Highwoods Whistleblower Policy provides a system for staff to report concerns regarding any wrongdoing without the fear of any repercussions,0,0,0,0,0,0,0,1,0,0,0
SID_236,3286,The Whistleblower Policy is intended to encourage and enable employees to raise serious concerns within Highwood,0,0,0,0,0,0,0,1,0,0,0
SID_236,3287,The Whistleblower Policy applies to all staff working for Highwood,0,0,0,0,0,0,0,1,0,0,0
SID_236,3288,"Furthermore, it is intended to provide a means for Suppliers, shareholders, etc to voice any concerns regarding Highwoods business conduct",0,0,0,0,0,0,0,1,0,0,0
SID_236,3289,Due Diligence,0,0,0,0,0,0,0,0,0,0,0
SID_236,3290,"Highwood expects all staff and all Suppliers that we work with to adhere to the core principles and values that Highwood abides by, and to comply with all applicable laws and regulations",0,0,0,0,0,0,0,0,0,0,0
SID_236,3291,Staff of Highwood all review Highwoods corporate governance policies and confirm in writing that they have read and understand the applicable policies,0,0,0,0,0,0,0,1,0,0,0
SID_236,3292,Highwood also takes steps to evaluate Suppliers to ensure their core principles and values adhere to the same levels as Highwood,0,0,0,0,0,0,0,0,0,0,0
SID_236,3293,"In addition, Highwood is continuously monitoring the supply chain and business relationships; identifying and assessing any potential gaps in our operations and policies; and providing training and raising awareness to staff and Suppliers to ensure they have an understanding of modern slavery and the impact it has",0,0,0,0,0,0,0,1,0,0,0
SID_236,3294,Assessing Highwoods Risk,0,0,0,0,0,0,0,0,0,0,0
SID_236,3295,"Overall, Highwood operates its business within Canada where there is a low risk of forced labour and child labour",0,0,0,0,1,0,1,0,0,0,0
SID_236,3296,"Highwoods workforce is largely comprised of office workers and highly skilled oil and gas field workers, and we believe there is low risk of force labour or child labour within our operations",0,0,0,0,1,0,1,0,0,0,0
SID_236,3297,"While Highwood operates in an area of low risk, we acknowledge that certain groups are particularly vulnerable to forced labour and child labour, including, but not limited to",0,0,0,0,0,0,1,0,0,0,0
SID_236,3298,Migrant workers,0,0,0,0,0,0,1,0,0,0,0
SID_236,3299,Contract or temporary workers,0,0,0,0,0,0,1,0,0,0,0
SID_236,3300,Ethnic and religious minorities; and,0,0,0,0,0,0,1,0,0,0,0
SID_236,3301,Young or student workers,0,0,0,0,0,0,1,0,0,0,0
SID_236,3302,"Highwood continuously seeks to identify any risk areas within our business and supply chain, and if any are found, mitigate the risk and address the issue",0,0,0,0,0,0,0,0,0,0,0
SID_236,3303,"We recognize our responsibility to ensure that forced labour and child labour are not used at any step of the production of goods, whether in Canada or elsewhere, by Highwood or within our supply chain",0,0,0,0,0,0,0,0,0,0,0
SID_236,3304,Below outlines just some of the actions Highwood has taken to address and mitigate these risks,0,0,0,0,0,0,0,1,0,0,0
SID_236,3305,Mapping our exploration and production activities (primarily in central Alberta),0,0,0,0,0,0,0,1,0,0,0
SID_236,3306,Monitoring our Suppliers and working with Suppliers with strong ethical reputations,0,0,0,0,0,0,0,1,0,0,0
SID_236,3307,Developing and implementing due diligence policies and procedures to identify and address any use of forced labour and/or child labour in the organizations activities and supply chains; and,0,0,0,0,0,0,0,1,0,0,0
SID_236,3308,Encourage staff and Suppliers to report any concerns or suspicions of forced labour or child labour,0,0,0,0,0,0,0,1,0,0,0
SID_236,3309,Remediation Measures The risk of force labour and child labour is low in Canada and no instances were found in Highwoods business activities in 2023,0,0,0,0,0,0,1,0,0,0,0
SID_236,3310,"As a result, Highwood has not taken any measures to remediate any forced labour or child labour",0,0,0,0,0,0,0,0,1,0,0
SID_236,3311,"In addition, Highwood has not identified any loss of income to vulnerable families resulting from measures taken to eliminate the use of forced labour or child labour",0,0,0,0,0,0,0,0,0,0,0
SID_236,3312,"Training and Awareness Highwood is committed to improving the training and awareness of our Staff to understand, identify and manage the risks of forced labour and child labour in our operations and across our supply chains",0,0,0,0,0,0,0,1,0,0,0
SID_236,3313,Staff at all levels are required to adhere to Highwoods Code of Business Conduct and Ethics policies and ensure it is understood and properly applied to their daily activities,0,0,0,0,0,0,0,1,0,0,0
SID_236,3314,"Every new staff member of Highwood must review and sign that they have read, understand and will abide by the Code of Business Conduct and Ethics",0,0,0,0,0,0,0,1,0,0,0
SID_236,3315,All staff are also informed of how to report wrongdoing under the Whistleblower policy and are encouraged to take initiative in reporting any concerns or suspicions of wrongdoing,0,0,0,0,0,0,0,1,0,0,0
SID_236,3316,We also commit to providing our staff with ongoing training opportunities to ensure our staff have the sufficient knowledge,0,0,0,0,0,0,0,0,0,0,0
SID_236,3317,"Assessing our Effectiveness Based on our review of our existing policies, practices, business activities, and areas we operate in, we believe the risk of forced labour or child labour in our operations or supply chain is low",0,0,0,0,0,0,1,0,0,0,0
SID_236,3318,We monitor compliance with our corporate policies on an ongoing basis,0,0,0,0,0,0,0,0,0,0,0
SID_236,3319,"While we have not had any significant concerns or complaints identified to date, we commit to reviewing and addressing any concerns or complaints that are potentially identified",0,0,0,0,0,0,0,0,0,1,0
SID_236,3320,"Approval and Attestation This Report was approved by Highwoods Board of Directors on May 21, 2024 and has been submitted to the Minister of Public Safety and Emergency Preparedness in Canada",1,0,0,0,0,0,0,0,0,0,0
SID_236,3321,"This Report is also available on our website at www.highwoodmgmt.com In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the Report",0,0,0,0,0,0,0,0,0,0,0
SID_236,3322,"Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the Report is true, accurate and complete in all material respects for the purposes of the Act, for 2023",0,0,0,0,0,0,0,0,0,0,0
SID_236,3323,I have the authority to bind Highwood Asset Management Ltd,0,0,0,0,0,0,0,0,0,0,0
SID_236,3324,"Greg Macdonald President & CEO Date: May 15, 2024",0,1,0,0,0,0,0,0,0,0,0
SID_236,3325,Advisories,0,0,0,0,0,0,0,0,0,0,0
SID_236,3326,Forward-Looking Information,0,0,0,0,0,0,0,0,0,0,0
SID_236,3327,"Certain statements contained in this report include statements which contain words such as anticipate, could, should, expect, seek, may, intend, likely, will, believe and similar expressions, statements relating to matters that are not historical facts, and such statements of our beliefs, intentions and expectations about development, results and events which will or may occur in the future, constitute forward-looking information within the meaning of applicable Canadian securities legislation and are based on certain assumptions and analysis made by us derived from our experience and perceptions",0,0,0,0,0,0,0,0,0,0,0
SID_236,3328,"Forward-looking information in this report includes, but is not limited to: the steps taken to prevent and reduce risks of forced and child labour; the implementation of policies in relation to forced labour and child labour; training provided to employees in respect of forced labour and child labour; business strategy and outlook; remediation measures in respect of forced labour or child labour; maintenance of existing supplier and partner relationships; supply channels; and other such matters",0,0,0,0,0,0,0,0,0,0,0
SID_236,3329,The foregoing factors are not exhaustive,0,0,0,0,0,0,0,0,0,0,0
SID_236,3330,"Actual results, performance, or achievements could differ materially from those expressed in, or implied by, this forward-looking information and, accordingly, no assurance can be given that any of the events anticipated by the forward-looking information will transpire or occur, or if any of them do so, what benefits will be derived there from",0,0,0,0,0,0,0,0,0,0,0
SID_236,3331,"Except as required by law, Highwood disclaims any intention or obligation to update or revise any forward-looking information, whether as a result of new information, future events or otherwise",0,0,0,0,0,0,0,0,0,0,0
SID_236,3332,The forward-looking information contained herein is expressly qualified by this cautionary statement,0,0,0,0,0,0,0,0,0,0,0
SID_240,3826,"2023 Supply Chains Act Annual Report This report constitutes the inaugural annual report (the Report) of Evans Adhesives Canada Inc (Evans, we, us or our) filed and published pursuant to the Fighting Against Forced Labour and Child Labour in Supply Chains Act (Canada) (the Supply Chains Act or the Act) for the twelve-month financial year ended December 31, 2023 (the Reporting Period)",0,0,0,0,0,0,0,0,0,0,0
SID_240,3827,"Our Structure, Operations and Supply Chains Evans is incorporated under the Canada Business Corporations Act",0,0,0,1,0,0,0,0,0,0,0
SID_240,3828,"It is a subsidiary of Evans Adhesives Corporation, based in Columbus, Ohio, United States, itself part of the Meridian Adhesives Group, with headquarters in Charlotte, North Carolina, United States (Meridian)",0,0,0,1,0,0,0,0,0,0,0
SID_240,3829,"Evans only operates in Canada from its single Industrial Packaging Division site located in Saint- Eustache, Quebec, Canada",0,0,0,1,1,0,0,0,0,0,0
SID_240,3830,Evans employs over 30 people,0,0,0,1,0,0,0,0,0,0,0
SID_240,3831,"Evans sells goods in Canada or abroad, distributes goods in Canada or abroad, or imports into Canada goods produced outside of Canada",0,0,0,0,1,0,0,0,0,0,0
SID_240,3832,"We formulate, manufacture and distribute industrial adhesives focused on the packaging market",0,0,0,0,1,0,0,0,0,0,0
SID_240,3833,"We offer water-based, hot melt, and pressure-sensitive adhesives that can perform under extreme conditions",0,0,0,0,1,0,0,0,0,0,0
SID_240,3834,"Our client base is comprised of players in the general product and food packaging, paper converting, construction and millwork industries",0,0,0,0,1,0,0,0,0,0,0
SID_240,3835,We source the majority of our material from the United States,0,0,0,0,0,1,0,0,0,0,0
SID_240,3836,Out of our ten largest suppliers nine are based in Canada or the United States and one is located in China,0,0,0,0,0,1,0,0,0,0,0
SID_240,3837,"The Steps We Have Taken during the Reporting Period to Prevent and Reduce the Risk of Forced Labour and Child Labour Evans current Code of Ethics (the Code) was adopted by our ultimate parent company, Meridian, and is applicable to Evans",0,0,0,0,0,0,0,0,0,0,0
SID_240,3838,"During the Reporting Period, we continued to implement our Code of Ethics discussed in section 3(a) of this Report",0,0,0,0,0,0,0,0,0,0,0
SID_240,3839,Except from the continued implementation of the Code no additional steps were taken during the Reporting Period to prevent and reduce the risk of forced labour and child labour in our operations and supply chains,0,0,0,0,0,0,0,1,0,0,0
SID_240,3840,"Policies, Due Diligence and Controls The Code which governs at a high-level issues related to business practices, employee relationships, customer relationships, community and the environment applies to all Meridians subsidiaries, including Evans",0,0,0,0,0,0,0,0,0,0,0
SID_240,3841,(a) Code of Ethics The statements set forth in the Code must be upheld by all our employees and representatives,0,0,0,0,0,0,0,0,0,0,0
SID_240,3842,"They owe a duty to Meridian, its customers and community to act in a way that will merit the continued trust and confidence of our community and those with which we do business",0,0,0,0,0,0,0,0,0,0,0
SID_240,3843,"Evans, its employees and representatives must ensure that there is no forced labour, including prison labour, indentured labour, bonded labour or other forms of forced labour used in our activities",0,0,0,0,0,0,0,1,0,0,0
SID_240,3844,#NAME?,0,0,0,0,0,0,0,0,0,0,0
SID_240,3845,Our workers cannot be younger than 16 years old or the compulsory age to be in school in the jurisdiction in which they live,0,0,0,0,0,0,0,1,0,0,0
SID_240,3846,"We will not partner with entities, including suppliers, who use child labour in any of their facilities",0,0,0,0,0,0,0,1,0,0,0
SID_240,3847,"We comply and follow all applicable local, provincial and federal laws relating to employment, wage and work hours",0,0,0,0,0,0,0,1,0,0,0
SID_240,3848,We uphold true and fair employment practices,0,0,0,0,0,0,0,1,0,0,0
SID_240,3849,"Beyond the statements established in our Code, it is our policy to comply with all laws, rules and regulations applicable to the business and countries in which we operate",0,0,0,0,0,0,0,1,0,0,0
SID_240,3850,"In the case of Evans, this includes laws relating to forced labour an child labour applicable in Quebec, Canada",0,0,0,0,0,0,0,1,0,0,0
SID_240,3851,"Risk Assessment Methodology and Results of Assessment During the Reporting Period, we did not make any assessment of the potential risk related to forced labour and child labour in our operations and supply chains",0,0,0,0,0,0,0,1,0,0,0
SID_240,3852,"In the future, we plan to roll- out a compliance program which may include a questionnaire designed to specifically address the issue of forced labour and child labour which we initially plan to send to our Tier 1 (direct) suppliers",0,0,0,0,0,0,0,1,0,0,0
SID_240,3853,"Risks of Forced Labour and Child Labour in our Operations and Supply Chains To our knowledge, during the Reporting Period we have not identified risks of forced labour and child labour in our operations and supply chains, although we recognize that this assessment was performed on a preliminary basis without recourse to the risk assessment tools that a robust compliance program could provide us with",0,0,0,0,0,0,1,0,0,0,0
SID_240,3854,"Remedial Action Taken during the Reporting Period Since we have not identified any forced labour or child labour in our activities and supply chains during the Reporting Period, we have not taken any remediation measures during the Reporting Period",0,0,0,0,0,0,0,0,1,0,0
SID_240,3855,"Our remediation processes All our employees are instructed and encouraged to report any violation to our Code and to, more generally, our commitment to true and fair financial, business and employment practices which would include denunciation of occurrences of forced labour and child labour in our operations or supply chains",0,0,0,0,0,0,0,1,0,0,0
SID_240,3856,They should report these potential violations to their manager or other management personnel without fear of retribution,0,0,0,0,0,0,0,1,0,0,0
SID_240,3857,"Remediation actions for the loss of income to the most vulnerable families that results from any measure taken to eliminate forced labour and child labour from our operations and supply chains Not applicable, we have not identified any loss of income to vulnerable families resulting from measures taken to eliminate the use of forced labour or child labour in our activities and supply chains during the Reporting Period",0,0,0,0,0,0,0,0,0,0,0
SID_240,3858,"Our training We have no director, officer or staff training in place at the moment dealing with forced labour and child labour in our operations and supply chains",0,0,0,0,0,0,0,1,0,0,0
SID_240,3859,-10,0,0,0,0,0,0,0,0,0,0,0
SID_240,3860,Assessing our effectiveness No assessment of our effectiveness to prevent and reduce the occurrence of forced labour and child labour in our operations and supply chains was conducted during the Reporting Period and until we put in place a compliance program to address this issue we are not contemplating performing an annual assessment of our effectiveness with regards to our action to prevent and reduce forced labour and child labour in our operations and supply chains,0,0,0,0,0,0,0,0,0,1,0
SID_240,3861,We expect to roll-out our initial assessment process in 2024,0,0,0,0,0,0,0,0,0,0,0
SID_240,3862,"Our consultation and governance process In preparing this Report, Evans consulted with key areas of our organization, including Procurement, Human Resources, the Legal Department and our external legal counsel",0,0,0,0,0,0,0,0,0,0,0
SID_240,3863,These teams operate across our enterprise,0,0,0,0,0,0,0,0,0,0,0
SID_240,3864,This consultation process has supported our enterprise- wide approach to forced labour and child labour,0,0,0,0,0,0,0,0,0,0,0
SID_240,3865,"Approval This Report was approved by the board of directors of Evans Adhesives Canada Inc pursuant to section 11(4)(a) of the Act on May 21, 2024",1,0,0,0,0,0,0,0,0,0,0
SID_240,3866,Conclusion Evans is committed to preventing forced labour and child labour from taking place in its operations and in its supply chain,0,0,0,0,0,0,0,0,0,0,0
SID_240,3867,"Accordingly, we expect to improve and/or develop policies, procedures and practices to address these value chain risks in the future",0,0,0,0,0,0,0,0,0,0,0
SID_240,3868,"Attestation In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the Report for the entity or entities listed above",0,0,0,0,0,0,0,0,0,0,0
SID_240,3869,"Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above",0,0,0,0,0,0,0,0,0,0,0
SID_240,3870,"Dated this 24th day of May, 2024 Evans Adhesives Canada Inc",0,0,0,0,0,0,0,0,0,0,0
SID_240,3871,"Per: Wayne Byrne, Director, I have the authority to bind Evans Adhesives Canada Inc",0,1,0,0,0,0,0,0,0,0,0
SID_240,3872,Draft 2023 Modern Slavery Statement (final version).DOCX DocuSign Envelope ID: 32621DD2-F986-4A3B-BA3D-BE26E6FBCBBB,0,0,0,0,0,0,0,0,0,0,0
SID_243,4030,Modern Slavery Act Report 2023,0,0,0,0,0,0,0,0,0,0,0
SID_243,4031,Introduction,0,0,0,0,0,0,0,0,0,0,0
SID_243,4032,"At SJC, we do not tolerate modern slavery or any unethical behaviours that violate human rights",0,0,0,0,0,0,0,0,0,0,0
SID_243,4033,"Modern slavery, which includes forced labour and child labour, is a global concern and one that goes against our core beliefs and values, including Respect Every Individual as Equal",0,0,0,0,0,0,0,0,0,0,0
SID_243,4034,"If we become aware of any unethical or illicit behaviours that we and the law consider to be unacceptable by our employees, freelancers, suppliers, or anyone we do business with, we will immediately address the situation and proceed in a way that minimizes harm to those affected",0,0,0,0,0,0,0,0,0,0,0
SID_243,4035,"We maintain a strong commitment to growth and continue to adapt, develop, and implement new policies and procedures to better protect our vulnerable communities and people",0,0,0,0,0,0,0,0,0,0,0
SID_243,4036,"In our 2023 reporting year, we took a number of steps to better address and prevent forced and child labour in our operations and those of our suppliers",0,0,0,0,0,0,0,1,0,0,0
SID_243,4037,Weve mapped our activities and supply chains as well as completed an internal risk assessment to prioritize the most severe areas of risk,0,0,0,0,0,0,0,1,0,0,0
SID_243,4038,"Additionally, we have maintained internal controls to guarantee workers are recruited voluntarily and we are developing training related to modern slavery",0,0,0,0,0,0,0,1,0,0,0
SID_243,4039,"Using our risk assessments and the information gathered from the supply chain mapping, we were able to develop an action plan and due diligence policies and processes to address modern slavery and protect children and labourers",0,0,0,0,0,0,0,1,0,0,0
SID_243,4040,"In the coming year, we will continue to develop, improve, and implement these policies and controls and will continue to work towards maintaining a supply chain with very minimal risk of modern slavery",0,0,0,0,0,0,0,1,0,0,0
SID_243,4041,"Structure, Activities, and Supply Chains St Joseph Printing Limited (SJPL), which operates under the name St",0,0,0,1,0,0,0,0,0,0,0
SID_243,4042,"Joseph Communications (SJC), is the entity that contains our Print division",0,0,0,1,0,0,0,0,0,0,0
SID_243,4043,Ontario,0,0,0,0,0,0,0,0,0,0,0
SID_243,4044,"Limited, which operates under the names SJC Content and SJC Media, is a wholly owned subsidiary of SJPL",0,0,0,1,0,0,0,0,0,0,0
SID_243,4045,Both entities are located in Canada,0,0,0,1,0,0,0,0,0,0,0
SID_243,4046,"SJC and its subsidiaries are involved in numerous business activities, including producing goods in Canada, selling goods in and outside Canada, distributing goods in and outside Canada, importing goods into Canada, and controlling an entity or entities engaged in any of the previously mentioned activities",0,0,0,1,1,0,0,0,0,0,0
SID_243,4047,"Our supply chains involve several vendors and suppliers, the greater part of which are located and operating in North America",0,0,0,0,0,1,0,0,0,0,0
SID_243,4048,Our Print divisions largest vendors are North American paper suppliers,0,0,0,0,0,1,0,0,0,0,0
SID_243,4049,"For SJC Content and SJC Media, creative work is either produced in-house or sourced through highly skilled freelancers that are primarily located in North America",0,0,0,0,1,1,0,0,0,0,0
SID_243,4050,Risks,0,0,0,0,0,0,0,0,0,0,0
SID_243,4051,"As the vast majority of our vendors and suppliers are located and operating in North America, risk exposure to Canadian and American labour law violations is relatively low",0,0,0,0,0,1,1,0,0,0,0
SID_243,4052,"Our Print manufacturing is also entirely in house, enabling us to guarantee proper conduct and practices",0,0,0,0,1,0,0,0,0,0,0
SID_243,4053,"We have identified and recognize risks related to some of the products we purchase, raw materials or commodities used in our supply chains, tier three and beyond suppliers, and the use of outsourced labour",0,0,0,0,0,0,1,0,0,0,0
SID_243,4054,"Though we source predominantly from North America and can be reasonably sure that our tier one and two suppliers are not engaging in any modern slavery or unethical behaviours and practices, we acknowledge that those in tier three and beyond of our supply chain may be sourcing or operating in higher risk locations or industries",0,0,0,0,0,1,1,0,0,0,0
SID_243,4055,We also recognize that the following sectors and industries related to our supply chain carry risk; Electronics/technology Forestry,0,0,0,0,0,0,1,0,0,0,0
SID_243,4056,Manufacturing Transportation and warehousing We maintain the commitment to further evaluate and identify areas of risk in our supply chains and improve our policies and procedures to address them,0,0,0,0,0,0,1,0,0,0,0
SID_243,4057,"Our Policies Our SJC policies and procedures align with human rights and provincial employment standards legislation, as well as all Canadian labour laws",0,0,0,0,0,0,0,1,0,0,0
SID_243,4058,"Our associate handbook sets out to ensure all employees, visitors, contractors, and customers of our company and its subsidiaries are respected and treated fairly in accordance with their human rights",0,0,0,0,0,0,0,0,0,0,0
SID_243,4059,The handbook outlines specific behaviours and practices that are unacceptable for those who are a part of SJC and represent the company,0,0,0,0,0,0,0,0,0,0,0
SID_243,4060,"Additionally, we have a code of ethics that outlines our commitment to honest and ethical conduct in all areas of our organization",0,0,0,0,0,0,0,0,0,0,0
SID_243,4061,"Relating to our paper suppliers and forestry risks, we have embedded responsible business conduct in our policies, as the large majority of our paper is Forest Stewardship Council (FSC) certified",0,0,0,0,0,1,0,1,0,0,0
SID_243,4062,This ensures the trees used to make the paper has been ethically sourced in a way that protects biological diversity and benefits the lives of local people and labourers,0,0,0,0,0,0,0,0,0,0,0
SID_243,4063,"For our creative freelancers located outside North America, we have existing policies in place to ensure they are in compliance with our internal policies and procedures, which includes avoidance of forced or child labour",0,0,0,0,0,1,0,1,0,0,0
SID_243,4064,"While these policies do work toward keeping our business practices and partners within our standards and ethical code, we are in the process of implementing vendor qualification questionnaires and due diligence processes to better ensure labour laws specifically are being respected across our entire supply chain",0,0,0,0,0,0,0,1,0,0,0
SID_243,4065,Remediation,0,0,0,0,0,0,0,0,0,0,0
SID_243,4066,"As per our associate handbook, our Open Door Policy promotes the fostering of open communication and trust between employees and their supervisor, Human Resources, or any company manager",0,0,0,0,0,0,0,0,0,0,0
SID_243,4067,We strongly encourage all employees to discuss any problems or concerns promptly with a manager or Human Resources,0,0,0,0,0,0,0,0,0,0,0
SID_243,4068,This includes misconduct by employees or members of our supply chain,0,0,0,0,0,0,0,0,0,0,0
SID_243,4069,"In any suspected case of modern slavery, we will immediately address our expectations and relationship, and work to promptly identify those affected by the wrongdoing and provide appropriate remediation",0,0,0,0,0,0,0,0,1,0,0
SID_243,4070,"To date we have not identified or been advised of any forced or child labour use, nor any loss of income to vulnerable families as a result of measures we have taken to eliminate modern slavery",0,0,0,0,0,0,1,0,0,0,0
SID_243,4071,Training,0,0,0,0,0,0,0,0,0,0,0
SID_243,4072,"Our employees are required to read and sign to acknowledge understanding of our associate handbook, which outlines our expectations of conduct as well as all of our internal policies",0,0,0,0,0,0,0,0,0,0,0
SID_243,4073,This includes expectations of ethical business practices and our right to take disciplinary action in cases of noncompliance,0,0,0,0,0,0,0,0,1,0,0
SID_243,4074,"Additionally, we are continuing to develop training to specifically address forced and child labour to improve understanding of modern slavery, and reinforce that it is not an acceptable practice by SJC or our suppliers",0,0,0,0,0,0,0,1,0,0,0
SID_243,4075,Assessing Effectiveness,0,0,0,0,0,0,0,0,0,0,0
SID_243,4076,We have and will continue to review our policies and procedures as well as emerging laws and legislation to determine if there are any enhancements to be made,0,0,0,0,0,0,0,0,0,1,0
SID_243,4077,"We intend to review our supplier questionnaire to establish continuous compliance, as well as",0,0,0,0,0,0,0,0,0,1,0
SID_243,4078,set key performance indicators where necessary to confirm our actions and risk management efforts are successful and serve to protect those most vulnerable,0,0,0,0,0,0,0,0,0,1,0
SID_243,4079,Conclusion SJC and its subsidiaries remain dedicated to sustained and earnest growth in all areas of our organization and business practices,0,0,0,0,0,0,0,0,0,0,0
SID_243,4080,"This includes our assurance to maintain ethical conduct, fair treatment, and human rights policies and practices",0,0,0,0,0,0,0,0,0,0,0
SID_243,4081,We intend to review and revise our policies and due diligence processes to continue to best serve our communities and help prevent modern slavery,0,0,0,0,0,0,0,0,0,1,0
SID_243,4082,Approval and Attestation This report has been approved by the governing body of SJC,1,0,0,0,0,0,0,0,0,0,0
SID_243,4083,"In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for the entity or entities listed above",0,0,0,0,0,0,0,0,0,0,0
SID_243,4084,"Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above",0,0,0,0,0,0,0,0,0,0,0
SID_243,4085,"Tony Gagliano Chief Executive Officer SJC May 22, 2024",0,1,0,0,0,0,0,0,0,0,0
SID_252,4331,"Transparency in Supply Chain Statement Reporting for January through December 2023 Introduction The Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act (Supply Chains Act), California Transparency in Supply Chains Act (SB 657), and the United Kingdom Modern Slavery Act 2015 requires certain businesses to provide disclosures concerning their efforts to address the issues of forced labor and child labor in their supply chains, to provide consumers the ability to make better and more informed choices about the products they buy and companies they support",0,0,0,0,0,0,0,0,0,0,0
SID_252,4332,"The business entity Columbia Sportswear Company (CSC) believes forced labor, child labor, modern slavery and human trafficking are egregious issues; we are committed to doing due diligence within our operations to minimize the risk and to remediate any found occurrence of these issues in our supply chain",0,0,0,0,0,0,0,0,0,0,0
SID_252,4333,"Company Information CSC was founded in 1938 in Portland, Oregon, as a small, family-owned, regional hat distributor and incorporated in 1961",0,0,0,1,1,0,0,0,0,0,0
SID_252,4334,"CSC is headquartered in Portland, Oregon USA",0,0,0,1,0,0,0,0,0,0,0
SID_252,4335,"We connect active people with their passions by designing, developing, marketing, and distributing our outdoor, active and everyday lifestyle apparel, footwear, accessories and equipment products to meet the diverse needs of our customers and consumers under four primary brands: Columbia, SOREL, Mountain Hard Wear, and prAna",0,0,0,1,1,0,0,0,0,0,0
SID_252,4336,CSC is a commercial retailer,0,0,0,0,1,0,0,0,0,0,0
SID_252,4337,"We sell our products in more than 100 countries and operate in four geographic segments: United States (""U.S.""), Latin America and Asia Pacific (""LAAP""), Europe, Middle East, and Africa (""EMEA""), and Canada",0,0,0,0,1,0,0,0,0,0,0
SID_252,4338,"We sell our products through a mix of distribution channels: wholesale distribution, international distributors, direct-to-consumer (""DTC"") distribution, retail, and through licensing certain of our trademarks across a range of apparel, accessories, equipment, footwear, and home products",0,0,0,0,1,0,0,0,0,0,0
SID_252,4339,"A list of our subsidiaries can be found in our 2024 Form 10-K, exhibit 21.1",0,0,0,1,0,0,0,0,0,0,0
SID_252,4340,"CSCs annual, worldwide, gross receipts exceed $100M US and $40M CAN, and annual turnover exceeds 36M",0,0,0,0,0,0,0,0,0,0,0
SID_252,4341,"Sourcing and Manufacturing CSC does not own, operate, or manage manufacturing facilities",0,0,0,0,1,0,0,0,0,0,0
SID_252,4342,"The vast majority of our products are manufactured by contract manufacturers located outside the United States, and none in Canada",0,0,0,0,0,1,0,0,0,0,0
SID_252,4343,We seek to establish and maintain long-term relationships with key manufacturing partners who share our values,0,0,0,0,0,0,0,0,0,0,0
SID_252,4344,"We manage our supply chain from a global and regional perspective and adjust as needed to changes in the global production environment, including political risks, factory capacity, import limitations and costs, raw material costs, availability and cost of labor, and transportation costs",0,0,0,0,0,0,0,0,0,0,0
SID_252,4345,"In 2023, our apparel, accessories and equipment products for our wholesale and direct-to- consumer (""DTC"") businesses were manufactured into finished goods in 15 countries",0,0,0,0,0,1,0,0,0,0,0
SID_252,4346,"In 2023, finished goods manufacturers in Vietnam, Bangladesh, Indonesia, and India produced approximately 40%, 20%, 15% and 10%, respectively, of these products",0,0,0,0,0,1,0,0,0,0,0
SID_252,4347,"Five of the largest contract finished goods manufacturers account for approximately 30% of our apparel, accessories and equipment production, with the largest manufacturer accounting for approximately 10%",0,0,0,0,0,1,0,0,0,0,0
SID_252,4348,"In 2023, our footwear products for our wholesale and DTC businesses were manufactured into finished goods in five countries",0,0,0,0,0,1,0,0,0,0,0
SID_252,4349,"In 2023, finished goods manufacturers in Vietnam and China produced approximately 75% and 20%, respectively, of these products",0,0,0,0,0,1,0,0,0,0,0
SID_252,4350,"Five of the largest contract finished goods manufacturers account for approximately 75% of our footwear production, with the two largest manufacturers accounting for approximately 20% each and three manufacturers accounting for approximately 15%, 10% and 10% individually",0,0,0,0,0,1,0,0,0,0,0
SID_252,4351,"Raw materials for the manufacturing of our apparel, accessories, equipment, and footwear products are primarily sourced from Asia and are purchased directly by our contract manufacturers",0,0,0,0,0,1,0,0,0,0,0
SID_252,4352,"In 2023, we maintained seven manufacturing liaison offices in six Asia Pacific countries",0,0,0,0,0,0,0,1,0,0,0
SID_252,4353,Our personnel in these offices monitor production at our contract manufacturers facilities,0,0,0,0,0,0,0,1,0,0,0
SID_252,4354,"The physical location of our employees in these regional offices enhances our ability to monitor contract manufacturers for compliance with our policies, procedures and standards related to labor practices",0,0,0,0,0,0,0,1,0,0,0
SID_252,4355,"Slavery and Human Trafficking Standards Our standards and compliance program as outlined in this statement is applied at a global level, including any business conducted in and products sold into Canada",0,0,0,0,0,0,0,0,0,0,0
SID_252,4356,CSC is committed to taking appropriate steps to help ensure that our products are manufactured in factories that operate with fair and safe working conditions and sustainable business practices,0,0,0,0,0,0,0,0,0,0,0
SID_252,4357,To demonstrate this,0,0,0,0,0,0,0,0,0,0,0
SID_252,4358,"responsibility, we value and strive for long term partnerships with factories to monitor and ensure continuous improvement in alignment with our Standards of Manufacturing Practices (SMP) (aka Code of Conduct)",0,0,0,0,0,1,0,0,0,0,0
SID_252,4359,We require tier 1 factories to post our SMP in the factory workers local language so they understand their fair labor rights; an email address is provided at the bottom of the SMP poster for workers to lodge grievances and/or report violations of the SMP confidentially to us,0,0,0,0,0,0,0,1,0,0,0
SID_252,4360,"The SMP includes a standard that addresses forced and child labor, where all suppliers are required to demonstrate that they do not use forced and child labor, whether in the form of prison, indentured, slave, bonded, trafficked or any other form of compulsory labor",0,0,0,0,0,0,0,1,0,0,0
SID_252,4361,CSC defines slavery and human trafficking as used by U.S,0,0,0,0,0,0,0,0,0,0,0
SID_252,4362,"Department of State and the ILO: Human Trafficking: ""any recruitment, harboring, transportation, provision, or obtaining of a person for labor services, through the use of force, fraud, or coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage, or slavery."" Slavery - Involuntary Servitude: ""a condition of servitude induced by means of (A) any scheme, plan, or pattern intended to cause a person to believe that, if the person did not enter into or continue in such condition, that person or another person would suffer serious harm or physical restraint; or (B) the abuse or threatened abuse of the legal process."" Child labor: is mentally, physically, socially or morally dangerous and harmful to children; and/or interferes with their schooling",0,0,0,0,0,0,0,0,0,0,0
SID_252,4363,Our Social Responsibility Manual for Manufacturing Partners serves as a central reference for our manufacturers to understand our Due Diligence process,0,0,0,0,0,0,0,0,0,0,0
SID_252,4364,This manual outlines expectations for conducting responsible business,0,0,0,0,0,0,0,0,0,0,0
SID_252,4365,"It also explains how we monitor, seek to prevent, and communicate when adverse impacts are found in factories which go against our SMP, such as forced and child labor",0,0,0,0,0,0,0,1,0,0,0
SID_252,4366,We have a Foreign Migrant Worker Policy which our suppliers are required to abide by,0,0,0,0,0,0,0,1,0,0,0
SID_252,4367,"This policy establishes a set of standards based upon ILO Core Conventions, internationally recognized principles, and industry best practices that we require our supplier partners to adhere to in order to offer the greatest protection to migrant workers who have traveled from another country to obtain employment",0,0,0,0,0,0,0,1,0,0,0
SID_252,4368,"We also refer to this policy to address domestic migrant worker issues, where and when applicable",0,0,0,0,0,0,0,0,0,0,0
SID_252,4369,We have an internal procedure that guides our team in addressing any violations related to migrant workers,0,0,0,0,0,0,0,0,0,0,0
SID_252,4370,Risk Assessment and Internal Accountability We recognize our industrys supply chain has a risk of forced labor and child labor,0,0,0,0,0,0,1,0,0,0,0
SID_252,4371,"We acknowledge the areas of risks in our sector, our specific production locations, including our raw material",0,0,0,0,0,0,1,0,0,0,0
SID_252,4372,"sourcing, and the types of products we sell",0,0,0,0,0,0,1,0,0,0,0
SID_252,4373,To the best of our ability we seek to identify forced and child labor risks in all of these areas within our supply chain,0,0,0,0,0,0,0,0,0,0,0
SID_252,4374,We strive to continuously enhance our methodologies to do this,0,0,0,0,0,0,0,0,0,0,0
SID_252,4375,"We continually assess the forced and child labor risks related to our apparel, footwear, accessories, and equipment supply chains, utilizing information received from industry associations, membership organizations, external experts and stakeholders to inform updates to our human rights strategy, policies, and procedures",0,0,0,0,0,0,0,1,0,0,0
SID_252,4376,"At the supplier level, the performance grades from audits/assessments inform seasonal sourcing decisions, and an annual supply chain risk assessment report is provided to our Board of Directors, which includes a section on Forced Labor and Child Labor risks",0,0,0,0,0,0,0,1,0,0,0
SID_252,4377,"Additionally, we recognize our industrys supply chain has a unique risk of human trafficking in the form of foreign migrant workers",0,0,0,0,0,0,1,0,0,0,0
SID_252,4378,"To confirm our commitment and accountability to address this issue, we have signed on to the American Apparel and Footwear Association (AAFA) & Fair Labor Association (FLA) Apparel & Footwear Industry Commitment to Responsible Recruitment, which specifies: We commit to work with our global supply chain partners to create conditions so that: No workers pay for their job; Workers receive a timely refund of fees and costs paid to obtain or maintain their job; Workers retain control of their travel documents and have full freedom of movement; and All workers are informed, in a language they understand, of the basic terms of their employment before leaving their country of origin",0,0,0,0,0,0,0,1,0,0,0
SID_252,4379,"Each of these requirements are outlined in detail in our Foreign Migrant Worker Policy, which our suppliers must abide by",0,0,0,0,0,0,0,1,0,0,0
SID_252,4380,"In 2023, we actively participated in the Joint Association Forced Labor Working Group (AAFA, NRF, RILA, and USFIA), which meets to discuss how to combat forced labor in our supply chains and create sustainable solutions for the industry",0,0,0,0,0,0,0,1,0,0,0
SID_252,4381,We maintain and enforce internal accountability procedures for employees and contractors regarding company standards around slavery and human trafficking,0,0,0,0,0,0,0,1,0,0,0
SID_252,4382,"In the case of non-compliance, we reserve the right to examine the specific situation and develop the best possible strategy for resolution",0,0,0,0,0,0,0,0,0,0,0
SID_252,4383,"If cases of non-compliance are not resolved within a timely manner, we may terminate the business relationship",0,0,0,0,0,0,0,1,0,0,0
SID_252,4384,Certification and Auditing CSC requires all contract manufacturing partners to sign a supply agreement,0,0,0,0,0,0,0,0,0,0,0
SID_252,4385,Such an agreement requires that contract manufacturing partners have read and understand the Columbia Sportswear Company Standards of Manufacturing Practices (SMP) Policy,0,0,0,0,0,0,0,0,0,0,0
SID_252,4386,"This policy ensures that our facilities and the facilities of its subcontractors are maintained in accordance with the SMP Policy standards, and will comply with all applicable laws, regulations, and orders regarding the use of forced labor, child labor, human slavery, human trafficking, wages, working hours and conditions, work eligibility and non-discrimination",0,0,0,0,0,0,0,1,0,0,0
SID_252,4387,"CSC strives to comply with the UN Guiding Principles on Business and Human Rights (UNGPs), which specify that due diligence processes should 'include assessing actual and potential human rights impacts, integrating and acting upon the findings, tracking responses, and communicating how impacts are addressed. All finished goods facilities are subject to performance evaluation of audit or assessment data which include specific criteria around risks for forced and child labor or human trafficking",0,0,0,0,0,0,0,1,0,0,0
SID_252,4388,"This includes the employment of vulnerable worker groups such as young workers, foreign migrants, interns and temporary workers, as well as high-risk practices such as restrictions on freedom of movement, payment of recruitment fees, or the use of labor brokers or third-party recruiters",0,0,0,0,0,0,1,0,0,0,0
SID_252,4389,"We require assessments annually and where heightened risks or concerns are found, we re-audit again within six months",0,0,0,0,0,0,0,1,0,0,0
SID_252,4390,"New finished goods facilities, including finished goods subcontractors, are audited or assessed and must meet our minimum standards before production can begin",0,0,0,0,0,1,0,1,0,0,0
SID_252,4391,"A re-audit will occur anywhere from 30 days to one year later, depending on the findings in the previous audit or assessment",0,0,0,0,0,0,0,0,0,0,0
SID_252,4392,"SMP monitoring performance data comes from several sources: unannounced audits completed by our internal SMP auditors as well as designated 3rd party audit firms who are trained to our standards, announced assessments performed by ILOs Better Work program, the Social and Labor Convergence Program, and audits from a handful of other brands with whom we have built a strong relationship",0,0,0,0,0,0,0,1,0,0,0
SID_252,4393,All data is scored according to our SMP grading matrix and local law,0,0,0,0,0,0,0,0,0,0,0
SID_252,4394,"In 2023, we utilized data from 314 audits and assessments at our finished goods factories (Tier 1) and 70 assessments at processing facilities (Tier 2)",0,0,0,0,0,0,0,0,0,1,0
SID_252,4395,We work with the suppliers to develop a Corrective Action Plan (CAP) to remediate issues identified during the audit or assessment,0,0,0,0,0,0,0,0,1,0,0
SID_252,4396,"CSC does not believe that slavery, human trafficking, forced labor or child labor exist in our supply chain",0,0,0,0,0,0,1,0,0,1,0
SID_252,4397,"In the event that we find non-compliance in these areas, we reserve the right to investigate the situation and to the best of our ability, remediate the violation",0,0,0,0,0,0,0,0,1,0,0
SID_252,4398,We have specific internal procedures that outline how we respond to these situations,0,0,0,0,0,0,0,0,0,0,0
SID_252,4399,If cases of non-compliance are not,0,0,0,0,0,0,0,0,0,0,0
SID_252,4400,"resolved within a timely manner, CSC may seek to terminate the business relationship",0,0,0,0,0,0,0,0,1,0,0
SID_252,4401,"While CSC intends to play an active role in the resolution of incidences of human trafficking, slavery, forced labor, and child labor within our supply chain, it is not fully possible to effectively solve the issue of without the cooperation of the supplier",0,0,0,0,0,0,0,0,0,0,0
SID_252,4402,We have not identified any loss of income to vulnerable families resulting from measures taken to eliminate the use of forced labor or child labor in our activities and supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_252,4403,"For example, CSC has signed on to AAFA/FLAs Commitment to Responsible Recruitment, which commits us to ensure that workers are re-imbursed for all fees paid to obtain their job and has incorporated these protocols into our companys social compliance standards",0,0,0,0,0,0,0,1,0,0,0
SID_252,4404,"Training CSC regularly communicates with all internal supply chain management staff on our forced labor, slavery and human trafficking policies and procedures, with a particular focus on mitigating risks, to ensure they are knowledgeable and aware of the issues and concerns surrounding our supply chain",0,0,0,0,0,0,0,1,0,0,0
SID_252,4405,"In 2023, a mandatory, in-depth training was assigned to all relevant CSC supply chain employees to bring awareness around forced labor and human trafficking prevalence, relevant legislation to our company, what CSC is doing for risk mitigation and due diligence, and what reporting mechanisms employees should follow if they have concerns or spot issues",0,0,0,0,0,0,0,1,0,0,0
SID_252,4406,This training will be conducted annually,0,0,0,0,0,0,0,1,0,0,0
SID_252,4407,The training helps to equip our colleagues with the skills to identify and report actual or perceived violations,0,0,0,0,0,0,0,0,0,0,0
SID_252,4408,This training is revised and enhanced continuously to ensure the content maintains relevancy,0,0,0,0,0,0,0,1,0,1,0
SID_252,4409,Our Social Responsibility staff are also required to attend and participate in the bi-weekly AAFA Social Responsibility Committee calls,0,0,0,0,0,0,0,0,0,0,0
SID_252,4410,This serves as an input for industry and geographical risks,0,0,0,0,0,0,0,0,0,0,0
SID_252,4411,"In 2023, a representative from the Social Responsibility team completed the FLAs e-learning which included a specific emphasis on forced labor",0,0,0,0,0,0,0,0,0,1,0
SID_252,4412,"Additionally, our Social Responsibility team seeks and attends external opportunities that arise on social compliance issues",0,0,0,0,0,0,0,0,0,0,0
SID_252,4413,"We strive to continuously improve our approach to identifying any risk of and to eradicating forced labor, child labor and modern slavery from our supply chain",0,0,0,0,0,0,0,0,0,0,0
SID_252,4414,We continue to evaluate the effectiveness of our eradication efforts via the publication of our annual Impact Report,0,0,0,0,0,0,0,0,0,0,0
SID_252,4415,"In 2024, we hope to further hone our specific effectiveness indicators",0,0,0,0,0,0,0,0,0,0,0
SID_252,4416,"Canadian Attestation In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for the entity or entities listed above",0,0,0,0,0,0,0,0,0,0,0
SID_252,4417,"Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above",0,0,0,0,0,0,0,0,0,0,0
SID_252,4418,________________________ Peter J,0,1,0,0,0,0,0,0,0,0,0
SID_252,4419,"Bragdon Director, Columbia Brands Canada Limited; EVP, CAO and General Counsel, Columbia Brands Holding Company, Sole Member of prAna Living, LLC Dated: I have the authority to bind these entities",0,1,0,0,0,0,0,0,0,0,0
SID_253,4420,"Dumur Industries 2 Ramm Avenue, White City, SK, S4L 5B1",0,0,0,0,0,0,0,0,0,0,0
SID_253,4421,T: (306) 757 2403,0,0,0,0,0,0,0,0,0,0,0
SID_253,4422,"2023 Report on Forced Labour and Child Labour This Report addresses the period from January 1, 2023 to December 31, 2023 and has been prepared in compliance with the Figh/ng Against Forced Labour and Child Labour in Supply Chains Act (Canada)(the Act)",0,0,0,0,0,0,0,0,0,0,0
SID_253,4423,This Report is made on behalf of 1916354 Alberta Ltd dba Dumur Industries,0,0,0,0,0,0,0,0,0,0,0
SID_253,4424,Introduc/on,0,0,0,0,0,0,0,0,0,0,0
SID_253,4425,"Dumur Industries and its subsidiaries (the Company, Dumur), acknowledge our responsibility to combat forced and child labour and are commi6ed to ac/ng ethically and with integrity and transparency",0,0,0,1,0,0,0,0,0,0,0
SID_253,4426,We are working to put systems and controls in place to safeguard against any form of forced or child labour occurring within our supply chain,0,0,0,0,0,0,0,0,0,0,0
SID_253,4427,Our Business,0,0,0,0,0,0,0,0,0,0,0
SID_253,4428,"Dumur Industries and its subsidiaries, Dellcom Aerospace and J/E Bearing & Machine Ltd, manufacture and supply parts and assemblies to customers who operate predominantly in the aerospace and defense sectors of industry",0,0,0,1,1,0,0,0,0,0,0
SID_253,4429,Customers may be Canadian or Interna/onal corpora/ons with opera/ons mainly in North America and Europe,0,0,0,0,1,0,0,0,0,0,0
SID_253,4430,"The head oce of Dumur Industries is in White City, SK while Dellcom Aerospace and J/E Bearing are located in Ontario",0,0,0,1,0,0,0,0,0,0,0
SID_253,4431,Dumur and J/E Bearing are focused mainly on producing land defense systems while Dellcom Aerospace provides parts and assemblies for commercial and military aerospace companies,0,0,0,1,1,0,0,0,0,0,0
SID_253,4432,The Company employs approximately 200 people,0,0,0,1,0,0,0,0,0,0,0
SID_253,4433,Our Supply Chains,0,0,0,0,0,0,0,0,0,0,0
SID_253,4434,"In the highly regulated aerospace and defense sectors, supply chains are primarily directed and approved by the customers",0,0,0,0,0,1,0,0,0,0,0
SID_253,4435,These directed sources are controlled by the customer and are almost always long-term rela/onships that account for most of the procured material at Dumur,0,0,0,0,0,1,0,0,0,0,0
SID_253,4436,Dumur Industries also manages its own supply chain,0,0,0,0,0,1,0,0,0,0,0
SID_253,4437,"These suppliers will provide raw material (steel, aluminum, etc.), tooling, shop supplies, machinery and hardware",0,0,0,0,0,1,0,0,0,0,0
SID_253,4438,"Dumur may also engage service providers for computer services, communica/on, payroll, legal and other administra/ve func/ons",0,0,0,0,0,1,0,0,0,0,0
SID_253,4439,"When Dumur Industries employees travel, they engage with airlines and na/onal hotel chains in Canada, the USA and Interna/onally as required",0,0,0,0,0,1,0,0,0,0,0
SID_253,4440,Any supplier providing a product or service goes through a formal approval process at Dumur in accordance with our AS9100 cer/ca/on requirements,0,0,0,0,0,0,0,1,0,0,0
SID_253,4441,Our Policies,0,0,0,0,0,0,0,0,0,0,0
SID_253,4442,The Dumur Management System policies and procedures establishes the organiza/on Dumur Industries strives to be and managements commitment to ensuring the Company operates within the laws of Canada,0,0,0,0,0,0,0,0,0,0,0
SID_253,4443,In seFng these goals Dumur has established a strict policy base to both protect the Company and its employees and ensure that we meet or exceed expecta/ons for ethical business prac/ces,0,0,0,0,0,0,0,0,0,0,0
SID_253,4444,"As part of the on-boarding process at Dumur Industries, new employees are required to read, understand and sign the Dumur Employee Handbook",0,0,0,0,0,0,0,1,0,0,0
SID_253,4445,This Employee Handbook is part of Dumurs Management System policies and procedures and is reviewed annually to ensure compliance with Canadian and Interna/onal business standards,0,0,0,0,0,0,0,0,0,1,0
SID_253,4446,"The Employee Handbook deals with issues in the workplace such as discrimina/on, harassment and violence",0,0,0,0,0,0,0,0,0,0,0
SID_253,4447,It also determines the condi/ons under which employees will work and how they will treat others,0,0,0,0,0,0,0,0,0,0,0
SID_253,4448,The Management System policies and procedures will be updated in 2024 to include a formal Code of Ethics policy,0,0,0,0,0,0,0,1,0,0,0
SID_253,4449,Assessing Our Risk,0,0,0,0,0,0,0,0,0,0,0
SID_253,4450,"No formal assessment of the risk of Forced Labour and Child Labour in our supply chain was conducted between January 1, 2023, and December 31, 2023",0,0,0,0,0,0,0,1,0,0,0
SID_253,4451,We intend to undertake this assessment in the next 24 months,0,0,0,0,0,0,0,1,0,0,0
SID_253,4452,Our Commitment to Ethical Prac/ces,0,0,0,0,0,0,0,0,0,0,0
SID_253,4453,Employee Training on the issues surrounding Forced Labour and Child Labour in the supply chain has not been established at Dumur Industries,0,0,0,0,0,0,0,1,0,0,0
SID_253,4454,It is intended that Dumur will dene a Code of Ethics policy for release to its employees,0,0,0,0,0,0,0,0,0,0,0
SID_253,4455,"Dumur will also release a Forced Labour and Child Labour policy and provide targeted training to employees during 2024, once the new policies and procedures have been introduced",0,0,0,0,0,0,0,1,0,0,0
SID_253,4456,Our Plans for 2024,0,0,0,0,0,0,0,0,0,0,0
SID_253,4457,"Area Ac ons Establish a formal Code of Ethics Policy Inves/gate, write, and release the policy to employees Establish Forced Labour and Child Labour Policy Establish policy and roll out to management and employees Policy Training Provide training to Dumur employees on the new policies",0,0,0,0,0,0,0,1,0,0,0
SID_253,4458,Approval & Signature/A6esta/on,0,0,0,0,0,0,0,0,0,0,0
SID_253,4459,"This report was approved by the Board of Dumur Industries on May 21st, 2024, and has been submi6ed to the Minister of Public Safety and Emergency Preparedness in compliance with the Act",1,0,0,0,0,0,0,0,0,0,0
SID_253,4460,This Report is also available on our website at www.dumurindustries.com,0,0,0,0,0,0,0,0,0,0,0
SID_253,4461,"In accordance with the requirements of the Act, and in par/cular sec/on 11 thereof, I a6est that I have reviewed the informa/on contained in this Report",0,0,0,0,0,0,0,0,0,0,0
SID_253,4462,"Based on my knowledge, and having exercised reasonable diligence, I a6est that the informa/on in this Report is true, accurate and complete in all material respects for the purposes of the Act, for the repor/ng year listed above",0,0,0,0,0,0,0,0,0,0,0
SID_253,4463,"Kendra Danbrook President May 21, 2024",0,1,0,0,0,0,0,0,0,0,0
SID_253,4464,I have the authority to bind 1916354 Alberta Ltd,0,0,0,0,0,0,0,0,0,0,0
SID_255,4576,E3 LITHIUM LTD,0,0,0,0,0,0,0,0,0,0,0
SID_255,4577,MODERN SLAVERY REPORT,0,0,0,0,0,0,0,0,0,0,0
SID_255,4578,"Introduction This report (the Report) is made jointly by E3 Lithium Ltd (E3) and its wholly-owned subsidiaries listed in Schedule A hereto (collectively, the Reporting Entities) pursuant to Canadas Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Act)",0,0,0,1,0,0,0,0,0,0,0
SID_255,4579,"This Report constitutes our forced labour and child labour reporting statement for the financial year ending December 31, 2023",0,0,0,0,0,0,0,0,0,0,0
SID_255,4580,"Where this Report refers to E3, the Company, we, us or our, it is a reference to all the Reporting Entities",0,0,0,0,0,0,0,0,0,0,0
SID_255,4581,"E3 does not tolerate child labour, forced labour or any other form of modern slavery",0,0,0,0,0,0,0,0,0,0,0
SID_255,4582,"We are dedicated to upholding and respecting human rights, firmly opposing all forms of modern slavery",0,0,0,0,0,0,0,0,0,0,0
SID_255,4583,We recognize the critical role this plays in human rights protection and strive to avoid causing or contributing to any adverse human rights impacts,0,0,0,0,0,0,0,0,0,0,0
SID_255,4584,II,0,0,0,0,0,0,0,0,0,0,0
SID_255,4585,"E3s Structure, Activities, and Supply Chains E3 is a Canadian lithium resource company with a current focus on commercial development of lithium extraction from brines contained in its mineral properties in Alberta",0,0,0,0,1,0,0,0,0,0,0
SID_255,4586,"E3s vision is to be a global leader in responsibly sourced lithium, fueling the global transition towards a brighter energy future",0,0,0,0,1,0,0,0,0,0,0
SID_255,4587,"The Company is incorporated under the Business Corporations Act (Alberta) and is listed on the TSX Venture Exchange, the Frankfurt Stock Exchange and the OTCQX",0,0,0,1,0,0,0,0,0,0,0
SID_255,4588,"The Companys head office is in Calgary, Alberta",0,0,0,1,0,0,0,0,0,0,0
SID_255,4589,E3 holds Canadas largest measured and indicated lithium resource located in a subsurface brine,0,0,0,0,1,0,0,0,0,0,0
SID_255,4590,"The Company has several operating areas, however, currently the E3s primary focus is to advance all aspects of its Clearwater Project located in Southern Alberta in order to achieve commercial operations",0,0,0,0,1,0,0,0,0,0,0
SID_255,4591,"E3 has over 30 employees and contractors working in professional office, research laboratory, and field operations roles",0,0,0,1,0,1,0,0,0,0,0
SID_255,4592,"All of E3s employees and contractors are located in Alberta with the majority located in Calgary, Alberta",0,0,0,1,0,1,0,0,0,0,0
SID_255,4593,"We strive to create a diverse, inclusive and respectful culture across our business operations and projects",0,0,0,0,0,0,0,0,0,0,0
SID_255,4594,"E3 does business with a wide range of goods and services suppliers (Suppliers), sourcing goods and services locally and globally",0,0,0,0,0,1,0,0,0,0,0
SID_255,4595,We strive to build relationships with Suppliers who align with our values and are committed to ensuring that our contracting and procurement activities are done in compliance with our policy commitments,0,0,0,0,0,0,0,0,0,0,0
SID_255,4596,"In 2023, E3 procured goods and services across a wide range of categories and industry sectors",0,0,0,0,0,1,0,0,0,0,0
SID_255,4597,The vast majority of E3s procurement activities in 2023 related to the purchase of services in relation to the construction and operation of Albertas first lithium field pilot,0,0,0,0,0,1,0,0,0,0,0
SID_255,4598,"These services included a service rig to produce brine, site preparation for the pilot, construction of temporary facilities, and testing of lithium extraction equipment",0,0,0,0,0,1,0,0,0,0,0
SID_255,4599,The majority of costs for equipment for our 2023 activities were rentals,0,0,0,0,0,1,0,0,0,0,0
SID_255,4600,"E3 also purchased manufactured goods such as laboratory equipment, skid, columns, heaters, valves, pipes, measurement instruments, pumps, programmable control systems and other engineered equipment for its field pilot",0,0,0,0,0,1,0,0,0,0,0
SID_255,4601,"The majority of our Suppliers are located in Canada and the United States, although we recognize that many of our Suppliers supply us with goods that originate in other jurisdictions and each have their own supply chains",0,0,0,0,0,1,0,0,0,0,0
SID_255,4602,"In evaluating Suppliers and potential Suppliers, we consider reliability, product quality, technical specifications, price, delivery terms and location, product guarantees/warranty, operational costs, support offering, reputation, and financial stability",0,0,0,0,0,0,0,0,0,0,0
SID_255,4603,III,0,0,0,0,0,0,0,0,0,0,0
SID_255,4604,Policies and Due Diligence E3 does not have specific policies and due diligence processes in place relating specifically to forced labour and/or child labour,0,0,0,0,0,0,0,1,0,0,0
SID_255,4605,"However, E3 does have similar policies governing how the Company conducts it business",0,0,0,0,0,0,0,0,0,0,0
SID_255,4606,"Policies E3 is committed to embedding human rights considerations into its policies, governance framework and decision-making and strives to continually evolve and improve its governance processes by implementing new policies and procedures",0,0,0,0,0,0,0,0,0,0,0
SID_255,4607,"While we do not have a specific policy in place relating to modern slavery concerns, E3s core corporate values promote a strong culture of corporate responsibility that empowers our people to create tangible and long-lasting benefits for our future",0,0,0,0,0,0,0,1,0,0,0
SID_255,4608,"All of E3s directors, officers and employees are required to comply with all applicable laws and regulations while fulfilling their duties and responsibilities",0,0,0,0,0,0,0,1,0,0,0
SID_255,4609,"E3 also has a risk mitigation program that identifies, ranks and addresses identified risks to the Company and its projects",0,0,0,0,0,0,0,0,0,0,0
SID_255,4610,"E3s current policies include policies pertaining to: Work Philosophies, including, but not limited to: o Conflict of Interest, Privacy, Intellectual Property, Technology Use Business Conduct and Ethics Environmental, Social and Governance Health, Safety and Environment Diversity, Equity and Inclusion Communication and Reporting Insider Trading and Reporting Whistleblower Procedures",0,0,0,0,0,0,0,1,0,0,0
SID_255,4611,Due Diligence E3 expects its critical Suppliers to comply with all applicable laws and regulations and E3 plans to request confirmation from its Suppliers that they are adhering to the Act,0,0,0,0,0,0,0,1,0,0,0
SID_255,4612,IV,0,0,0,0,0,0,0,0,0,0,0
SID_255,4613,Areas of Risk and Steps Taken to Manage Risk,0,0,0,0,0,0,0,0,0,0,0
SID_255,4614,"Risk Factors In 2023, E3 procured a minimal amount of products, equipment and services from outside of Canada, the United States and Europe",0,0,0,0,0,1,0,0,0,0,0
SID_255,4615,The risk during the period was very low,0,0,0,0,0,0,0,0,0,0,0
SID_255,4616,"Based on E3s review of its supply chain, the Company believes the greatest risk of forced labour and child labour in its supply chain originates from products and equipment sourced outside of Canada, the United States and Europe",0,0,0,0,0,0,1,0,0,0,0
SID_255,4617,The Company plans to engage with critical Suppliers (particularly those who import goods) to confirm their understanding of the Act and to understand how they intend to comply with the requirements,0,0,0,0,0,0,0,0,0,0,0
SID_255,4618,"E3 recognizes that the risks of forced labour and child labour are increased in certain high-risk areas, including: sectors reliant on low-skilled labour, often vulnerable to exploitative practices; dangerous or undesirable roles more likely to involve coercion; migrant workers at risk due to language barriers, uncertain legal status, and isolation; labour brokers or intermediaries that may obscure exploitative employment practices; manufacturing or production in regions with lax labour laws or enforcement, posing a higher risk; extended supply chains lacking transparency, complicating oversight and increasing the likelihood of labour abuses; industries and regions known for prevalent child labour and forced labour; and risks exacerbated by poverty and conflict",0,0,0,0,0,0,0,0,0,0,0
SID_255,4619,"E3 will consider in the future, additional ways to monitor and improve interactions with its employees and Suppliers, especially those in sectors potentially at higher risk of labour exploitation",0,0,0,0,0,0,0,0,0,0,0
SID_255,4620,Risk Management Strategy E3 understands that the risks associated with modern slavery are complex and ever-changing,0,0,0,0,0,0,0,0,0,0,0
SID_255,4621,The potential elimination of forced labour and child labour requires ongoing diligence,0,0,0,0,0,0,0,0,0,0,0
SID_255,4622,"We are committed to continuously identifying and addressing these risks within our business, and will consider in the future how we might refine our policies further to help combat forced labour and child labour",0,0,0,0,0,0,0,0,0,0,0
SID_255,4623,Measures Taken to Remediate Forced Labour or Child Labour and Loss of Income E3 has not identified any instances of forced labour or child labour in its operations or supply chain,0,0,0,0,0,0,1,0,0,0,0
SID_255,4624,"As a result, it has not had to take any measures to remediate any forced labour or child labour",0,0,0,0,0,0,0,0,1,0,0
SID_255,4625,E3 acknowledges that efforts to prevent and reduce forced labor and child labor can unintentionally impact the income of vulnerable families,0,0,0,0,0,0,0,0,0,0,0
SID_255,4626,"However, there have been no identified or reported instances where our measures to eliminate forced or child labor have led to income loss for these families within our activities and supply chains",0,0,0,0,0,0,0,0,0,0,0
SID_255,4627,"Should E3 identify incidents of forced labour or child labour, it may have the option of the following responses: taking actions to halt the identified practices and initiate an investigation to fully understand the issue; DocuSign Envelope ID: 2F9DFB1C-8F09-41B3-9BD1-BA80C667BAA0",0,0,0,0,0,0,0,0,1,0,0
SID_255,4628,"taking measures to ensure the well-being of impacted individuals, focusing on their safety and immediate needs; discussing with relevant parties, including Suppliers, the formulation and execution of a corrective action plan to address underlying causes and prevent recurrence; and conducting a review of associated policies and procedures to identify and implement enhancements that could strengthen its preventive strategies against forced labour and child labour",0,0,0,0,0,0,0,0,1,1,0
SID_255,4629,VI,0,0,0,0,0,0,0,0,0,0,0
SID_255,4630,"Employee Training When onboarding new employees, and annually for existing employees, E3 provides training regarding our safety commitments",0,0,0,0,0,0,0,0,0,0,0
SID_255,4631,"Employees are provided E3s employee handbook, which includes polices outlined in the policy section above and requires annual sign-off",0,0,0,0,0,0,0,1,0,0,0
SID_255,4632,"E3 is also committed to improving the capacity of our employees to understand, identify and manage the risks of modern slavery in our operations and across our supply chains",0,0,0,0,0,0,0,0,0,0,0
SID_255,4633,"E3 will consider in the future, mandatory training modules for new employees to familiarize them with E3s core principles and guidelines",0,0,0,0,0,0,0,1,0,0,0
SID_255,4634,VII,0,0,0,0,0,0,0,0,0,0,0
SID_255,4635,"Assessment of Effectiveness E3 will explore in the future, additional ways to maintain standards of ethics and integrity, which are reflected in its policies referenced above",0,0,0,0,0,0,0,0,0,0,0
SID_255,4636,"Review and Response E3 is evaluating how to address concerns raised through these channels, including taking necessary actions to resolve identified issues",0,0,0,0,0,0,0,0,1,0,0
SID_255,4637,"These actions may include implementing corrective measures, adjusting policies, or providing additional training to prevent recurrence",0,0,0,0,0,0,0,0,1,0,0
SID_255,4638,E3s ongoing evaluation of its governance and compliance processes reflects its interest in upholding ethical business practices and the welfare of its employees and supply chain partners,0,0,0,0,0,0,0,0,0,0,0
SID_255,4639,"Board Oversight E3 will dedicate a line item at a meeting of its corporate governance committee, a sub-committee to the board of directors with board oversight to improving its policies and procedures for identifying and tackling forced labour and child labour in its operations and supply chain",0,0,0,0,0,0,0,1,0,0,0
SID_255,4640,VIII,0,0,0,0,0,0,0,0,0,0,0
SID_255,4641,Approval and Attestation This Report was approved pursuant to subparagraph 11(4)(b)(ii) of the Act by the Board of Directors of E3 Lithium Ltd for all Reporting Entities and has been submitted to the Minister of Public Safety and Emergency Preparedness in Canada,1,0,0,0,0,0,0,0,0,0,0
SID_255,4642,This Report is also available on our company website at https://www.e3lithium.ca/,0,0,0,0,0,0,0,0,0,0,0
SID_255,4643,"In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for the Reporting Entities",0,0,0,0,0,0,0,0,0,0,0
SID_255,4644,"Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the 2023 reporting year",0,0,0,0,0,0,0,0,0,0,0
SID_255,4645,"Chris Doornbos CEO, President & Director May 31, 2024",0,1,0,0,0,0,0,0,0,0,0
SID_255,4646,I have the authority to bind E3 Lithium Ltd,0,0,0,0,0,0,0,0,0,0,0
SID_255,4647,"Schedule A Wholly-owned subsidiaries of E3 Lithium Ltd 1975293 Alberta Ltd 2437798 Alberta Ltd 2216747 Alberta Ltd (Voluntarily dissolved on December 22, 2023) Mexigold Resources SA de CV (Inactive and no assets)",0,0,0,1,0,0,0,0,0,0,0
SID_256,4648,Canada Fighting Forced Labour and Child Labour in Supply Chains Act Report 2023 May 2024,0,0,0,0,0,0,0,0,0,0,0
SID_256,4649,"Canada Fighting Forced Labour and Child Labour in Supply Chains Act Report 2023 1 Introduction This joint report has been prepared in accordance with Canadas Fighting Against Forced Labour and Child Labour in Supply Chains Act (The Act), which came into force on January 1, 2024, on behalf of the bp reporting entities set out belowa (Reporting Entities, bp, we, our, or us)",0,0,0,0,0,0,0,0,0,0,0
SID_256,4650,"This report lays out the steps taken by the Reporting Entities during the nancial year ending December 31, 2023, to prevent forced labour and child labour in our business operations and supply chains",0,0,0,0,0,0,0,0,0,0,0
SID_256,4651,This joint report has been prepared in collaboration with relevant corporate functions and representatives from each relevant Reporting Entity,0,0,0,0,0,0,0,0,0,0,0
SID_256,4652,"Structure, activities and supply chains The Reporting Entities are part of the bp group of companies, which is a global energy business",0,0,0,1,0,0,0,0,0,0,0
SID_256,4653,"The Reporting Entities Canada-based activities focus on buying and selling energy commodities, as well as oshore energy exploration activities in Newfoundland and Labrador",0,0,0,0,1,0,0,0,0,0,0
SID_256,4654,"US-based Reporting Entities are also involved in buying and selling energy commodities in Canada, the United States and elsewhere, as well as rening, and operating retail fuel supply networks in the United States",0,0,0,0,1,0,0,0,0,0,0
SID_256,4655,"Canada-based activities rely on supply chains that focus on sourcing materials and services for transportation and storage of energy commodities, support of the oshore drilling program, and other materials and services incidental to our business",0,0,0,0,1,0,0,0,0,0,0
SID_256,4656,"We procure goods and services from a range of third-parties in dierent businesses including information technology, telecommunications, real estate management, human resources rms, transportation, storage, mail services, research and analytics, consulting services, and oce supplies",0,0,0,0,0,1,0,0,0,0,0
SID_256,4657,a As prescribed by The Act,0,0,0,0,0,0,0,0,0,0,0
SID_256,4658,and its subsidiaries are separate legal entities,0,0,0,0,0,0,0,0,0,0,0
SID_256,4659,References in this report to bp group or bp group of companies are to BP p.l.c,0,0,0,0,0,0,0,0,0,0,0
SID_256,4660,"and its subsidiaries generally, to one or more of them, or to those who work for them",0,0,0,0,0,0,0,0,0,0,0
SID_256,4661,"publishes a statement under the UK Modern Slavery Act, which can be found at https://www.bp.com/en_gb/united-kingdom/home.html under Regulatory Information",0,0,0,0,0,0,0,0,0,0,0
SID_256,4662,"Canada Fighting Forced Labour and Child Labour in Supply Chains Act Report 2023 2 Reporting entity Description of structure/activities BP Canada Energy Group ULC (BPCEG) BPCEG is a Nova Scotia unlimited liability company with its principal operating oce in Calgary, AB and an oce in St",0,0,0,1,1,0,0,0,0,0,0
SID_256,4663,"John, Nd",0,0,0,0,0,0,0,0,0,0,0
SID_256,4664,BPCEG is the main operating entity in Canada,0,0,0,0,1,0,0,0,0,0,0
SID_256,4665,"Its activities include the purchase and sale of natural gas and other commodities within Canada, export and import to/from the United States and the provision of related gas management services, as well as oil and natural gas exploration oshore Newfoundland and Labrador",0,0,0,0,1,0,0,0,0,0,0
SID_256,4666,"BP Canada Energy Marketing Corp (BPCEMC) BPCEMC is a Delaware company with its principal operating oce in Houston, TX and oces in Omaha, NB and Chicago, IL",0,0,0,1,1,0,0,0,0,0,0
SID_256,4667,"Its activities include the purchase and sale of natural gas and biogas in the United States, and the provision of related gas management services IGI Resources Inc (IGI) IGI is an Idaho company with its principal operating oce in Boise, Idaho",0,0,0,0,1,0,0,0,0,0,0
SID_256,4668,"Its activities include the purchase and sale of natural gas in Western Canada and the United States Pacic Northwest regions, and the provision of related gas management services",0,0,0,0,1,0,0,0,0,0,0
SID_256,4669,"BP Products North America Inc (BPPNA) BPPNA is a Maryland company with its principal operating oce in Chicago, IL",0,0,0,1,1,0,0,0,0,0,0
SID_256,4670,"Its primary activities include the purchase and sale of crude oil, condensate and refined products from/to suppliers and customers throughout the Americas",0,0,0,0,1,0,0,0,0,0,0
SID_256,4671,"Refining of crude oil at its two crude oil refineries in the United States located at Whiting, Indiana and Cherry Point, Washington",0,0,0,0,1,0,0,0,0,0,0
SID_256,4672,"Operation of a convenience store and retail fuel supply network in the United States, including the supply of fuel, foods, and other services to bp branded independently operated retail sites",0,0,0,0,1,0,0,0,0,0,0
SID_256,4673,"BP Lubricants USA Inc (BPLUSA) BPLUSA is a Delaware company with its principal operating oce in Wayne, NJ",0,0,0,1,1,0,0,0,0,0,0
SID_256,4674,"Its activities include the development, manufacturing, distribution and marketing of lubricating oils, uids, and greases, as well as provision of related services in the United States and sales in Canada",0,0,0,0,1,0,0,0,0,0,0
SID_256,4675,"Air BP Canada LLC (AirBPC) AirBPC is a Delaware company with its principal operating oce in Houston, TX",0,0,0,1,1,0,0,0,0,0,0
SID_256,4676,Its activities include the purchase and sale of jet fuel from suppliers in Canada and the United States for sale to airline customers in Canada,0,0,0,0,1,0,0,0,0,0,0
SID_256,4677,Canada Fighting Forced Labour and Child Labour in Supply Chains Act Report 2023 3 Policies and due diligence processes bp supports the elimination of forced labour and child labour in line with the International Labour Organization Core Conventions on Rights at Workb,0,0,0,0,0,0,0,0,0,0,0
SID_256,4678,This type of exploitation is contrary to our commitment to respecting the rights of our workforce,0,0,0,0,0,0,0,0,0,0,0
SID_256,4679,Each of the Reporting Entities is a member of the bp group of companies and is required to conduct its activities in conformance with the bp group policies and procedures applicable to their activities,0,0,0,0,0,0,0,0,0,0,0
SID_256,4680,"These policies and procedures set expectations of our interactions within bp, and with external partners, suppliers, and communities where we operate",0,0,0,0,0,0,0,0,0,0,0
SID_256,4681,"We describe here a framework of policies and controls underlying the activities undertaken by the Reporting Entities in 2023 and relating to mapping, assessing, developing and implementing the due diligence processes related to identifying and addressing labour rights and modern slavery (LRMS) risks in our supply chains",0,0,0,0,0,0,0,0,0,0,0
SID_256,4682,Our processes for assessing and managing modern slavery risks are risk-prioritized globally based on geography and work activity,0,0,0,0,0,0,0,0,0,0,0
SID_256,4683,"Since the business activities of the Reporting Entities in Canada and the United States are in many areas lower-risk for modern slavery, relative to business activities in some other geographies, specic actions pursuant to these processes taken for the Reporting Entities business activities may accordingly be relatively limited",0,0,0,0,1,0,1,0,0,0,0
SID_256,4684,b In this report we also refer in places to modern slavery,0,0,0,0,0,0,0,0,0,0,0
SID_256,4685,"This is a term used in policy and law, for example in the UK Modern Slavery Act, to describe forms of exploitation that constitute serious violations of human rights, including forced labour, human tracking, and child labour",0,0,0,0,0,0,0,0,0,0,0
SID_256,4686,Canada Fighting Forced Labour and Child Labour in Supply Chains Act Report 2023 4 Key controls supporting modern slavery prevention bp group control Description How it supports mitigation of modern slavery risks Code of Conduct and Human Rights Policy Establishes principles and expectations for how we work,0,0,0,0,0,0,0,0,0,0,0
SID_256,4687,Code of Conduct underpins and reinforces our Human Rights Policy,0,0,0,0,0,0,0,0,0,0,0
SID_256,4688,These policies apply to all employees,0,0,0,0,0,0,0,0,0,0,0
SID_256,4689,These policies reference recognized human rights and core labour standards as established by International Bill of Human Rights and the International Labour Organizations Declaration on Fundamental Principles and Rights at Work,0,0,0,0,0,0,0,1,0,0,0
SID_256,4690,"In addition to requiring employees to report human rights abuses, we expect them, and encourage contractors, communities and other third-parties, to speak up if they see something they feel to be potentially unsafe, unethical, or harmful",0,0,0,0,0,0,0,1,0,0,0
SID_256,4691,"The policies are supported by a variety of channels to facilitate this speak up culture, such as line managers, supporting teams, ethics and compliance, human resources, or via bp's condential helpline OpenTalk",0,0,0,0,0,0,0,1,0,0,0
SID_256,4692,bp Labour Rights & Modern Slavery (LRMS) Principles The principles are intended to assist our businesses as they work to check performance against our expectations relating to LRMS,0,0,0,0,0,0,0,1,0,0,0
SID_256,4693,"Lays out our expectation that workers in our operations and supply chains are not subject to abusive or inhumane practices, such as child labour, forced labour, tracking, slavery or servitude, discrimination, or harassment",0,0,0,0,0,0,0,1,0,0,0
SID_256,4694,Other bp key controls and policies in the LRMS space align with these principles and expectations,0,0,0,0,0,0,0,0,0,0,0
SID_256,4695,Operating Management System (OMS) Governs our activities where bp operates,0,0,0,0,0,0,0,0,0,0,0
SID_256,4696,"Our OMS provides a framework for delivering safe, reliable, and compliant operations in bp",0,0,0,0,0,0,0,0,0,0,0
SID_256,4697,"It brings together bp requirements on health, safety, security, environment, social performance (including LRMS) and operational reliability, as well as related areas such as maintenance, working with contractors and organizational learning, into a common management system",0,0,0,0,0,0,0,1,0,0,0
SID_256,4698,"Procurement and Supply Chain Management Processes Supports procurement minimum standards, methodology, vendor vetting and management processes",0,0,0,0,0,0,0,0,0,0,0
SID_256,4699,Applies to bp procurement activities,0,0,0,0,0,0,0,0,0,0,0
SID_256,4700,Sets out expectations on how bp procures goods and services in relation to LRMS due diligence,0,0,0,0,0,0,0,1,0,0,0
SID_256,4701,Supported by training and guidance to build awareness on LRMS risks and how to engage with suppliers,0,0,0,0,0,0,0,1,0,0,0
SID_256,4702,Counterparty Due Diligence Sets minimum KYC (Know Your Counterpart) requirements to contract with any third party wishing to do business with bp,0,0,0,0,0,0,0,0,0,0,0
SID_256,4703,"Risk assessment and due diligence of third-parties bp contracts with, that includes corporate structure vetting, assessment of sanctions, criminal activity, negative media coverage for reputational risks (including modern slavery), assignment of risk rating and ongoing dynamic monitoring for updates and red ags",0,0,0,0,0,0,0,1,0,0,0
SID_256,4704,"The Group Investment Assurance and Approvals Process (GIAAP) Governs the evaluation, documentation, and approval of investment projects",0,0,0,0,0,0,0,0,0,0,0
SID_256,4705,"For projects above pre-determined thresholds, sustainability professionals are included in the assurance process, to assess impacts and opportunities, including LRMS risks, arising from the proposed investments",0,0,0,0,0,0,0,1,0,0,0
SID_256,4706,"Canada Fighting Forced Labour and Child Labour in Supply Chains Act Report 2023 5 Assessing and managing our risk bp has taken a risk-based approach to the assessment and identication of modern slavery in our businesses and supply chains, based on business activity, country risk and workforce demographics",0,0,0,0,0,0,0,1,0,0,0
SID_256,4707,"Assessment tools and approach We use external labour rights and modern slavery (LRMS) data sources, such as Maplecroft risk indices, to generate risk heatmaps for the countries in which we operate",0,0,0,0,0,0,0,1,0,0,0
SID_256,4708,"Each country is then categorized as being either low, medium, or highrisk",0,0,0,0,0,0,0,0,0,0,0
SID_256,4709,Canada is identied as low risk by Maplecroft,0,0,0,0,0,0,0,0,0,0,0
SID_256,4710,Country level risk is used in conjunction with the scope of work conducted and workforce composition to perform risk assessments,0,0,0,0,0,0,0,0,0,0,0
SID_256,4711,Risk assessment is included as a requirement in our operating management system (OMS) processes,0,0,0,0,0,0,0,1,0,0,0
SID_256,4712,This approach intends to enable our businesses to determine any further due diligence or actions required to adequately mitigate supply chain LRMS risks,0,0,0,0,0,0,0,0,0,0,0
SID_256,4713,Our operating businesses are working towards conformance with this requirement,0,0,0,0,0,0,0,0,0,0,0
SID_256,4714,"Within the trading & shipping organization, based on an assessment of risk, scale and value, certain investment or divestment cases are required to include an assessment of alignment with bps sustainability frame and the identication of any material sustainability-related impacts and risks, including those related to LRMS, prior to any authority being granted to take the case forward",0,0,0,0,0,0,0,1,0,0,0
SID_256,4715,"Supplier due diligence Before contracts are awarded through our procurement teams processes, we consider suppliers scope of work, location, and workforce composition",0,0,0,0,0,0,0,0,0,0,0
SID_256,4716,This helps us conduct risk assessment and prioritize our due diligence activities,0,0,0,0,0,0,0,0,0,0,0
SID_256,4717,"In 2023, as part of the pre-contract assessment, high-risk suppliers were required to provide our procurement teams with evidence that they have implemented appropriate policies, processes, and practices to manage LRMS risks",0,0,0,0,0,0,0,1,0,0,0
SID_256,4718,"This includes reviewing contractors policies and procedures against LRMS indicators such as recruitment practices, pay and rest periods",0,0,0,0,0,0,0,1,0,0,0
SID_256,4719,High-risk suppliers are also expected to demonstrate that they have shared these with their workforce,0,0,0,0,0,0,0,1,0,0,0
SID_256,4720,This approach enables us to assess whether suppliers can meet our LRMS expectations,0,0,0,0,0,0,0,1,0,0,0
SID_256,4721,"In addition to pre-contract due diligence of new suppliers, LRMS risk assessments are ongoing across the bp groups current global supplier base",0,0,0,0,0,0,0,1,0,0,0
SID_256,4722,"OMS requires our businesses to carry out contractor risk assessments and regular monitoring activities, which form a key part of our routine due diligence",0,0,0,0,0,0,0,1,0,0,0
SID_256,4723,We supplement the risk assessment processes with information sourced through our speak up channels,0,0,0,0,0,0,0,1,0,0,0
SID_256,4724,"Where our assessments and monitoring activities identify gaps or concerns, we work with suppliers to devise prioritized corrective action plans to make ongoing improvements and review their performance during contract review meetings",0,0,0,0,0,0,0,0,1,0,0
SID_256,4725,Canada Fighting Forced Labour and Child Labour in Supply Chains Act Report 2023 6 Remediation measures/assessing eectiveness We encourage a speak up culture among employees and with our contractors and suppliers in their work for us,0,0,0,0,0,0,0,1,0,0,0
SID_256,4726,"Concerns can be raised through OpenTalk, which is available 24 hours a day, seven days a week and in 75 languages",0,0,0,0,0,0,0,1,0,0,0
SID_256,4727,"Concerns can be raised anonymously from most locations, including Canada and the United States, and reports are kept condential to the fullest extent possible, consistent with law and good business practices",0,0,0,0,0,0,0,1,0,0,0
SID_256,4728,Concerns are taken seriously and bp does not tolerate retaliation of any kind,0,0,0,0,0,0,0,1,0,0,0
SID_256,4729,"If we nd that we have caused or directly contributed to adverse impacts on workforce rights, we are committed to provide for, or cooperate in, the remediation of those impacts and work with our contractors and suppliers to encourage them to do the same, in line with our human rights policy",0,0,0,0,0,0,0,0,1,0,0
SID_256,4730,"As stated in the policy, we do not impede access to state-based judicial processes or require individuals to permanently waive their legal right to bring a claim through a judicial process as a precondition of raising a grievance through a bp grievance mechanism",0,0,0,0,0,0,0,1,0,0,0
SID_256,4731,"Where adverse impacts are directly linked to our activities through our business relationships, we will support our business partners in the remediation of those impacts through their own grievance management processes, or support collaboration to provide for non-judicial remediation through third-parties",0,0,0,0,0,0,0,0,1,0,0
SID_256,4732,The Reporting Entities are also in the process of creating and rening a framework to assess the eectiveness of our approach to LRMS risk management for these entities and reporting under the Act,0,0,0,0,0,0,0,0,0,1,0
SID_256,4733,Training Code of Conduct training is mandatory for all bp employees,0,0,0,0,0,0,0,1,0,0,0
SID_256,4734,"bp group also makes available training for use by bp businesses including the Reporting Entities, designed to develop and build the capability needed to eectively identify and manage LRMS risks",0,0,0,0,0,0,0,0,1,0,0
SID_256,4735,"This training focuses on three specic needs: (i) raising awareness of LRMS issues amongst employees across bp; (ii) building capability to meet our LRMS due diligence requirements through targeted training for specic groups of employees, for example, certain procurement and contracting teams; and (iii) developing the specialist skills required by a small group of employees to carry out more in-depth LRMS due diligence",0,0,0,0,0,0,0,0,1,0,0
SID_256,4736,"Approval and attestation This report was approved pursuant to subparagraph 11 (4)(a) of the Act by the board of directors of each of BP Canada Energy Group ULC, BP Canada Energy Marketing Corp., IGI Resources Inc., BP Products North America Inc., Air BP Canada LLC, and BP Lubricants USA Inc as it relates to the activities of each applicable Reporting Entity",1,0,0,0,0,0,0,0,0,0,0
SID_256,4737,"In accordance with the requirements of the Act, and in particular section 11 thereof, I, the undersigned, attest that I have reviewed the information contained in this report for the entity named above my signature",0,0,0,0,0,0,0,0,0,0,0
SID_256,4738,"Based on my knowledge, having exercised reasonable due diligence, I attest that the information in this report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above",0,0,0,0,0,0,0,0,0,0,0
SID_256,4739,"BP Canada Energy Group ULC I have the authority to bind BP Canada Energy Group ULFaLl;: "" a Signaturel:,3,=,2-3E=g3=11=32=42F",0,1,0,0,0,0,0,0,0,0,0
SID_256,4740,"------- Name: Alison Allen Title: Director Date: May 28, 2024 BP Canada Energy Marketing Corp I have the authority to bind BP Canada Energy Marketing  J:!)>.cuSigned by",0,1,0,0,0,0,0,0,0,0,0
SID_256,4741,__!_ J Signature: 03c3soIss34Mo1,0,1,0,0,0,0,0,0,0,0,0
SID_256,4742,"Name: John Jackson Title: _ D_ i _re_c_to_ r ___________ _ Date: May 28, 2024 IGI Resources Inc I have the cuuu,;ttitt.rtiind IGI Resources Inc Signature: j 
 SCAfJft Name: Randy Schultz Title: _ D_ i _re_ c _to_ r ___________ _ Date: May 28, 2024 BP Products North America, Inc I have the authority to bind BP Products North America, l/:Z.""' ; 1 Signature:l:_77Fl3sco33F3341F",0,1,0,0,0,0,0,0,0,0,0
SID_256,4743,"Name: Aleida Rios Title: _D _ir _ec_ t _o _r ___________ _ Date: May 28, 2024 BP Lubricants USA Inc I have the authority to bind BP Lubricants USA Inc G DocuSignedby",0,1,0,0,0,0,0,0,0,0,0
SID_256,4744,"HP S1gnature: 1ee>'<Ell""l>'<Moro",0,1,0,0,0,0,0,0,0,0,0
SID_256,4745,"Name: Hortensia Perez Title: _ D_ i _re_ c_to_ r ___________ _ Date: May 28, 2024 Air BP Canada, LLC I have the CT P'R.9fi;py<te,y:bind Air BP Canada, LLC Signature:"""" fttiSk 36A3II8865IE491",0,1,0,0,0,0,0,0,0,0,0
SID_256,4746,"Name: Laura Hola kovsky Title: _D _ire_c_t _or ___________ _ Date: May 28, 2024 Canada Fighting Forced Labour and Child Labour in Supply Chains Act Report 2023 7",0,1,0,0,0,0,0,0,0,0,0
SID_260,4850,Forced Labour and Child Labour in Supply Chains Report Fiscal Year 2023,0,0,0,0,0,0,0,0,0,0,0
SID_260,4851,"ABOUT THIS REPORT This report relates to the financial year ending December 31, 2023",0,0,0,0,0,0,0,0,0,0,0
SID_260,4852,"It is published by Cap America, Inc (the Company) in compliance with Canadas Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Act)",0,0,0,0,0,0,0,0,0,0,0
SID_260,4853,This report highlights the key activities the Company has undertaken during the last financial year to prevent and reduce the risk that forced labour or child labour be used at any step of the production of goods in Canada or elsewhere by the Company or of goods imported into Canada by the Company,0,0,0,0,0,0,0,0,0,0,0
SID_260,4854,"References in this report to Cap America, we, our and similar terms are to the Company",0,0,0,0,0,0,0,0,0,0,0
SID_260,4855,PREVENTING AND REDUCING RISKS OF FORCED LABOUR AND CHILD LABOUR Cap America strives to be a leader within our industry and our community,0,0,0,0,0,0,0,0,0,0,0
SID_260,4856,"From investing in local educational programs to reducing our carbon footprint, Cap America works to make a difference at the local, national, and global levels",0,0,0,0,0,0,0,0,0,0,0
SID_260,4857,We believe it is in our interest to conduct our business in an honest and honorable fashion in order to create a sustainable work environment for the future of our workers and the Company,0,0,0,0,0,0,0,0,0,0,0
SID_260,4858,"In line with our commitment to ethical employment practices, we are committed to respecting human rights in everything we do and we have a zero-tolerance approach to forced labour and child labour",0,0,0,0,0,0,0,0,0,0,0
SID_260,4859,"During our last financial year, we have taken various steps to prevent and reduce the risk that forced labour or child labour be used in our activities and supply chains, including the following",0,0,0,0,0,0,0,1,0,0,0
SID_260,4860,We have mapped our organizations cotton supply chain and verified high risk areas with isotope testing,0,0,0,0,0,1,0,1,0,0,0
SID_260,4861,We initiated an internal risk assessment of forced labour and child labour in our organizations activities and supply chain based on the information and resources provided by the American Apparel & Footwear Association (AAFA) to make informed decisions,0,0,0,0,0,0,0,1,0,0,0
SID_260,4862,We only worked with Tier 1 suppliers who had recently been audited by reputable third party auditors and ensured none of our suppliers transact business with Xinjiang Production and Construction Corps (XPCC),0,0,0,0,0,0,0,1,0,0,0
SID_260,4863,"We implemented our Code of Conduct throughout our supply chain by requiring all our Tier 1 suppliers to sign it and included a contractual clause to our purchase orders which provides that by accepting the purchase order, the supplier agrees to comply with our Code of Conduct",0,0,0,0,0,0,0,1,0,0,0
SID_260,4864,We continued monitoring our suppliers in China and Vietnam through our Shanghai office,0,0,0,0,0,1,0,1,0,0,0
SID_260,4865,Details of the above actions are set out in this report,0,0,0,0,0,0,0,0,0,0,0
SID_260,4866,ABOUT US & OUR SUPPLY CHAIN Cap America is a privately held manufacturing and wholesale company based in Fredericktown in the state of Missouri in the United States,0,0,0,1,1,0,0,0,0,0,0
SID_260,4867,We sell headwear exclusively to distributors of promotional products and advertising specialties,0,0,0,0,1,0,0,0,0,0,0
SID_260,4868,"Our blank caps and knits are delivered to our Missouri facility which we then decorate with embroidery or patches based on our clients custom orders and then import them into Canada, among other countries, for sale",0,0,0,0,1,0,0,0,0,0,0
SID_260,4869,"We generally source our blank garments from third party manufacturers based in Asia, including China, Vietnam, Bangladesh, and Myanmar",0,0,0,0,0,1,0,0,0,0,0
SID_260,4870,"Since cotton is traded as a commodity, achieving full traceability to farm level can be difficult, especially when a farms output changes every season dependent various factors such as climate, yield, staple length, colour, quality, etc",0,0,0,0,0,0,0,0,0,0,0
SID_260,4871,"Nonetheless, we have been able to confirm through isotope testing on selected cotton samples that the cotton used by our higher risk manufacturers does not originate from the Xinjiang region in China",0,0,0,0,0,0,1,1,0,0,0
SID_260,4872,"POLICIES AND DUE DILIGENCE PROCESSES As we continue to strengthen our processes to reduce risks related to forced and child labour, our policies and due diligence practices are aligned with the risks involved in our activities, our supply chains and our business relationships in a manner conducive to responsible conduct",0,0,0,0,0,0,0,1,0,0,0
SID_260,4873,Our Code of Conduct Our Code of Conduct is the foundation of our human rights risk management approach,0,0,0,0,0,0,0,0,0,0,0
SID_260,4874,"It sets out the values and principles that guide our relationship with our suppliers, their subcontractors, and their workers",0,0,0,0,0,0,0,0,0,0,0
SID_260,4875,"Notably, the Code of Conduct provides for",0,0,0,0,0,0,0,0,0,0,0
SID_260,4876,A prohibition from engaging in any form of forced labour and child labour requiring suppliers to obtain and keep on record documentation to legally prove the date of birth of their workers,0,0,0,0,0,0,0,1,0,0,0
SID_260,4877,"The obligation to operate in full compliance with the laws, rules and regulations of the countries of operation",0,0,0,0,0,0,0,1,0,0,0
SID_260,4878,"The protection of workers rights, freedom of association, and a safe and healthy working environment",0,0,0,0,0,0,0,1,0,0,0
SID_260,4879,"During the last financial year, we implemented our Code of Conduct throughout our supply chain by requiring all our Tier 1 suppliers to sign it",0,0,0,0,0,0,0,1,0,1,0
SID_260,4880,"We also developed a contractual clause in our purchase orders which provides that by accepting the purchase order, the supplier agrees to comply with our Code of Conduct, violations of which may be grounds for the nullification of the purchase order",0,0,0,0,0,0,0,1,1,0,0
SID_260,4881,"The code also adds that Cap America may, at its sole discretion, terminate business with any vendor upon a reasonable belief that the vendor uses or promotes the use of forced, convict, or child labour",0,0,0,0,0,0,0,0,1,0,0
SID_260,4882,"Due Diligence Processes The informal internal risk assessment we conducted on a preliminary basis allowed us to monitor current and prospective Tier 1 suppliers as well as to identify, assess and mitigate any adverse impacts in our operations, supply chains and business relationships",0,0,0,0,0,0,0,1,0,0,0
SID_260,4883,"When initiating collaboration with Tier 1 suppliers, we ensure transparency and accountability by requesting that they provide information on the latest audit conducted at their facilities and that they agree to be bound by our Code of Conduct",0,0,0,0,0,0,0,1,0,0,0
SID_260,4884,"To meet our standards, the audits of our suppliers must have been conducted by reputable third-party auditors such as Worldwide Responsible Accredited Production (WRAP) association and the Sedex Members Ethical Trade Audit (SMETA) association of accredited auditors",0,0,0,0,0,0,0,1,0,0,0
SID_260,4885,"These audits confirm, among other things, that the workers employed in our Tier 1 suppliers factories were recruited voluntarily",0,0,0,0,0,0,0,0,0,1,0
SID_260,4886,"We then collaborate with the factories to ensure corrective action plans and any remediation measures are taken based on the audit recommendations, and we communicate with them on how impacts can be addressed",0,0,0,0,0,0,0,1,0,0,0
SID_260,4887,We track suppliers compliance with our Code of Conduct and social audit recommendations through periodic site visits conducted by our head office or Shanghai office,0,0,0,0,0,0,0,1,0,0,0
SID_260,4888,"Together, these steps allow us to embed responsible business conduct into our organisation and to track implementation and results, as required",0,0,0,0,0,0,0,0,0,0,0
SID_260,4889,"We have no tolerance for suppliers transacting business with high-risk partners, such as the XPCC which has been placed on the U.S",0,0,0,0,0,0,0,0,0,0,0
SID_260,4890,Department of Treasurys Office of Foreign Assets Controls Specially Designated Nationals List,0,0,0,0,0,0,0,0,0,0,0
SID_260,4891,Our suppliers are required to fill out and sign a questionnaire to confirm that XPCC is not among their business partners,0,0,0,0,0,0,0,1,0,0,0
SID_260,4892,"In addition, our Tier 1 and Tier 2 suppliers were vetted by legal counsel to ensure they had no affiliation with XPCC and they do not figure on United States or European Union sanctions lists",0,0,0,0,0,0,0,1,0,0,0
SID_260,4893,"When faced with signs of human rights abuses, we seek to mitigate and cease any negative impact by engaging with our suppliers to remediate the issue, as is further explained below",0,0,0,0,0,0,0,0,0,0,0
SID_260,4894,"RISK ASSESSMENT In the context of our internal risk assessment, we have identified certain parts of our activities and supply chains which carry risks of forced labour and child labour using the List of Goods Produced by Child Labour or Forced Labour list published by the Bureau of International Labour Affairs",0,0,0,0,0,0,1,1,0,0,0
SID_260,4895,"The risks identified are primarily related to the types of goods we produce, sell, distribute and import, the locations of our activities and operations, the type of product we source, the use of migrant labour, and the raw materials or commodities used in our supply chains",0,0,0,0,0,0,1,0,0,0,0
SID_260,4896,We also understand that the risk of forced labour and child labour in the textile supply chain exists and that textile supply chains that extend into certain foreign countries potentially face greater risk of forced labour and child labour,0,0,0,0,0,0,1,0,0,0,0
SID_260,4897,"Although we have strong oversight on our Tier 1 manufacturers, we recognize that they are located in areas where there may be higher prevalence of labour rights abuses",0,0,0,0,0,0,0,0,0,0,0
SID_260,4898,We also acknowledge that our suppliers have their own value chains that may extend into high-risk countries and on which we have limited visibility,0,0,0,0,0,0,0,0,0,0,0
SID_260,4899,"To mitigate the risks associated with suppliers further upstream in the production chain, we have mapped our supply chains and verified high risk areas with isotope testing",0,0,0,0,0,0,0,1,0,0,0
SID_260,4900,"We require our suppliers to provide shipping records and invoicing from the farm to the end product to show traceability and for the higher risk manufacturers, we have started using isotope testing",0,0,0,0,0,0,0,1,0,0,0
SID_260,4901,The testing conducted confirms that the cotton we use is not from the Xinjiang region in China,0,0,0,0,0,1,0,0,0,0,0
SID_260,4902,"Cap America believes that human rights risk assessments play a vital role in promoting ethical sourcing, cultivating sustainable supply chains, and demonstrating responsible due diligence, which ultimately safeguards our business interests and reinforces our commitment to ethical practices",0,0,0,0,0,0,0,0,0,0,0
SID_260,4903,"Cap America continues to prioritize understanding human rights risks within our supply chain, with a focus on forced labour and child labour, and will continue to strive to identify emerging risks",0,0,0,0,0,0,0,0,0,0,0
SID_260,4904,"ACTING ON IDENTIFIED RISKS & IMPACTS Together with partners, we engage in programmes, industry initiatives and activities to address identified risks and impacts",0,0,0,0,0,0,0,0,0,0,0
SID_260,4905,Our initiatives to remediate any forced labour or child labour include engaging with the Workers Right Consortium as a representative for the workers who are at risk of forced labour and child labour in our suppliers factories,0,0,0,0,0,0,0,1,0,0,0
SID_260,4906,"During our last financial year, we were made aware of a situation in one of our Myanmar factories, where unpaid overtime claims were filed",0,0,0,0,0,0,1,0,0,0,0
SID_260,4907,"As a result, we have taken substantial remediation measures by starting to work with the Workers Right Consortium and other brands to remediate alleged unpaid work and will continue to identify and address any gaps in our response",0,0,0,0,0,0,0,0,1,1,0
SID_260,4908,We are monitoring this situation closely and will consider any reasonable action to remediate human rights risks in this factory,0,0,0,0,0,0,0,0,0,0,0
SID_260,4909,TRAINING AND CAPABILITY BUILDING Our AAFA membership allows our workforce to increase its level of understanding of the risks of forced labour and child labour in our business and supply chains,0,0,0,0,0,0,0,1,0,0,0
SID_260,4910,"As members of the AAFA, our compliance team keeps abreast of best practices to decrease the risks of forced labour and child labour in our supply chain by regularly attending AAFA seminars, webinars and conferences addressing critical industry supply chain issues",0,0,0,0,0,0,0,1,0,0,0
SID_260,4911,We routinely use AAFA information and resources to assess and monitor our Tier 1 suppliers social compliance,0,0,0,0,0,0,0,1,0,0,0
SID_260,4912,"We have implemented their CSR Guidance on Assessing Prospective New Supplier social compliance through various measures, Commitment to Responsible Recruitment of employees, and Eradicating Forced Labour policies in our management processes",0,0,0,0,0,0,0,1,0,0,0
SID_260,4913,"Most importantly, our compliance team participates in a biweekly social responsibility consultation with the AAFA Senior vice president of Policy",0,0,0,0,0,0,0,1,0,0,0
SID_260,4914,ASSESSING THE EFFECTIVENESS OF OUR APPROACH Ensuring that forced labour and child labour practices are not taking place in our business and supply chains is and will always be a work in progress,0,0,0,0,0,0,0,0,0,0,0
SID_260,4915,"In order to assess the effectiveness of the measures we have taken to reduce human rights risks, we conduct regular review and audit of our policies and procedures related to forced labour and child labour to ensure their scope and scale are proportionate to the human right risks our organization and supply chain may face",0,0,0,0,0,0,0,0,0,1,0
SID_260,4916,"LOOKING AHEAD As we are committed to further strengthening our efforts in combating human rights abuses, we will continue expanding our cotton isotope testing and we intend to undertake a thorough risk assessment of our supply chains conducted by a recognized provider of inspection and certification services",0,0,0,0,0,0,0,1,0,0,0
SID_260,4917,"*** This report was approved by the Board of Directors of the Company on April 24, 2024 pursuant to paragraph 11(4)(a) of the Act and constitutes our report for the financial year ending December 31, 2023",1,0,0,0,0,0,0,0,0,0,0
SID_260,4918,"In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for the entity listed above",0,0,0,0,0,0,0,0,0,0,0
SID_260,4919,"Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year indicated above",0,0,0,0,0,0,0,0,0,0,0
SID_260,4920,"I have the authority to bind Cap America, Inc",0,1,0,0,0,0,0,0,0,0,0
SID_260,4921,"Full name: Mark Gammon Title: CEO Date: April 24, 2024",0,1,0,0,0,0,0,0,0,0,0
SID_268,5375,"2024 MODERN SLAVERY REPORT Introduction This Report constitutes the first report of Uranium Royalty Corp (""Uranium Royalty"" or the ""Company"") pursuant to Section 11 of Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act (the ""Act"") and sets out the steps taken to prevent and reduce the risk that forced labour or child labour is used at any step of the production of goods in Canada or elsewhere or of goods imported into Canada by the Company (""Modern Slavery Risks"")",0,0,0,0,0,0,0,0,0,0,0
SID_268,5376,"This Report has been prepared for the Company's fiscal year ended April 30, 2024 (the Reporting Period)",0,0,0,0,0,0,0,0,0,0,0
SID_268,5377,Who We Are The Company is committed to ensuring that forced labour and child labour are not used in its supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_268,5378,"Uranium Royalty is a pure-play uranium royalty company focused on gaining exposure to uranium prices by making strategic investments in uranium interests, including royalties, streams, debt and equity investments in uranium companies, as well as through engaging in physical uranium transactions",0,0,0,0,1,0,0,0,0,0,0
SID_268,5379,"At the end of the Reporting Period, the Companys growing portfolio included 20 interests on 18 development, advanced, permitted and producing uranium projects in multiple jurisdictions, including royalties on the McArthur River and Cigar Lake mines, each located in Saskatchewan",0,0,0,1,1,0,0,0,0,0,0
SID_268,5380,"The Company interests in uranium projects and properties are usually limited to receiving payment under its royalties and other interests, which are customarily in cash or through the delivery of physical uranium",0,0,0,0,1,0,0,0,0,0,0
SID_268,5381,"The Company is incorporated under the Canada Business Corporations Act and has two wholly-owned subsidiaries, Uranium Royalty (USA) Corp, a corporation incorporated under the laws of Delaware on October 24, 2018, and Reserve Minerals, LLC, a limited liability company existing under the laws of Delaware",0,0,0,1,0,0,0,0,0,0,0
SID_268,5382,"The Company's head office is located in Vancouver, British Columbia",0,0,0,1,0,0,0,0,0,0,0
SID_268,5383,"For further information regarding the Company and its assets, please refer to its most recent Annual Information Form, a copy of which is available on its website at www.uraniumroyalty.com",0,0,0,0,0,0,0,0,0,0,0
SID_268,5384,"Our Supply Chain The Company's operations are focused on acquiring royalties, streams and other interests in the uranium sector, along with engaging in transactions in physical uranium",0,0,0,0,1,0,0,0,0,0,0
SID_268,5385,"As such, the",0,0,0,0,0,0,0,0,0,0,0
SID_268,5386,"Page 2 Company's physical supply chain is generally limited to: (i) the acquisition of uranium; and (ii) to a lesser extent, sourcing goods and services for its head office operations, such as office equipment, computer equipment, accounting, legal and other advisory or consulting services and other miscellaneous office supplies",0,0,0,0,0,1,0,0,0,0,0
SID_268,5387,The latter are substantially all sourced within Canada and the United States,0,0,0,0,0,1,0,0,0,0,0
SID_268,5388,The Company's supply chain for acquiring physical uranium includes the following,0,0,0,0,0,1,0,0,0,0,0
SID_268,5389,"existing uranium royalty or stream arrangements with operators of uranium mines, whereby physical uranium may be delivered as payment to the Company by the operator of the underlying uranium mine",0,0,0,0,0,1,0,0,0,0,0
SID_268,5390,"Currently, all of the Company's such interests in producing mines are mines located in Saskatchewan, Canada; and",0,0,0,0,0,1,0,0,0,0,0
SID_268,5391,"purchases of physical uranium in market-based purchases through brokers, dealers and other counterparties, including pursuant to long term delivery contracts",0,0,0,0,0,1,0,0,0,0,0
SID_268,5392,"During the Reporting Period, the Company sourced uranium through primarily market-based purchases and an existing royalty agreement with a Canadian mine",0,0,0,0,0,1,0,0,0,0,0
SID_268,5393,How We Work to Ensure Our Supply Chains Are Free of Forced Labour and Child Labour Governance Risk oversight is the responsibility of the Company's board of directors,0,0,0,0,0,0,0,0,0,0,0
SID_268,5394,"The Company's Sustainability Policy, which addresses Modern Slavery Risks and is described below, is overseen by the Company's board of directors",0,0,0,0,0,0,0,1,0,0,0
SID_268,5395,"The Company's board of directors has delegated to its Audit Committee the responsibility to review and monitor its risk management policies and practices generally and reviewing compliance with the Company's Code of Business Conduct and Ethics (the ""Code"")",0,0,0,0,0,0,0,0,0,0,0
SID_268,5396,"In addition, the Company has appointed a Vice President of Environmental, Social and Governance (ESG), who is accountable to ensure the implementation of programs and processes that support its Sustainability Policy, including the management and mitigation of Modern Slavery Risks",0,0,0,0,0,0,0,1,0,0,0
SID_268,5397,"The Company has established and maintains a number of policies, internal controls and procedures relating to the procurement of goods and services, including physical uranium, that are intended to help manage risk and comply with applicable laws and regulatory requirements in the jurisdictions in which we operate or source supplies",0,0,0,0,0,1,0,1,0,0,0
SID_268,5398,Policies Code of Business Conduct and Ethics: Uranium Royalty is committed to the highest ethical standards for conducting its business,0,0,0,0,0,0,0,0,0,0,0
SID_268,5399,The Companys Code establishes standards across the,0,0,0,0,0,0,0,0,0,0,0
SID_268,5400,"Page 3 organization for honest and ethical conduct, fostering a culture of integrity",0,0,0,0,0,0,0,0,0,0,0
SID_268,5401,"The Code also requires Company personnel to at all times obey and comply with all federal, provincial, state and local laws, including those relating to forced labour and child labour",0,0,0,0,0,0,0,1,0,0,0
SID_268,5402,Whistleblower Policy: Uranium Royalty has a Whistleblower Policy that provides a formal framework for employees to report any violations of the Code anonymously and confidentially,0,0,0,0,0,0,0,1,0,0,0
SID_268,5403,"The Company encourages employees to report any situation that appears to involve any breach of the Code, or ethical or legal obligations",0,0,0,0,0,0,0,1,0,0,0
SID_268,5404,The Whistleblower Policy also provides that the Company will not tolerate an attempt on the part of anyone to apply any sanction or detriment to any person who has reported to the Company a serious and genuine concern that they may have about any apparent wrongdoing,0,0,0,0,0,0,0,1,0,0,0
SID_268,5405,Sustainability Policy: The Companys Sustainability Policy outlines its ESG related values,0,0,0,0,0,0,0,0,0,0,0
SID_268,5406,"The policy is designed to ensure that sustainability-related risks, including Modern Slavery risks, and opportunities facing the Company, its third-party operators and suppliers are assessed appropriately as a part of its risk management processes",0,0,0,0,0,0,0,1,0,0,0
SID_268,5407,The policy provides that the Company adheres to the following human rights related principles,0,0,0,0,0,0,0,0,0,0,0
SID_268,5408,"Respect internationally recognized human rights as proclaimed by the Universal Declaration of Human Rights, and the International Labor Organizations Declaration on Fundamental Principles and Rights at Work",0,0,0,0,0,0,0,0,0,0,0
SID_268,5409,This means that we are committed to and seek to align our actions with the United Nations Guiding Principles on Business and Human Rights,0,0,0,0,0,0,0,0,0,0,0
SID_268,5410,"Respect the rights of all people, upholding human rights, and acting with integrity and transparency throughout all of our actions, communications and stakeholder engagement",0,0,0,0,0,0,0,0,0,0,0
SID_268,5411,"Prohibit the use of any form of forced or compulsory labor, including child labor, both within our operations, and by those with which we enter into any business dealing",0,0,0,0,0,0,0,1,0,0,0
SID_268,5412,"We have zero tolerance for such human rights violations committed by our employees, or any third parties entered into business dealings with the Company",0,0,0,0,0,0,0,0,0,0,0
SID_268,5413,We will take appropriate action if a human rights violation is reported,0,0,0,0,0,0,0,0,0,0,0
SID_268,5414,"Procedures Due diligence: When entering into new royalty, streaming or similar agreements with third parties, the Company conducts specific due diligence on Modern Slavery Risks to ensure that we transact with third parties who share and upholds the values outlined in our Code, as well as our Sustainability Policy",0,0,0,0,0,0,0,1,0,0,0
SID_268,5415,"In evaluating such potential transactions, the Company utilizes a disciplined approach to, among others, safeguard against human rights abuses",0,0,0,0,0,0,0,0,0,0,0
SID_268,5416,"When entering into a royalty agreement or other financial arrangement, the Company carefully screens and seeks to select",0,0,0,0,0,0,0,0,0,0,0
SID_268,5417,Page 4 operators who share our principles of responsible environmental and social stewardship,0,0,0,0,0,0,0,0,0,0,0
SID_268,5418,"This process includes reviewing publicly available information, conducting jurisdiction-based reviews and risk assessments and, where available, reviewing the third party's internal policies, procedures and records relating to Modern Slavery Risks",0,0,0,0,0,0,0,1,0,0,0
SID_268,5419,The Company also regularly reviews sanctions and other lists compiled by governmental and non-governmental organizations to identify jurisdictions and entities that have heightened Modern Slavery Risks,0,0,0,0,0,0,0,1,0,0,0
SID_268,5420,"In the case of market-based transactions, due to the nature of uranium as a fungible commodity, the Company has limited access to information to diligence the mine source and related supply chain in each transaction",0,0,0,0,0,0,1,0,0,0,0
SID_268,5421,"However, the Company does have access to information regarding the country of origin underlying each uranium acquisition",0,0,0,0,0,0,1,0,0,0,0
SID_268,5422,"Uranium is not listed as a product where there is a risk of modern slavery on the Global Slavery Index.1 Further, due to the heavily regulated nature of the industry globally, the Company believes there is a low risk of forced labour and child labour in our supply chain",0,0,0,0,0,0,1,0,0,0,0
SID_268,5423,"Given the regulated nature of uranium mining activities globally and the technical nature of such activities, the Company believes Modern Slavery Risks are generally low in relation to its market-based purchases",0,0,0,0,0,0,1,0,0,0,0
SID_268,5424,"In order to further mitigate risks related to market-based purchases, the Company also seeks to deal only with reputable brokers and dealers",0,0,0,0,0,0,0,0,0,0,0
SID_268,5425,"During the Reporting Period, the Company took the following steps to prevent and reduce Modern Slavery Risks in its business and supply chains",0,0,0,0,0,0,0,1,0,0,0
SID_268,5426,Reviewed its existing policies and procedures to ensure they remained up to date and applicable,0,0,0,0,0,0,0,0,0,1,0
SID_268,5427,"In compliance with its policies and procedures, continued conducting due diligence of potential royalty and stream partners and other counterparties before entering into agreements; and",0,0,0,0,0,0,0,1,0,0,0
SID_268,5428,Conducted a management-led assessment of Modern Slavery Risks in the Company's supply chain,0,0,0,0,0,0,0,1,0,0,0
SID_268,5429,Assessment of Modern Slavery Risks in our Supply Chains The Company recognizes that Modern Slavery Risks vary by industry and jurisdiction,0,0,0,0,0,0,0,0,0,0,0
SID_268,5430,Walk Free The Global Slavery Index 2023 (https://cdn.walkfree.org/content/uploads/2023/05/17114737/GlobalSlavery-Index-2023.pdf),0,0,0,0,0,0,0,0,0,0,0
SID_268,5431,"Page 5 The Company does not consider that any of its operations carry Modern Slavery Risks, given its limited operations and business model",0,0,0,0,0,0,1,0,0,0,0
SID_268,5432,"Additionally, due to the heavily regulated nature of the industry the risk is further mitigated",0,0,0,0,0,0,0,0,0,0,0
SID_268,5433,"Finally, as outlined above, the Company has a number of internal policies and controls designed to safeguard the rights of its employees along with its commitment to respecting and observing human rights in accordance with applicable law and the principles set forth in applicable international standards described herein",0,0,0,0,0,0,0,0,0,0,0
SID_268,5434,"Remediation of Modern Slavery Risks and Loss of Income Based on the Company's assessment of its activities and supply chain, as described above, during the Reporting Period, there were no measures taken to remediate any forced labour or child labour or loss of income to the most vulnerable families given that there were no incidents of forced or child labour identified in the Company's operations or supply chain",0,0,0,0,0,0,1,0,1,0,0
SID_268,5435,Assessing Effectiveness The Company has a number of measures to prevent and reduce Modern Slavery Risks in its activities and supply chain,0,0,0,0,0,0,0,0,0,0,0
SID_268,5436,"Given its limited supply chain activities, the Company has not yet taken any formal actions to assess the effectiveness of those measures",0,0,0,0,0,0,0,0,0,1,0
SID_268,5437,It plans to do so at a later stage,0,0,0,0,0,0,0,0,0,0,0
SID_268,5438,Approval and Attestation This Report was approved by the Companys Board of Directors,1,0,0,0,0,0,0,0,0,0,0
SID_268,5439,"In accordance with the requirements of the Act, and in particular section 11 thereof, I, the undersigned, attest that I have reviewed the information contained in this Report for the Company",0,0,0,0,0,0,0,0,0,0,0
SID_268,5440,"Based on my knowledge, and having exercised reasonable diligence, I attest that the information in this Report is true, accurate and complete in all material respects for the purposes of the Act, for the Reporting Period",0,0,0,0,0,0,0,0,0,0,0
SID_268,5441,"_____________________ Scott Melbye Chief Executive Officer, President and Director May 6, 2024",0,1,0,0,0,0,0,0,0,0,0
SID_269,5442,Commercial Bakeries Corp Fighting Against Forced Labour and Child Labour in Supply Chains Act Report 2023,0,0,0,0,0,0,0,0,0,0,0
SID_269,5443,Introduction The Canadian Fighting Against Forced Labour and Child Labour in Supply Chain Act (the Act) requires that businesses state actions they have taken during the most recently completed fiscal year to prevent and reduce the risk of forced labour or child labour within their operations and supply chain,0,0,0,0,0,0,0,0,0,0,0
SID_269,5444,"This report (Report) is solely for Commercial Bakeries Corp (CBC or the Company or we or our), which has an obligation to publish a report under the Act",0,0,0,0,0,0,0,0,0,0,0
SID_269,5445,"This Report refers to the 2023 fiscal year end, being June 30, 2023 (the Reporting Year), and describes steps taken by the Company up to and until June 30, 2023",0,0,0,0,0,0,0,0,0,0,0
SID_269,5446,"At CBC, we consider the respect of human rights to be a fundamental corporate responsibility and a value governing all of our activities",0,0,0,0,0,0,0,0,0,0,0
SID_269,5447,"We recognize our responsibility to respect and protect the human rights of all people who support and intersect with our business, which is comprised of colleagues and employees in our facilities in addition to workers, including migrant and temporary labourers, in our supply chain network",0,0,0,0,0,0,0,0,0,0,0
SID_269,5448,"Our customers trust that the products made in our facility come from suppliers that provide safe, fair, and ethical working conditions for workers",0,0,0,0,0,0,0,0,0,0,0
SID_269,5449,"CBCs commitment to preventing and reducing the risk of forced and child labour applies to our network of facilities, our business partners and our supply chain network",0,0,0,0,0,0,0,0,0,0,0
SID_269,5450,"We expect our business partners and suppliers (as well as their contractors, agents, subcontractors, sub-agents and labour agencies) to uphold these same principles within their operations and adhere to applicable human rights and employment standards laws",0,0,0,0,0,0,0,0,0,0,0
SID_269,5451,"The steps taken this year include, but are not limited to, assessing the risks of forced labour and child labour in our activities and supply chains, and engaging with our supply chain partners on the issues of forced labour and child labour",0,0,0,0,0,0,0,1,0,0,0
SID_269,5452,Our approach to preventing modern slavery forms part of our wider corporate responsibilities,0,0,0,0,0,0,0,0,0,0,0
SID_269,5453,We are adopting procedures that will contribute to ensuring modern slavery does not occur in our business or supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_269,5454,It is our expectation that organizations with whom we do business adopt policies to comply with the relevant legislation,0,0,0,0,0,0,0,0,0,0,0
SID_269,5455,"Structure, Activities and Supply Chain Structure",0,0,0,0,0,0,0,0,0,0,0
SID_269,5456,CBC is a corporation incorporated in the Province of Ontario pursuant to articles of amalgamation under the Business Corporations Act (Ontario),0,0,0,1,0,0,0,0,0,0,0
SID_269,5457,"Our shares are not listed on any Canadian stock exchange, or any other stock exchange in the world",0,0,0,0,0,0,0,0,0,0,0
SID_269,5458,"The Companys registered head office is located in Toronto, Ontario",0,0,0,1,0,0,0,0,0,0,0
SID_269,5459,"Originally established in the early 1950s, CBC stands as a prominent manufacturing company specializing in the production of private label cookie products",0,0,0,0,1,0,0,0,0,0,0
SID_269,5460,"Pioneering the private label concept in the 1970s, CBC has evolved into a leading private label and private brand supplier, serving a multitude of esteemed clients, and shipping high-quality products worldwide",0,0,0,0,1,0,0,0,0,0,0
SID_269,5461,"Activities CBC is exclusively dedicated to this niche, which serves a vast portion of North America",0,0,0,0,1,0,0,0,0,0,0
SID_269,5462,"CBCs diverse product line caters to evolving consumer preferences, including an array of recently popular varieties tailored to health-conscious consumers",0,0,0,0,0,0,0,0,0,0,0
SID_269,5463,"Notably, since 1995, CBCs research and development team has",0,0,0,0,0,0,0,0,0,0,0
SID_269,5464,"spearheaded the creation of a line of delicious sugar-free cookies, further expanded to encompass gluten- free and all-natural organic options, as well as convenient portion control packs",0,0,0,0,0,0,0,0,0,0,0
SID_269,5465,"With certifications as an organic and kosher facility, CBC adheres to the highest quality standards",0,0,0,0,0,0,0,0,0,0,0
SID_269,5466,"Moreover, CBC also transitioned to a peanut-free facility in January 2011, demonstrating the Company prioritization of consumer safety and inclusivity",0,0,0,0,0,0,0,0,0,0,0
SID_269,5467,"With a global footprint extending beyond Canada to Asia, Europe, South Africa, Australia, the Caribbean islands, and the United States, CBC continues to strengthen its presence in key markets whilst upholding its reputation for exceptional product quality and customer satisfaction",0,0,0,0,1,0,0,0,0,0,0
SID_269,5468,CBC is focused on delivering the best services and products in a timely and efficient manner,0,0,0,0,0,0,0,0,0,0,0
SID_269,5469,"As a leading private label cookie manufacturer in Canada, CBC bakes quality cookies, biscuits, and baked snacks for private label brands, club stores, regional and national retailers, quick-service restaurants, institutions, other food manufacturers, and more",0,0,0,0,1,0,0,0,0,0,0
SID_269,5470,Supply Chain The CBC product development team works closely with third party suppliers to develop and manufacture products,0,0,0,0,0,0,0,0,0,0,0
SID_269,5471,"As well, CBC actively sources goods, including when CBC is the Importer of Record (the IOR), from the United States, the Philippines, Madagascar, Cte d'Ivoire, Indonesia, Malaysia, Mexico, Brazil and France",0,0,0,0,0,1,0,0,0,0,0
SID_269,5472,"Policies, Programs and Due Diligence Processes As part of our due diligence processes, CBC strives to embed responsible business conduct into our diverse range of policies both within our company and, to the extent we are able to do so, with respect to our supply chains",0,0,0,0,0,0,0,0,0,0,0
SID_269,5473,Our selection criteria for new suppliers requires that a business with whom we choose to partner meet our standard of a reputable company,0,0,0,0,0,0,0,0,0,0,0
SID_269,5474,Suppliers are evaluated by our internal procurement team prior to partnership to ensure we maintain integrity throughout our supply chains to the best of our ability,0,0,0,0,0,0,0,1,0,0,0
SID_269,5475,Employment,0,0,0,0,0,0,0,0,0,0,0
SID_269,5476,We are committed to the safety and health of employees and we conduct our operations in compliance with applicable laws and regulations,0,0,0,0,0,0,0,0,0,0,0
SID_269,5477,Suppliers are expected to provide a safe working environment,0,0,0,0,0,0,0,0,0,0,0
SID_269,5478,Suppliers are expected to remain in material compliance with all health and safety laws applicable to the operation and use of the facilities at which products are manufactured on our behalf,0,0,0,0,0,0,0,0,0,0,0
SID_269,5479,"Like with many food processing and manufacturing businesses, risks in our supply chain arise because of our limited visibility into our own suppliers supply chains",0,0,0,0,1,0,1,0,0,0,0
SID_269,5480,Recruitment and Selection Process The Companys recruitment process ensures the proper verification of age from government issued identification at multiple stages,0,0,0,0,0,0,0,1,0,0,0
SID_269,5481,"In all cases, each applicant for employment is recruited, hired, and assigned based on merit without discrimination based on race, ancestry, place of origin, colour, ethnic origin, citizenship, creed, sex, sexual orientation, gender identity, gender expression, age, marital status, record of offences, family status, disability, or any other protected ground under the Ontario Human Rights Code (the Code)",0,0,0,0,0,0,0,0,0,0,0
SID_269,5482,"The Company has taken steps to abide by and respect the principles set forth in the Code, the Accessibility for Ontarians with Disabilities Act as amended from time to time as well as the Ontario Employment Standards Act 2000",0,0,0,0,0,0,0,0,0,0,0
SID_269,5483,"Supporting our people Our employee code of conduct (the Employee Code of Conduct) requires all of us to act ethically and we expect employees to comply with legal requirements at all times, putting our values into practice in everything we do",0,0,0,0,0,0,0,1,0,0,0
SID_269,5484,Training Our employees receive regular tailored training on ethical topics and our policies,0,0,0,0,0,0,0,1,0,0,0
SID_269,5485,"All new employees are assigned a mandatory onboarding training package, which includes training on all matters covered in the Employee Code of Conduct",0,0,0,0,0,0,0,1,0,0,0
SID_269,5486,Employees who are involved in the onboarding process in the procurement function are given on the job training to help ensure the process is performed correctly,0,0,0,0,0,0,0,0,0,0,0
SID_269,5487,"Further Steps We plan to take the following steps in the future, some of which are nearly in place, and others, which will require a longer timeline, to further guard against the risk of modern slavery and trafficking",0,0,0,0,0,0,0,1,0,0,0
SID_269,5488,we are in the process of finalizing our supplier code of conduct (Supplier Code of Conduct) and we are committed to working with current and prospective suppliers to ensure ethical business practices and a clear understanding and appreciation of the values that will be reflected in our Supplier Code of Conduct,0,0,0,0,0,0,0,1,0,0,0
SID_269,5489,"we will begin to provide ongoing training to all procurement personnel to ensure a deep understanding of the Supplier Code of Conduct, our principles and our values",0,0,0,0,0,0,0,1,0,0,0
SID_269,5490,"we will continue to examine ways to improve our assessment and management of risks in various jurisdictions through awareness, training, best practices or other assistance to our employees and suppliers; and",0,0,0,0,0,0,0,1,0,0,0
SID_269,5491,take steps to improve our ongoing due diligence procedures in relation to modern slavery risks in our supply chain,0,0,0,0,0,0,0,1,0,0,0
SID_269,5492,"This includes developing a process by which we can assess and audit the compliance of our suppliers with the Supplier Code of Conduct being developed, and through that, compliance with the Act",0,0,0,0,0,0,0,0,0,0,0
SID_269,5493,Assessing and Managing Risk We recognize that the risk of modern slavery being used in operations varies by industry and jurisdiction and that those risks are elevated in the food processing and manufacturing sector,0,0,0,0,0,0,1,0,0,0,0
SID_269,5494,"We acknowledge that the raw materials procurement process does not often take place from our direct suppliers, but may occur further down the supply chain",0,0,0,0,0,0,0,0,0,0,0
SID_269,5495,This reduces our visibility over the raw materials used within our supply chain to produce components used in manufacturing,0,0,0,0,0,0,1,0,0,0,0
SID_269,5496,"In order to assess and manage the serious risks associated with forced labour and child labour effectively, CBC arranged for a third-party social compliance audits under the Sedex Members Ethical Trade Audit (SMETA)",0,0,0,0,0,0,0,1,0,0,0
SID_269,5497,"CBC also received a satisfactory rating from UL Solutions, which completed an audit",0,0,0,0,0,0,0,1,0,0,0
SID_269,5498,Remediation Measures,0,0,0,0,0,0,0,0,0,0,0
SID_269,5499,"To date, we have not identified any specific instances of forced labour or child labour in the supply chain",0,0,0,0,0,0,1,0,0,0,0
SID_269,5500,"As such, no remediation activities have been undertaken by us and no remediation measures have been taken to remediate any loss of income that resulted from measures taken by us",0,0,0,0,0,0,0,0,0,0,0
SID_269,5501,Training provided to employees on forced labour and child labour,0,0,0,0,0,0,0,0,0,0,0
SID_269,5502,"Employees are familiarized with the Companys policies and procedures regarding ethical labour practices, including our zero-tolerance policy towards forced labour and child labour",0,0,0,0,0,0,0,1,0,0,0
SID_269,5503,They are trained on how to report any concerns or suspicions they may have through appropriate channels,0,0,0,0,0,0,0,1,0,0,0
SID_269,5504,Other offerings in this respect include,0,0,0,0,0,0,0,0,0,0,0
SID_269,5505,Annual Refresher Training It is crucial to stay updated on issues like forced labour and child labour undergo regular training to recognize and address it effectively,0,0,0,0,0,0,0,1,0,0,0
SID_269,5506,"With our annual refresher training we try to reinforce knowledge, update on legal changes, and share new strategies for prevention and intervention",0,0,0,0,0,0,0,1,0,0,0
SID_269,5507,"These sessions typically cover topics such as identifying signs of forced labour and child labour, understanding relevant laws and regulations, learning about vulnerable industries and regions, and exploring best practices for reporting and addressing instances of forced labour and child labour",0,0,0,0,0,0,0,1,0,0,0
SID_269,5508,With regular training CBC ensures that individuals and organizations remain vigilant and equipped to combat this serious issue,0,0,0,0,0,0,0,0,0,0,0
SID_269,5509,Responsibilities and Accountability Employees are informed of their responsibilities in upholding ethical labour practices and the consequences of non-compliance,0,0,0,0,0,0,0,1,0,0,0
SID_269,5510,They understand that adherence to these standards is essential to maintaining CBC's reputation and integrity,0,0,0,0,0,0,0,0,0,0,0
SID_269,5511,Assessing Effectiveness,0,0,0,0,0,0,0,0,0,0,0
SID_269,5512,CBC is in the process of implementing a number of measures to prevent and reduce the risk that forced labour or child labour is used in our activities and supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_269,5513,"While we have not yet taken any actions to assess the effectiveness of those actions, CBC intends to assess its effectiveness in preventing and reducing risks of forced labour and child labour in its activities and supply chains at a later stage",0,0,0,0,0,0,0,0,0,1,0
SID_269,5514,We acknowledge our responsibility to combat forced and child labour and are committed to acting ethically and with integrity and transparency,0,0,0,0,0,0,0,0,0,0,0
SID_269,5515,We are working to put systems and controls in place to safeguard against any form of forced or child labour taking place within the business or our supply chain,0,0,0,0,0,0,0,0,0,0,0
SID_269,5516,"As of June 30, 2023, CBC has not faced situations of forced labour or child labour and has therefore not had to remedy and rectify such situations",0,0,0,0,0,0,1,0,0,0,0
SID_269,5517,Approval and Attestation,0,0,0,0,0,0,0,0,0,0,0
SID_269,5518,The Report was approved pursuant to subparagraph 11(4)(b)(ii) of the Act by the Companys board of directors,1,0,0,0,0,0,0,0,0,0,0
SID_269,5519,"In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for the entity or entities listed above",0,0,0,0,0,0,0,0,0,0,0
SID_269,5520,"Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above",0,0,0,0,0,0,0,0,0,0,0
SID_269,5521,Shawn Warren (signed) Shawn Warren Chief Executive Officer Commercial Bakeries Corp I have authority to bind Commercial Bakeries Corp,0,1,0,0,0,0,0,0,0,0,0
SID_273,5763,"P a g e | 1 Fiscal Year End December 31, 2023 RADIAL, INC",0,0,0,0,0,0,0,0,0,0,0
SID_273,5764,"SECTION I: IDENTIFYING INFORMATION In addition to the information contained in our online questionnaire completed as part of our 2024 Report filing process, this report is filed on behalf of Radial, Inc (Radial) for the fiscal year ending December 31, 2023 in accordance with the requirements of Canadas Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Act)",0,0,0,0,0,0,0,0,0,0,0
SID_273,5765,Radial is a corporate entity incorporated under the laws of the Commonwealth of Pennsylvania; its Canadian Business Number is 848873063,0,0,0,1,0,0,0,0,0,0,0
SID_273,5766,"Radial is a Third-Party Logistics Provider, which is headquartered in the United States",0,0,0,1,1,0,0,0,0,0,0
SID_273,5767,Radials service in Canada is providing order management and fulfillment for its e-commerce customers from its Canadian fulfillment centers,0,0,0,0,1,0,0,0,0,0,0
SID_273,5768,The following categorization set out in the Act applies to Radial,0,0,0,0,0,0,0,0,0,0,0
SID_273,5769,Canadian business presence,0,0,0,0,0,0,0,0,0,0,0
SID_273,5770,Has a place of business in Canada Does business in Canada Has assets in Canada,0,0,0,0,0,0,0,0,0,0,0
SID_273,5771,Meets size-related thresholds,0,0,0,0,0,0,0,0,0,0,0
SID_273,5772,"Has at least $20 million in assets for at least one of its two most recent financial years Has generated at least $40 million in revenue for at least one of its two most recent financial years Employs an average of at least 250 employees for at least one of its two most recent financial years companywide, including non-Canadian employees",0,0,0,0,0,0,0,0,0,0,0
SID_273,5773,Radial also distributes goods in Canada or elsewhere,0,0,0,0,0,0,0,0,0,0,0
SID_273,5774,SECTION II ANNUAL REPORT Radials structure and activities are described in Section I of this Report,0,0,0,0,0,0,0,0,0,0,0
SID_273,5775,"As a third-party logistics provider, Radial's supply chain is limited and includes primarily the vendors and suppliers who provide us with the materials and equipment we need to support our activities as a service provider",0,0,0,0,1,0,0,0,0,0,0
SID_273,5776,"In fiscal year 2023, Radial has taken the following steps to prevent and reduce the risk that forced labour or child labour is used at any step of the production of goods in Canada or elsewhere by the entity or of goods imported into Canada by Radial",0,0,0,0,0,0,0,1,0,0,0
SID_273,5777,Developing and implementing child protection policies and processes Developing and implementing anti-forced labour and/or -child labour contractual clauses DocuSign Envelope ID: B4E1CD26-AECC-476D-87D7-B42CB311089E,0,0,0,0,0,0,0,1,0,0,0
SID_273,5778,"P a g e | 2 Fiscal Year End December 31, 2023",0,0,0,0,0,0,0,0,0,0,0
SID_273,5779,"In light of Radials role in the supply chain (primarily as a third-party logistics services provider), Radials forced/child labour supply chain risks are considered low and our policies and compliance infrastructure is properly calibrated to our level of risk",0,0,0,0,0,0,1,0,0,0,0
SID_273,5780,"The company has adopted a Supplier Code of Conduct, which has been rolled out to Radials Canadian third-party staffing vendors",0,0,0,0,0,0,0,0,0,0,0
SID_273,5781,Radial will look to incorporate the Supplier Code of Conduct into its contracts with other key vendors going forward,0,0,0,0,0,0,0,0,0,0,0
SID_273,5782,"In addition, to guard against force/child labour risks, the company does not hire anyone under the age of 18",0,0,0,0,0,0,0,1,0,0,0
SID_273,5783,The company is committed to the fight against forced and child labour in supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_273,5784,"We will continue to monitor our risk profile and regularly review, and enhance as needed, our policies and practices in this area, in line with recognized best practices",0,0,0,0,0,0,0,0,0,0,0
SID_273,5785,Radial has not yet identified parts of its activities and supply chains that carry a risk of forced labour or child labour being used,0,0,0,0,0,0,1,0,0,0,0
SID_273,5786,"However, as stated above, In light of our role in the supply chain (primarily as a third-party logistics services provider), our forced/child labour supply chain risks are considered low and our policies and compliance infrastructure is properly calibrated to our level of risk",0,0,0,0,0,0,1,0,0,0,0
SID_273,5787,"To date, Radial has not identified any forced or child labour in its supply chain and has, therefore, not taken any related remediation measures",0,0,0,0,0,0,1,0,1,1,0
SID_273,5788,"Likewise, since we have not taken remediation measures, we have not taken any measures to compensate for loss of income to vulnerable families resulting from measures taken to eliminate the use of forced labour or child labour in our activities and supply chains",0,0,0,0,0,0,0,0,0,0,0
SID_273,5789,"At this time, given our low risk profile for forced or child labour in our supply chain, we have not deployed dedicated training on forced or child labour in supply chains",0,0,0,0,0,0,1,1,0,0,0
SID_273,5790,The company regularly reassesses its risk profile and reviews it policies and compliance infrastructure,0,0,0,0,0,0,0,1,0,1,0
SID_273,5791,"As such, our current training practices may change in the future, should we determine that training on forced/child labour risks becomes warranted",0,0,0,0,0,0,0,1,0,0,0
SID_273,5792,"Likewise, given our low risk profile and role in the industry, we have not developed a specific methodology for assessing our effectiveness in ensuring that forced or child labour are not used in Radials supply chain",0,0,0,0,0,0,1,0,0,1,0
SID_273,5793,The company will periodically reassesses its supply chain risks and review its policies and practices for alignment with best practices in our industry,0,0,0,0,0,0,0,1,0,1,0
SID_273,5794,"P a g e | 3 Fiscal Year End December 31, 2023",0,0,0,0,0,0,0,0,0,0,0
SID_273,5795,"RADIAL, INC",0,0,0,0,0,0,0,0,0,0,0
SID_273,5796,ATTESTATION,0,0,0,0,0,0,0,0,0,0,0
SID_273,5797,"In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for the entity or entities listed above",0,0,0,0,0,0,0,0,0,0,0
SID_273,5798,"Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above",0,0,0,0,0,0,0,0,0,0,0
SID_273,5799,"Full name: Laura Ritchey Title: Chief Executive Officer Date: May 22, 2024",0,1,0,0,0,0,0,0,0,0,0
SID_273,5800,"I have the authority to bind Radial, Inc ___________________________",0,1,0,0,0,0,0,0,0,0,0
SID_273,5801,Signature,0,1,0,0,0,0,0,0,0,0,0
SID_290,8100,Canada - 2023 Annual Report This Annual Report has been produced by Tiffany & Co,0,0,0,0,0,0,0,0,0,0,0
SID_290,8101,"Canada (""Tiffany & Co",0,0,0,0,0,0,0,0,0,0,0
SID_290,8102,"Canada"" or the ""Company"") pursuant to the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the ""Act"")",0,0,0,0,0,0,0,0,0,0,0
SID_290,8103,It sets out the steps that Tiffany & Co,0,0,0,0,0,0,0,0,0,0,0
SID_290,8104,"Canada has taken during its previous financial year ending December 31, 2023 to prevent and reduce the risk that forced or child labour is used in the production of goods imported into Canada by the Company",0,0,0,0,0,0,0,0,0,0,0
SID_290,8105,The report also provides supplementary information as is required under the Act,0,0,0,0,0,0,0,0,0,0,0
SID_290,8106,"Structure, Activities and Supply Chains Tiffany & Co",0,0,0,0,0,0,0,0,0,0,0
SID_290,8107,Canada is incorporated under the Nova Scotia Companies Act,0,0,0,1,0,0,0,0,0,0,0
SID_290,8108,"It is an indirect, wholly owned subsidiary of Tiffany & Co (together with its other relevant subsidiaries, ""Tiffany""), an American holding company that conducts business globally through its subsidiary companies, including Tiffany & Co",0,0,0,1,0,0,0,0,0,0,0
SID_290,8109,"Tiffany is ultimately owned by LVMH Moet Hennessy Louis-Vuitton SE (""LVMH""), a multinational conglomerate specializing in luxury goods, headquartered in France",0,0,0,1,1,0,0,0,0,0,0
SID_290,8110,Canada is engaged in marketing and selling Tiffany & Co.-branded products in Canada,0,0,0,0,1,0,0,0,0,0,0
SID_290,8111,"Tiffany designs, manufactures, and markets jewelry, watches, and luxury accessories",0,0,0,0,1,0,0,0,0,0,0
SID_290,8112,"Tiffany maintains substantial control over its product supply chain through internal jewelry manufacturing and direct diamond sourcing, and then supplies these products to its subsidiaries, including Tiffany & Co",0,0,0,0,1,1,0,0,0,0,0
SID_290,8113,"Tiffany manufactures jewelry in the United States in New York, Rhode Island and Kentucky, polishes and performs certain assembly work on jewelry in the Dominican Republic and crafts silver hollowware in Rhode Island",0,0,0,0,1,0,0,0,0,0,0
SID_290,8114,"In total, these internal manufacturing facilities produce approximately 60% of the units of jewelry sold by Tiffany and its subsidiaries, including Tiffany & Co",0,0,0,0,1,0,0,0,0,0,0
SID_290,8115,"The balance, and almost all non-jewelry items, is purchased from third parties that manufacture products to Tiffany's specifications",0,0,0,0,0,1,0,0,0,0,0
SID_290,8116,"To supply its internal manufacturing facilities, Tiffany processes, cuts and polishes rough diamonds at its facilities outside the US and sources precious metals, polished diamonds and other gemstones, as well as certain fabricated components, from third parties",0,0,0,0,1,0,0,0,0,0,0
SID_290,8117,"Both these third parties and those who supply finished goods to Tiffany constitute Tiffany's ""supply chain partners",0,0,0,0,1,0,0,0,0,0,0
SID_290,8118,"Tiffany subsidiaries that conduct retail and distribution activities worldwide source their products from Tiffany such that Tiffany's global subsidiaries, including Tiffany & Co",0,0,0,0,1,1,0,0,0,0,0
SID_290,8119,"Canada, share the same product supply chain",0,0,0,0,0,1,0,0,0,0,0
SID_290,8120,Tiffany and Tiffany & Co,0,0,0,0,0,0,0,0,0,0,0
SID_290,8121,"Canada have long been committed to conducting business responsibly, sustaining the natural environment and positively impacting the communities in which the companies operate",0,0,0,0,0,0,0,0,0,0,0
SID_290,8122,"Additional information about Tiffany's global sustainability strategy and initiatives, which applies to Tiffany & Co",0,0,0,0,0,0,0,0,0,0,0
SID_290,8123,"Canada and its supply chain, is available at https://www.tiffany.com/sustainability/",0,0,0,0,0,0,0,0,0,0,0
SID_290,8124,"Tiffany has an Ethics and Compliance Committee consisting of cross-functional leaders from throughout the organization, including its Chief Executive Officer and other members of its senior management team",0,0,0,0,0,0,0,0,0,0,0
SID_290,8125,"The Committee is chaired by Tiffany's Chief Compliance Officer and is responsible for leading and overseeing ethics and compliance matters at Tiffany and its subsidiaries, including Tiffany & Co",0,0,0,0,0,0,0,0,0,0,0
SID_290,8126,The Committee's oversight includes matters pertaining to misconduct (including violations related to human rights risk) in Tiffany's supply chain and owned operations,0,0,0,0,0,0,0,1,0,0,0
SID_290,8127,"Steps Taken to Prevent and Reduce Risks of Forced Labour and Child Labour During the previous financial year, Tiffany undertook the following steps, which are relevant to Tiffany & Co",0,0,0,0,0,0,0,1,0,0,0
SID_290,8128,Canada's supply chain,0,0,0,0,0,0,0,1,0,0,0
SID_290,8129,Developed and implemented action plans for and engaged with supply chain partners on the issue of addressing forced or child labour,0,0,0,0,0,0,0,1,0,0,0
SID_290,8130,"Tiffany conducts biennial risk assessments as part of its Social and Environmental Accountability Program (""SEA Program"") with all of its jewelry manufacturing and diamond polishing facilities, supply chain partners, and other key suppliers to identify regional and supplier risks related to social and environmental compliance",0,0,0,1,1,0,0,0,0,0,0
SID_290,8131,"Throughout 2023, Tiffany engaged with relevant supply chain partners to draft corrective action plans for non-conformances and critical risks that emerged from the 2022 risk assessments",0,0,0,0,0,0,0,0,1,0,0
SID_290,8132,"In addition, Tiffany conducted third-party audits of certain new supply chain partners in 2023 and issued new corrective action plans for non-conformances",0,0,0,0,0,0,0,1,1,0,0
SID_290,8133,Verification re- audits were also conducted where critical risks were identified,0,0,0,0,0,0,0,1,0,0,0
SID_290,8134,"In addition, in 2023, Tiffany's SEA Program identified some gaps in human rights-related policies and procedures for a fractional percentage of its total supply chain partners",0,0,0,0,0,0,0,0,0,0,0
SID_290,8135,"In response to these findings, Tiffany engaged with the relevant supply chain partners to establish corrective action plans to address those gaps in their policies and procedures and ensure that robust monitoring systems are in place to minimize the risk of modern slavery entering their supply chains",0,0,0,0,0,0,0,1,1,0,0
SID_290,8136,"Developed and implemented due diligence policies and processes for identifying, addressing and prohibiting the use of forced or child labour in the organization's activities and supply chains",0,0,0,0,0,0,0,0,0,0,0
SID_290,8137,"In 2023, Tiffany continued to enhance its risk assessment processes, questionnaires and procedures to continually improve its ability to identify, mitigate and account for risks within its supply chain and its owned operations",0,0,0,0,0,0,0,1,0,0,0
SID_290,8138,Tiffany requires supply chain partners to have robust policies and procedures in place to identify and minimize the risk of forced labour and child labour in their activities and supply chains,0,0,0,0,0,0,0,1,0,0,0
SID_290,8139,"Developed and implemented anti-forced labour and child labour contractual clauses, standards, codes of conduct and/or compliance checklists",0,0,0,0,0,0,0,1,0,0,0
SID_290,8140,"In 2023, Tiffany continued to rollout the LVMH Supplier Code of Conduct (with the Tiffany addendum, the ""Supplier Code"") to supply chain partners and other key suppliers, including by making the updated Supplier Code of Conduct available online through its website, including on Tiffany.ca",0,0,0,0,0,0,0,1,0,0,0
SID_290,8141,"The Supplier Code is incorporated into relevant contracts and sets clear expectations for Tiffany's supply chain partners, including that the LVMH Group does not tolerate any form of abusive or illegal labor in its supply chain such as forced labor or human trafficking",0,0,0,0,0,0,0,1,0,0,0
SID_290,8142,"See ""Supplier Code of Conduct"" for more information",0,0,0,0,0,0,0,0,0,0,0
SID_290,8143,Continued to audit and monitor Tiffany's supply chain partners,0,0,0,0,0,0,0,0,0,0,0
SID_290,8144,"Through its SEA Program, Tiffany continued to conduct pre-sourcing audits and reassess risks as it engaged and contracted with new supply chain partners in 2023",0,0,0,0,0,0,0,1,0,0,0
SID_290,8145,Tiffany also continued to monitor its existing supply chain partners for new risks through ongoing business monitoring,0,0,0,0,0,0,0,1,0,0,0
SID_290,8146,Developed and implemented grievance mechanisms,0,0,0,0,0,0,0,0,0,0,0
SID_290,8147,"All Tiffany stakeholders can notify Tiffany through various channels if any of Tiffany's requirements are not being met, including those concerning forced or child labour",0,0,0,0,0,0,0,1,0,0,0
SID_290,8148,"See ""Alert Line"" for more information",0,0,0,0,0,0,0,0,0,0,0
SID_290,8149,Developed and implemented training and awareness materials on forced labour and child labour,0,0,0,0,0,0,0,1,0,0,0
SID_290,8150,"Tiffany engages with supply chain partners on the issue of addressing forced labour and child labour by providing ongoing training resources and communicating clear expectations related to its Supplier Code through an on line responsible sourcing education platform, which is available to all of its supply chain partners year-round",0,0,0,0,0,0,0,1,0,0,0
SID_290,8151,"In 2023, Tiffany continued to provide training resources and engage with new and existing suppliers on various topics, including on Tiffany's Human Rights Policy and on Forced Labour Prevention",0,0,0,0,0,0,0,1,0,0,0
SID_290,8152,"See ""Training and Awareness"" for more information",0,0,0,0,0,0,0,0,0,0,0
SID_290,8153,The Risks of Forced Labour and Child Labour in Tiffany's Operations and Supply Chains Tiffany & Co,0,0,0,0,0,0,0,0,0,0,0
SID_290,8154,Canada sources the products it distributes in Canada from Tiffany such that Tiffany and Tiffany & Co,0,0,0,0,0,1,0,0,0,0,0
SID_290,8155,Canada share the same product supply chain,0,0,0,0,0,1,0,0,0,0,0
SID_290,8156,Tiffany has actively promoted respect for human rights for more than two decades and continuously assesses human rights risks within its supply chain,0,0,0,0,0,0,0,0,0,0,0
SID_290,8157,Tiffany recognizes that there is the risk that forced or child labour may be used at any level or tier of the luxury good supply chain and that use of migrant labour or unauthorized subcontracted labor is a possibility,0,0,0,0,0,0,1,0,0,0,0
SID_290,8158,"In particular, sourcing raw materials and working with external manufacturing facilities continue to be areas of high risk that Tiffany closely monitors through its assessment programs",0,0,0,0,0,0,1,0,0,0,0
SID_290,8159,"With respect to raw materials, Tiffany recognizes that there are risks associated with the use and supply of precious metals, diamonds and gemstones, including the potential use of conflict diamonds in its supply chain, or sourcing of gold or gemstones from conflict affected high risk regions",0,0,0,0,0,1,1,0,0,0,0
SID_290,8160,"In addition, Tiffany recognizes that the risks of forced or child labour vary around the world according to local regulations, local culture, and the enforcement of employment terms and conditions in applicable jurisdictions",0,0,0,0,0,0,0,0,0,0,0
SID_290,8161,"Tiffany uses robust independent data from Maplecroft, a global risk and strategic consulting firm, to bolster its risk assessments and to identify geographic risks within its supply chain",0,0,0,0,0,0,0,1,0,0,0
SID_290,8162,Maplecroft is an organization recognized as a benchmark for excellent assessment of global risks,0,0,0,0,0,0,0,0,0,0,0
SID_290,8163,"Maplecroft's human rights dataset comprises over 34 indices, forming a structured dataset covering the full spectrum of labour, civil, and political rights across all countries",0,0,0,0,0,0,0,0,0,0,0
SID_290,8164,"Tiffany applies enhanced scrutiny to identified high risk situations, in addition to communicating to its supply chain partners that all modern slavery, including but not limited to forced and child labour, bonded labour, and human trafficking are zero tolerance issues that will subject the supply chain partner to a halt of business, and may lead to the removal of the supplier from the Tiffany supply chain",0,0,0,0,0,0,0,1,1,0,0
SID_290,8165,"Tiffany is committed to continuously improving its risk assessment processes to continually improve its ability to identify, mitigate and account for risks within its supply chain and its owned operations",0,0,0,0,0,0,0,0,0,0,0
SID_290,8166,"Due Diligence Processes & Policies in Relation to Forced Labour and Child Labour To minimize the risk of forced or child labor in its supply chain, Tiffany and its subsidiaries, including Tiffany & Co",0,0,0,1,0,0,0,0,0,0,0
SID_290,8167,"Canada, adhere to the policies and processes described below",0,0,0,1,0,0,0,0,0,0,0
SID_290,8168,"Policies Concerning Forced and Child Labour Tiffany has long been committed to ensuring respect of the International Labour Organization Core Conventions, United Nations Universal Declaration of Human Rights, and United Nations Global Compact",0,0,0,0,0,0,0,1,0,0,0
SID_290,8169,These standards are central to its responsible business policies and are the foundation for many of Tiffany's labour-related policies,0,0,0,0,0,0,0,1,0,0,0
SID_290,8170,"Code of Conduct Tiffany's worldwide Business Conduct Policy (""Business Conduct Policy"") sets forth rules and principles that apply to the work conducted by Tiffany to ensure compliance by Tiffany and its employees with Tiffany's expectations regarding ethical behavior",0,0,0,0,0,0,0,0,0,0,0
SID_290,8171,"As a subsidiary of LVMH Moet Hennessy Louis-Vuitton SE (""LVMH""), Tiffany incorporates the LVMH Code of Conduct into its Business Conduct Policy to ensure that Tiffany and its employees also adhere to the ethical framework for actions and decisions expected by LVMH",0,0,0,1,0,0,0,0,0,0,0
SID_290,8172,"All employees are required to sign an annual commitment to the principles set forth in the Business Conduct Policy (and the incorporated LVMH Code of Conduct}, including commitments to act responsibly, with social awareness and with respect for human rights and fundamental freedoms",0,0,0,0,0,0,0,1,0,0,0
SID_290,8173,"Tiffany Human Rights Policy The Tiffany Human Rights Policy captures Tiffany's approach to integrating human rights across its value chain in addition to addressing its most salient human rights risks, impacts, and opportunities",0,0,0,0,0,0,0,0,0,0,0
SID_290,8174,"This policy integrates existing Tiffany policies with human rights touch points, articulating a unified vision and approach to managing and promoting human rights",0,0,0,0,0,0,0,0,0,0,0
SID_290,8175,All Tiffany employees are required to complete mandatory training on the Tiffany Human Rights Policy during new hire onboarding,0,0,0,0,0,0,0,1,0,0,0
SID_290,8176,"Supplier Code of Conduct Tiffany's commitment to identifying, preventing, and mitigating modern slavery, human trafficking and forced and child labour is also in the Supplier Code",0,0,0,0,0,0,0,1,0,0,0
SID_290,8177,"The Supplier Code, which Tiffany amends from time to time, sets out general principles and requirements that are applicable to all suppliers",0,0,0,0,0,0,0,1,0,0,0
SID_290,8178,"Further, Tiffany's supply chain partners, their subcontractors that are approved to provide goods or services to Tiffany, and select service providers, are required to fully comply with the Supplier Code as a part of Tiffany's purchasing agreements",0,0,0,0,0,0,0,1,0,0,0
SID_290,8179,"The Supplier Code sets clear expectations for Tiffany's suppliers, including that all employment must be voluntary, with the current Supplier Code specifying as follows: The L VMH Group does not tolerate anyform of abusive or illegal labor in its supply chain such asforced labor or human trafficking",0,0,0,0,0,0,0,1,0,0,0
SID_290,8180,"Allforms offorced labor, slavery, servitude or trafficking in human beings by Suppliers, as well as withholding identity papers or work permits or requiring workers to deposit a bond or the use of any other constraint, is strictly prohibited",0,0,0,0,0,0,0,1,0,0,0
SID_290,8181,All workers are entitled to accept or leave their employmentfreely,0,0,0,0,0,0,0,1,0,0,0
SID_290,8182,Suppliers must respect workersfreedom of movement,0,0,0,0,0,0,0,1,0,0,0
SID_290,8183,Suppliers cannot require workers to work to repay a debt to them or to a third party,0,0,0,0,0,0,0,1,0,0,0
SID_290,8184,"Tiffany's expectations and requirements covering responsible recruitment, forced or child labour, indentured, debt-bonded or convict labour, and human trafficking are further detailed in its Supplier Code of Conduct Guidance (""Code Guidance"")",0,0,0,0,0,0,0,1,0,0,0
SID_290,8185,This Code Guidance is distributed to its supply chain partners and compliance with the requirements is mandatory,0,0,0,0,0,0,0,1,0,0,0
SID_290,8186,The Code Guidance is regularly updated to ensure that Tiffany is consistently communicating requirements and methods to respond to specific challenges,0,0,0,0,0,0,0,1,0,0,0
SID_290,8187,"All requirements in the Code Guidance are applicable throughout the supply chain, such that a supplier with which Tiffany has a direct relationship in turn bears the responsibility for ensuring compliance across its own supply chain",0,0,0,0,0,0,0,1,0,0,0
SID_290,8188,"Employees can also discuss these topics with their direct manager, human resources, the legal department, or the internal audit team",0,0,0,0,0,0,0,1,0,0,0
SID_290,8189,"Employees can also discuss these topics with their direct manager, human resources, the legal department, or the internal audit team",0,0,0,0,0,0,0,1,0,0,0
SID_290,8190,All individuals who report suspected policy,0,0,0,0,0,0,0,1,0,0,0
SID_290,8191,"violations in good faith are protected from retaliation arising from such reporting in any form, including disciplinary action, intimidation, or otherwise, even when reports are ultimately proved unfounded",0,0,0,0,0,0,0,1,0,0,0
SID_290,8192,"Representatives of the human resources, legal, and internal audit team, collect and review all cases and ensure they are investigated and, responded to, by the appropriate teams",0,0,0,0,0,0,0,0,1,0,0
SID_290,8193,"Due Diligence Processes To identify and mitigate risk in its supply chain and that of its subsidiaries, including Tiffany & Co",0,0,0,1,0,0,0,0,0,0,0
SID_290,8194,"Canada, Tiffany completes due diligence assessments and audits as part of its SEA Program",0,0,0,0,0,0,0,1,0,0,0
SID_290,8195,"Tiffany's jewelry manufacturing and diamond polishing facilities, supply chain partners, and other key suppliers are regularly assessed for adherence to its Supplier Code through the SEA Program",0,0,0,0,1,0,0,1,0,0,0
SID_290,8196,The SEA Program work includes,0,0,0,0,0,0,0,1,0,0,0
SID_290,8197,"Screening of suppliers to ensure that Tiffany works with supply chain partners and other key suppliers that share its commitment to human rights, fair and safe labour practices that do not involve forced or child labour, environmental protection, and ethical business conduct",0,0,0,0,0,0,0,1,0,0,0
SID_290,8198,"Conducting biennial risk assessments with all of Tiffany's jewelry manufacturing and diamond polishing facilities, supply chain partners, and other key suppliers to identify regional and supplier risks related to social and environmental compliance",0,0,0,0,1,0,0,1,0,0,0
SID_290,8199,Conducting regular third-party audits based on the results of such risk assessments to determine conformance with Tiffany-specific requirements,0,0,0,0,0,0,0,1,0,0,0
SID_290,8200,"Corrective action plans are required for non- conformances, and verification re-audits are required for all critical risk audits",0,0,0,0,0,0,0,0,1,0,0
SID_290,8201,Based on its risk mitigation approach Tiffany includes key portions of its supply chain in its monitoring program and require its supply chain partners to communicate its social and environmental responsibility expectations to their own supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_290,8202,"Both Tiffany's risk assessment and supplier audits screen for modern slavery, including forced and child labour indicators such as overtime requirements, the existence of foreign migrant labourers in employment, grievance mechanisms and freedom of association",0,0,0,0,0,0,0,1,0,0,0
SID_290,8203,"The last biennial risk assessment was conducted in 2022, and throughout 2023, corrective action plans were developed, executed, and verification re-audits were conducted as required",0,0,0,0,0,0,0,1,1,0,0
SID_290,8204,"Tiffany also continued to roll out its program, conducting risk assessments and pre-sourcing audits, and reassessing its risks as it engaged and contracted with new supply chain partners in 2023",0,0,0,0,0,0,0,1,0,0,0
SID_290,8205,"While SEA Program assessments identified some gaps in human rights-related policies and procedures for a fractional percentage of our total supply chain partners in 2023, no acts of child labor or forced labor have been identified in Tiffany's active supply chain",0,0,0,0,0,0,1,0,0,0,0
SID_290,8206,"For all identified gaps in policies and procedures, corrective action plans were established with the respective supply chain partners to address identified gaps and ensure that robust monitoring systems are in place to minimize the risk of modern slavery entering their supply chains",0,0,0,0,0,0,0,0,1,0,0
SID_290,8207,Other Program Features Supplier Partnerships Tiffany works to establish lasting partnerships with its suppliers and provides them with training and development programs as well as sharing best practices,0,0,0,0,0,1,0,1,0,0,0
SID_290,8208,"Tiffany also works jointly with industry partners, non-governmental organizations (NGOs), and local stakeholders to identify human rights-related risks and further the improvement of the most complex challenges in human rights and labour",0,0,0,0,0,0,0,1,0,0,0
SID_290,8209,"For example, with the goal of improving the coloured gemstone industry, Tiffany has worked with a group of luxury brands and",0,0,0,0,0,0,0,1,0,0,0
SID_290,8210,"gemstone miners (the ""Coloured Gemstone Working Group"") to launch a community platform that includes trainings, policies and support on human rights and modern slavery topics",0,0,0,0,0,0,0,1,0,0,0
SID_290,8211,The Gemstones and Jewellery Community Platform,0,0,0,0,0,0,0,0,0,0,0
SID_290,8212,"launched in 2021 by the Coloured Gemstone Working Group, is freely available to all companies who are part of the gemstone and jewelry industry, from mining through to cutting and polishing, trading and retailing",0,0,0,0,0,0,0,0,0,0,0
SID_290,8213,Modules on Human Rights and Equality and Labor Rights and Fair Working Conditions will educate those along the coloured gemstone supply chain on risk and mitigation strategies for modern slavery and human trafficking,0,0,0,0,0,0,0,1,0,0,0
SID_290,8214,"Responsible Mining Tiffany helped launch the Initiative for Responsible Mining Assurance (IRMA) in 2006 and remains steadfast in its commitment to work with suppliers, employees, the industry at large, NGOs and other local stakeholders to foster responsible mining",0,0,0,0,0,0,0,1,0,0,0
SID_290,8215,"IRMA published a Standard for Responsible Mining, which represents a robust, practicable and comprehensive set of requirements for responsible mining, which incorporate human rights and modern slavery, as well as other environmental, social, ethical, and transparency, considerations",0,0,0,0,0,0,0,1,0,0,0
SID_290,8216,Assessing Effectiveness Respect for human rights is embedded throughout the entirety of Tiffany's business as a result of its emphasis on human rights in its policies and procedures,0,0,0,0,0,0,0,0,0,0,0
SID_290,8217,Tiffany's monitoring and training programs are designed to continuously monitor effectiveness and ensure appropriate awareness of Tiffany's commitment to human rights,0,0,0,0,0,0,0,1,0,1,0
SID_290,8218,"In particular, audits and re-audits of supply chain partners through Tiffany's SEA Program are designed to assess effectiveness, including by identifying any repeat non-conformities or improvements",0,0,0,0,0,0,0,1,0,0,0
SID_290,8219,"See ""Due Diligence Processes"" above for more information",0,0,0,0,0,0,0,0,0,0,0
SID_290,8220,"In addition, Tiffany's SEA Program is regularly audited by third parties (including certain of its own suppliers and trade associations) for reviews of effectiveness as related to forced and child labour as part of renewals and certifications with such third parties",0,0,0,0,0,0,0,0,0,1,0
SID_290,8221,Training and Awareness Tiffany provides ongoing training resources and communicates expectations related to its Supplier Code through an on line responsible sourcing education platform for its supply chain partners,0,0,0,0,0,0,0,1,0,0,0
SID_290,8222,"Training webinars and e-learning modules on the Supplier Code, Tiffany Human Rights Policy and on Forced Labour Prevention are available to its supply chain partners year-round",0,0,0,0,0,0,0,1,0,0,0
SID_290,8223,"With respect to Tiffany's employees, all employees who work directly with the companies' supply chain partners are required to participate in mandatory training on the SEA Program biennially",0,0,0,0,0,0,0,1,0,0,0
SID_290,8224,"The training covers a range of topics, including topics related to forced labour and child labour, among others",0,0,0,0,0,0,0,1,0,0,0
SID_290,8225,Measures Taken to Remediate any Forced Labour or Child Labour Tiffany & Co,0,0,0,0,0,0,0,0,0,0,0
SID_290,8226,Canada is not aware of any incidents of forced or child labour in its supply chain and therefore is not aware of any need to remediate any such incidents,0,0,0,0,0,0,1,0,0,0,0
SID_290,8227,Measures Taken to Remediate the Loss of Income Tiffany & Co,0,0,0,0,0,0,0,0,0,0,0
SID_290,8228,Canada is not aware of any families that have experienced the loss of income as a result of steps taken by Tiffany to eliminate forced or child labour risks in its supply chain and is therefore not aware of any need to remediate any such incidents,0,0,0,0,0,0,0,0,0,0,0
SID_290,8229,Approval and Attestation This report was approved pursuant to paragraph 11(4)(a) of the Act by the Board of Directors of Tiffany & Co,1,0,0,0,0,0,0,0,0,0,0
SID_290,8230,"In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for the entity listed above",0,0,0,0,0,0,0,0,0,0,0
SID_290,8231,"Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above",0,0,0,0,0,0,0,0,0,0,0
SID_290,8232,"Per: Tit! : Director owe7o,, 50,12024 I have the authority to bind Tiffany & Co",0,1,0,0,0,0,0,0,0,0,0
SID_293,8233,"BLACK DIAMOND GROUP LIMITED ANNUAL JOINT REPORT 2023 FIGHTING AGAINST FORCED LABOUR AND CHILD LABOUR IN SUPPLY CHAINS ACT Issue Date: May 31, 2024",0,0,0,0,0,0,0,0,0,0,0
SID_293,8234,Black Diamond Group Limiteds Annual Joint Report (2023) (the Report) has been prepared in accordance with Section 11 of the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Act)1,0,0,0,0,0,0,0,0,0,0,0
SID_293,8235,Black Diamond Group Limited (Black Diamond) is a party to this joint report including two additional entities,0,0,0,1,0,0,0,0,0,0,0
SID_293,8236,Black Diamond Lodging Inc (Black Diamond Lodging),0,0,0,1,0,0,0,0,0,0,0
SID_293,8237,BOXX Modular LP (BOXX Modular) Black Diamond is committed to respecting human rights and acting with integrity in all operations and business dealings,0,0,0,1,0,0,0,0,0,0,0
SID_293,8238,"One area of particular focus is modern slavery, which is an umbrella term for a number of serious exploitative work practices that represent violations of human rights",0,0,0,0,0,0,0,0,0,0,0
SID_293,8239,"This Report covers the reporting entities listed above for the Financial Year January 1, 2023 to December 31, 2023",0,0,0,0,0,0,0,0,0,0,0
SID_293,8240,It provides an overview of the steps Black Diamond is taking to prevent our involvement in human rights harm by positively influencing our supply chains and other business partnerships to act responsibly and ethically,0,0,0,0,0,0,0,0,0,0,0
SID_293,8241,"BLACK DIAMOND Black Diamond owns and operates a portfolio of businesses specializing in modular buildings and remote and temporary workforce accommodations, along with a digital marketplace for business-to-business crew travel management",0,0,0,0,1,0,0,0,0,0,0
SID_293,8242,"With approximately five hundred employees, and approximate assets of $650 million worldwide, Black Diamond offers a comprehensive suite of solutions and services, including",0,0,0,1,0,0,0,0,0,0,0
SID_293,8243,"Modular space solutions through BOXX Modular, which owns a large rental fleet of modular buildings of various types and sizes",0,0,0,0,1,0,0,0,0,0,0
SID_293,8244,"Its network of local branches rent, sell, service, and provide ancillary products and services to a diverse customer base in the construction, industrial, education, financial, and government sectors",0,0,0,0,1,0,0,0,0,0,0
SID_293,8245,"Workforce accommodations and solutions through Black Diamond Lodging, which owns a large rental fleet of modular accommodation assets of various types",0,0,0,0,1,0,0,0,0,0,0
SID_293,8246,"Its regional operating terminals rent, sell, service, and provide ancillary products and services including turnkey operated camps to a wide array of customers in the resource, infrastructure, construction, disaster recovery, and education sectors",0,0,0,0,1,0,0,0,0,0,0
SID_293,8247,ABOUT THIS REPORT INTRODUCTION ABOUT US 1 Fighting Against Forced Labour and Child Labour in Supply Chains Act (S.C,0,0,0,0,0,0,0,0,0,0,0
SID_293,8248,"2023, c.9)",0,0,0,0,0,0,0,0,0,0,0
SID_293,8249,"OUR MISSION: CREATE A BETTER WAY Our vision is to build a world-class Company that is a leading provider of modular space solutions, workforce accommodations, and business-to-business crew travel management",0,0,0,0,0,0,0,0,0,0,0
SID_293,8250,We believe our collective behaviours influence and drive our values-based culture,0,0,0,0,0,0,0,0,0,0,0
SID_293,8251,"It takes a special set of circumstances to make a Black Diamond under high pressure, unique properties are forged to create something known for its strength and brilliance",0,0,0,0,0,0,0,0,0,0,0
SID_293,8252,"Weve built a culture around these qualities, and the traits and attributes that set our high-performing team apart are growth, collaboration, innovation, agility, and commitment, to name just a few",0,0,0,0,0,0,0,0,0,0,0
SID_293,8253,"MISSION STATEMENT Black Diamond has locations across Canada, operating in",0,0,0,0,1,0,0,0,0,0,0
SID_293,8254,"Langley, BC Nanaimo, BC Kelowna, BC Prince George, BC",0,0,0,0,1,0,0,0,0,0,0
SID_293,8255,"Edmonton, AB Calgary, AB Regina, SK Toronto, ON",0,0,0,0,1,0,0,0,0,0,0
SID_293,8256,"Kitchener/ Waterloo, ON Ottawa, ON Montral, QC",0,0,0,0,1,0,0,0,0,0,0
SID_293,8257,"Moncton, NB Fort St",0,0,0,0,1,0,0,0,0,0,0
SID_293,8258,"John, BC Grand Prairie, AB",0,0,0,0,1,0,0,0,0,0,0
SID_293,8259,"Timmins, ON MAP OF OPERATIONS",0,0,0,0,1,0,0,0,0,0,0
SID_293,8260,This Report covers the following entities,0,0,0,0,0,0,0,0,0,0,0
SID_293,8261,Black Diamond Group Limited Black Diamond Group owns and operates a portfolio of businesses specializing in modular buildings and remote and temporary workforce accommodations,0,0,0,1,1,0,0,0,0,0,0
SID_293,8262,"BOXX Modular LP BOXX Modular provides high quality, cost effective modular space solutions to a diversified client base which includes general contractors, education providers, construction trades, manufacturers, commercial businesses, financial institutions, government agencies and various companies involved in the resource industry",0,0,0,1,1,0,0,0,0,0,0
SID_293,8263,Black Diamond Lodging Inc,0,0,0,1,0,0,0,0,0,0,0
SID_293,8264,"Black Diamond Lodging provides workforce accommodations and associated services throughout Canada to a client base which includes oil and natural gas exploration and development companies, mineral and metals mining and processing companies, catering and food services providers, engineering and construction companies, general contractors, pipeline constructors, disaster recovery, social housing initiatives and varying levels of governments",0,0,0,0,1,0,0,0,0,0,0
SID_293,8265,"Black Diamond Lodging also provides turnkey lodging services, remote facility management and sophisticated supply chain management services to customers to improve efficiency of remote accommodation facilities",0,0,0,0,1,0,0,0,0,0,0
SID_293,8266,"Black Diamond delivers its services and solutions using a combination of our internal workforce, external suppliers, and contractors to ensure that activities, projects, and work program resources are deployed efficiently and at the lowest sustainable cost, maintained over the long-term",0,0,0,0,1,0,0,0,0,0,0
SID_293,8267,Black Diamonds success is linked to the performance of our supply chain,0,0,0,0,0,0,0,0,0,0,0
SID_293,8268,BLACK DIAMOND ENTITIES & ACTIVITIES OUR SUPPLY CHAINS,0,0,0,0,0,0,0,0,0,0,0
SID_293,8269,"Black Diamond recognizes that modern slavery persists in regions where poverty rates are high, the rule of law is underdeveloped, and enforcement is absent or undermined by corruption",0,0,0,0,0,0,0,0,0,0,0
SID_293,8270,"Black Diamonds commitment to this is currently outlined in our 2023 Black Diamond Supplier Code of Conduct2 (Code of Conduct), setting out the standards of conduct we expect of ourselves and our suppliers",0,0,0,0,0,0,0,0,0,0,0
SID_293,8271,Child Labour Suppliers shall not exploit child labour and shall not employ any workers under the minimum legal age as dictated by law where the work is performed,0,0,0,0,0,0,0,1,0,0,0
SID_293,8272,"In no instance shall a supplier permit a child to perform work that exposes them to undue physical risks that can harm their physical, mental, or emotional development or improperly interfere with their education or vocational needs",0,0,0,0,0,0,0,1,0,0,0
SID_293,8273,XI,0,0,0,0,0,0,0,0,0,0,0
SID_293,8274,"Forced Labour Suppliers must refrain from violating the rights of others, adhere to regulations prohibiting slavery, human trafficking and forced labour and comply with all applicable local laws in the country in which they operate",0,0,0,0,0,0,0,1,0,0,0
SID_293,8275,Employment decisions must be based on free choice and not under threats of violence or coercion,0,0,0,0,0,0,0,1,0,0,0
SID_293,8276,Work agreements must clearly state employment terms and must not restrict worker movement through the confiscation of identification documents,0,0,0,0,0,0,0,1,0,0,0
SID_293,8277,"In 2023, Black Diamond requested all current suppliers working with all Black Diamond entities acknowledge and sign this Code of Conduct",0,0,0,0,0,0,0,1,0,0,0
SID_293,8278,"In addition, Black Diamond has other key procedures and practices which govern business activities, including",0,0,0,0,0,0,0,0,0,0,0
SID_293,8279,Code of Business Conduct and Ethics,0,0,0,0,0,0,0,0,0,0,0
SID_293,8280,Whistleblower Policy Each of these policies are published on our website,0,0,0,0,0,0,0,1,0,0,0
SID_293,8281,Awareness of these policies is supported by on-line training modules for all Black Diamond employees,0,0,0,0,0,0,0,1,0,0,0
SID_293,8282,POLICIES AND DUE DILIGENCE 2 2023 Black Diamond Supplier Code of Conduct,0,0,0,0,0,0,0,0,0,0,0
SID_293,8283,Black Diamond believes in working with business partners who demonstrate high standards of ethical business conduct,0,0,0,0,0,0,0,0,0,0,0
SID_293,8284,"We expect them to be guided by the principles outlined in our policies and codes of conduct, and we will not knowingly work with business partners who operate unethically, unsafely or who violate the law, compete dishonestly, or use unfair business practices",0,0,0,0,0,0,0,0,0,0,0
SID_293,8285,"When engaging with our business partners, we take steps to retain them on commercially reasonable terms and conditions and are aware of, and contractually bound by, our standards of business conduct",0,0,0,0,0,0,0,0,0,0,0
SID_293,8286,Risk of Forced Labour or Child Labour and Steps to Assess and Manage the Risk Black Diamond has started the process of identifying risks of forced labour or child labour in our activities or supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_293,8287,"We have identified a potential risk of a tier three supplier in the manufacturing sector, but there are still gaps in our assessment",0,0,0,0,0,0,1,0,0,0,0
SID_293,8288,"Measures taken to Remediate any Forced Labour or Child Labour or the Loss of Income to Vulnerable Families Not applicable, we have not identified any loss of income to vulnerable families resulting from measures taken to eliminate the use of forced labour or child labour in our activities and supply chains",0,0,0,0,0,0,0,0,0,0,0
SID_293,8289,"DUE DILIGENCE In accordance with the requirements of the Act 1, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for the entity or entities listed above",0,0,0,0,0,0,0,0,0,0,0
SID_293,8290,"Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above",0,0,0,0,0,0,0,0,0,0,0
SID_293,8291,"Trevor Haynes Chairman & CEO, Black Diamond Group Limited Date: 05/23/2024 I have the authority to bind Black Diamond Group Limited, Black Diamond Lodging Inc, and BOXX Modular LP",0,1,0,0,0,0,0,0,0,0,0
SID_295,8385,Forced Labor in Canadian Supply Chains,0,0,0,0,0,0,0,0,0,0,0
SID_295,8386,FY 2024 Report Aiphone Corporation,0,0,0,0,0,0,0,0,0,0,0
SID_295,8387,"Note: This report has been prepared referencing all applicable questions from Public Safety Canadas required questionnaire for Bill S-211, An Act to enact the Fighting Against Forced Labour and Child Labour in Supply Chains Act",0,0,0,0,0,0,0,0,0,0,0
SID_295,8388,Questions have been directly copied from the questionnaire and are displayed in bold text throughout the report,0,0,0,0,0,0,0,0,0,0,0
SID_295,8389,"What steps has the entity taken in the previous financial year to prevent and reduce the risk that forced labour or child labour is used at any step of the production of goods in Canada or elsewhere by the entity or of goods imported into Canada by the entity? Aiphone Corporation does not produce any goods in Canada; however, we do import goods to Canada and employ Canadian citizens",0,0,0,0,1,0,0,0,0,0,0
SID_295,8390,"When seeking new suppliers, Aiphone Corporation gives preference to suppliers operating in countries with robust workers rights and labor protection measures codied into law",0,0,0,0,0,0,0,0,0,0,0
SID_295,8391,Most of our partners are US and Canadian entities,0,0,0,0,0,1,0,0,0,0,0
SID_295,8392,"New suppliers must agree to maintaining compliance with all applicable government laws, statues, ordinances, rules, regulations, orders and other requirements, including those related to age, U.S.C",0,0,0,0,0,0,0,1,0,0,0
SID_295,8393,"regarding forced labor, the Uyghur Forced Labor Prevention Act, and all other relevant regulations governing labor and workers rights",0,0,0,0,0,0,0,1,0,0,0
SID_295,8394,"Our parent company, AIPHONE CO., LTD",0,0,0,1,0,0,0,0,0,0,0
SID_295,8395,(TYO: 6718) is based in Japan,0,0,0,1,0,0,0,0,0,0,0
SID_295,8396,They manufacture the majority of the products Aiphone Corporation sells,0,0,0,0,1,0,0,0,0,0,0
SID_295,8397,Articles 5 and 6 of Japans Labor Standards Act prohibit the use of forced labor and explicitly disallows intermediate exploitation by employers,0,0,0,0,0,0,0,0,0,0,0
SID_295,8398,Aiphone Corporation monitors the UFLPA Entity List maintained by the US Department of Homeland Security to ensure we are not transacting with entities that have been agged as entities beneting from the use of forced labor,0,0,0,0,0,0,0,1,0,0,0
SID_295,8399,"Our scal year begins April 1 each year, while this was not completed during the previous scal year, we conducted an internal assessment of risks of forced labor and/or child labor in our supply chain along with creating an associated risk identication and analysis document this April",0,0,0,0,0,0,0,1,0,0,0
SID_295,8400,Risks were scored based on probability of occurrence and potential impact to the business,0,0,0,0,0,0,0,0,0,0,0
SID_295,8401,"Pertaining to hiring practices, on all applications Aiphone Corporation requires applicants to conrm they are legally 18 years of age or older",0,0,0,0,0,0,0,1,0,0,0
SID_295,8402,Aiphone Corporation does not consider the applications of minors nor does the company employ minors (those under the age of 18),0,0,0,0,0,0,0,1,0,0,0
SID_295,8403,Human Resources conducts background checks on all considered applicants and requires the completion of form I-9 (Employment Eligibility Verication) which is then submitted via the E-Verify system to ensure that government records match the personal information provided by the applicant,0,0,0,0,0,0,0,1,0,0,0
SID_295,8404,Please provide additional information describing the steps taken (if applicable),0,0,0,0,0,0,0,0,0,0,0
SID_295,8405,*Which of the following accurately describes the entitys structure,0,0,0,0,0,0,0,0,0,0,0
SID_295,8406,Corporation,0,0,0,1,0,0,0,0,0,0,0
SID_295,8407,Which of the following accurately describes the entitys activities? Select all that apply,0,0,0,0,0,0,0,0,0,0,0
SID_295,8408,"Producing goods (including manufacturing, extracting, growing and processing) o outside Canada",0,0,0,0,0,0,0,0,0,0,0
SID_295,8409,Selling goods,0,0,0,0,0,0,0,0,0,0,0
SID_295,8410,o in Canada o outside Canada o Importing into Canada goods produced outside Canada,0,0,0,0,0,0,0,0,0,0,0
SID_295,8411,"Please provide additional information on the entitys structure, activities and supply chains Aiphone Corporation is a subsidiary of AIPHONE CO., LTD",0,0,0,1,0,0,0,0,0,0,0
SID_295,8412,"(TYO: 6718), based in Japan",0,0,0,1,0,0,0,0,0,0,0
SID_295,8413,Aiphone is known for manufacturing intercom and access control systems,0,0,0,0,1,0,0,0,0,0,0
SID_295,8414,"The majority of SKUs Aiphone Corporation carries are produced by AIPHONE CO., LTD, which has manufacturing facilities in Japan, Thailand, and Vietnam",0,0,0,0,1,0,0,0,0,0,0
SID_295,8415,"Monthly or semi-monthly orders are placed to AIPHONE CO., LTD for nished products and parts with Aiphone Corporation receiving regular shipments via container and air freight originating from Thailand and Japan",0,0,0,0,1,0,0,0,0,0,0
SID_295,8416,"Aiphone Corporation is based in Redmond, WA and serves the Americas and Caribbean region, with most sales concentrated in the United States and Canada",0,0,0,0,1,0,0,0,0,0,0
SID_295,8417,These sales are facilitated through dealer and distributor networks,0,0,0,0,0,1,0,0,0,0,0
SID_295,8418,"Activities are typical of a sales-focused company including, but not limited to, meeting with dealers and distributors, attending industry trade shows, leading product training sessions, developing system specications for projects, providing technical support and customer service, and marketing Aiphones products and services",0,0,0,0,1,0,0,0,0,0,0
SID_295,8419,Aiphone Corporation also engages in the production and repair of intercoms,0,0,0,0,1,0,0,0,0,0,0
SID_295,8420,The products Aiphone Corporation produces in the United States are mainly for the North American market,0,0,0,0,1,0,0,0,0,0,0
SID_295,8421,"Most of these items are designed to add additional features, functionality, and/or quality of life improvements to existing product lines",0,0,0,0,0,0,0,0,0,0,0
SID_295,8422,Electronic components are sourced from authorized parts distributors located in the United States,0,0,0,0,0,1,0,0,0,0,0
SID_295,8423,"Items such as panels, labels, and screws are sourced mainly from local vendors and almost exclusively from US-based companies",0,0,0,0,0,1,0,0,0,0,0
SID_295,8424,Does the entity currently have policies and due diligence processes in place related to forced labour and/or child labour? No,0,0,0,0,0,0,0,1,0,0,0
SID_295,8425,Has the entity identified parts of its activities and supply chains that carry a risk of forced labour or child labour being used,0,0,0,0,0,0,0,0,0,0,0
SID_295,8426,"Yes, we have identied risks to the best of its knowledge and will continue to strive to identify emerging risks",0,0,0,0,0,0,0,0,0,0,0
SID_295,8427,"If yes, has the entity identified forced labour or child labour risks related to any of the following aspects of its activities and supply chains",0,0,0,0,0,0,1,0,0,0,0
SID_295,8428,Tier two suppliers,0,0,0,0,0,0,1,0,0,0,0
SID_295,8429,Tier three suppliers,0,0,0,0,0,0,1,0,0,0,0
SID_295,8430,Suppliers further down the supply chain than tier three,0,0,0,0,0,0,1,0,0,0,0
SID_295,8431,Has the entity identified forced labour or child labour risks in its activities and supply chains related to any of the following sectors and industries,0,0,0,0,0,0,1,0,0,0,0
SID_295,8432,"Mining, quarrying, and oil and gas extraction",0,0,0,0,0,0,1,0,0,0,0
SID_295,8433,Manufacturing 10,0,0,0,0,0,0,1,0,0,0,0
SID_295,8434,"Please provide additional information on the parts of the entitys activities and supply chains that carry a risk of forced labour or child labour being used, as well as the steps that the entity has taken to assess and manage that risk",0,0,0,0,0,0,0,0,0,0,0
SID_295,8435,Electrical components utilized in manufacturing of devices represent the largest risk of forced or child labor in Aiphone Corporations supply chain,0,0,0,0,0,0,1,0,0,0,0
SID_295,8436,Companies who design components often have global footprints and utilize contract labor (whom often sub-contract) to meet their manufacturing needs,0,0,0,0,0,0,1,0,0,0,0
SID_295,8437,Many semiconductor devices and PCBs are manufactured in localities known to have recent incidents of forced and/or child labor,0,0,0,0,0,0,1,0,0,0,0
SID_295,8438,Aiphone Corporations exposure to end products manufactured from mined commodities also carries a risk of forced or child labor,0,0,0,0,0,0,1,0,0,0,0
SID_295,8439,Mining has historically been and continues to be one of the worst offending industries in utilizing forced and/or child labor,0,0,0,0,0,0,0,0,0,0,0
SID_295,8440,The U.S,0,0,0,0,0,0,0,0,0,0,0
SID_295,8441,"Department of Labor estimates that at least 25,000 children are working in cobalt mines in the DRC today, for",0,0,0,0,0,0,0,0,0,0,0
SID_295,8442,examplei,0,0,0,0,0,0,0,0,0,0,0
SID_295,8443,"Companies are incentivized to source commodities such as bauxite, iron ore, and tin ore from localities with the lowest cost to produce them, but the tradeoff is often that lower costs typically come with less robust institutional labor protections and more frequent instances of locally operating companies being involved in unethical labor practices",0,0,0,0,0,0,0,0,0,0,0
SID_295,8444,We do not have visibility on the full map of suppliers the smelters producing semi-finished metal (used by our vendors) utilize which presents a risk,0,0,0,0,0,1,1,0,0,0,0
SID_295,8445,Nearly every business involved with sourcing or manufacturing any electronic devices should list mined commodities as a risk for exposure to forced and child labor,0,0,0,0,0,0,0,0,0,0,0
SID_295,8446,Tin is the primary metal used for soldering,0,0,0,0,0,0,0,0,0,0,0
SID_295,8447,"The worlds 3 largest tin-producing countries are Myanmar, Indonesia, and China-- these three nations produce significantly more tin than the rest of the world combined",0,0,0,0,0,0,0,0,0,0,0
SID_295,8448,"The US government estimates there are over 100,000 Uyghurs and other ethnic minorities currently subjected to forced labor in Chinaii",0,0,0,0,0,0,0,0,0,0,0
SID_295,8449,"Myanmar is enveloped in a civil war, nominally ruled by a military junta, where close to one in ten children are estimated to be involved in child laboriii",0,0,0,0,0,0,0,0,0,0,0
SID_295,8450,There is also a lengthy history of civil rights and forced labor abuses against the Rohingya people in Myanmar,0,0,0,0,0,0,0,0,0,0,0
SID_295,8451,Apple and Samsung have both conducted somewhat recent investigations as to whether tin produced using child labor sourced from Bangka Island in Indonesia ended up in their productsiv,0,0,0,0,0,0,0,0,0,0,0
SID_295,8452,"Especially for commodities where most of the worlds output comes from regions with problematic historical records regarding child/forced labor, there will be risk of forced and child labor",0,0,0,0,0,0,0,0,0,0,0
SID_295,8453,Has the entity taken any measures to remediate any forced labour or child labour in its activities and supply chains? No 12,0,0,0,0,0,0,0,0,1,0,0
SID_295,8454,Please provide additional information on any measures the entity has taken to remediate any forced labour or child labour N/A 13,0,0,0,0,0,0,0,0,0,0,0
SID_295,8455,Has the entity taken any measures to remediate the loss of income to the most vulnerable families that results from any measure taken to eliminate the use of forced labour or child labour in its activities and supply chains? No 12,0,0,0,0,0,0,0,0,0,0,0
SID_295,8456,Please provide additional information on any measures the entity has taken to remediate the loss of income to the most vulnerable families that results from any measure taken to eliminate the use of forced labour or child labour in its activities and supply chain N/A,0,0,0,0,0,0,0,0,0,0,0
SID_295,8457,15,0,0,0,0,0,0,0,0,0,0,0
SID_295,8458,Does the entity currently provide training to employees on forced labour and/or child labour? No 16,0,0,0,0,0,0,1,0,0,0,0
SID_295,8459,Please provide additional information on the training the entity provides to employees on forced labour and child labour,0,0,0,0,0,0,0,0,0,0,0
SID_295,8460,N/A 17,0,0,0,0,0,0,0,0,0,0,0
SID_295,8461,Does the entity currently have policies and procedures in place to assess its effectiveness in ensuring that forced labour and child labour are not being used in its activities and supply chains? No 18,0,0,0,0,0,0,0,0,0,1,0
SID_295,8462,Please provide additional information on how the entity assesses its effectiveness in ensuring that forced labour and child labour are not being used in its activities and supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_295,8463,/30/2024,0,0,0,0,0,0,0,0,0,0,0
SID_296,8464,"2023 MODERN SLAVERY REPORT TSX: SOIL May 31, 2024",0,0,0,0,0,0,0,0,0,0,0
SID_296,8465,"INTRODUCTION OUR COMMITMENTS POLICIES & DUE DILIGENCE RISK ASSESSMENT EDUCATION & AWARENESS CONCLUSION LETTER TO STAKEHOLDERS This Report has been prepared in accordance with requirements set out in the Fighting Against Forced Labour and Child Labour in Supply Chain Act, S.C",0,0,0,0,0,0,0,0,0,0,0
SID_296,8466,"2023, c.9 (the Act)",0,0,0,0,0,0,0,0,0,0,0
SID_296,8467,It is a joint report prepared on behalf of and approved by the Board of Directors of Saturn Oil and Gas Inc pursuant to section 11(4)(b)(ii) of the Act,1,0,0,0,0,0,0,0,0,0,0
SID_296,8468,This report highlights how Saturn is identifying and addressing risks throughout our business and our supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_296,8469,"Although we are not aware of any recorded modern slavery incidents in our business in 2023, we are committed to continuous improvement",0,0,0,0,0,0,1,0,0,0,0
SID_296,8470,"As we navigate the complexities of growth, we remain resolute in our commitment to combatting modern slavery and fostering a culture of ethical conduct",0,0,0,0,0,0,0,0,0,0,0
SID_296,8471,"Together, we will continue to work tirelessly to ensure that Saturns operations uphold the highest standards of integrity and respect for human rights",0,0,0,0,0,0,0,0,0,0,0
SID_296,8472,"In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for the entity or entities listed above",0,0,0,0,0,0,0,0,0,0,0
SID_296,8473,"Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above",0,0,0,0,0,0,0,0,0,0,0
SID_296,8474,"/s/John Jeffrey Chief Executive Officer (CEO) & Director May 31, 2024",0,1,0,0,0,0,0,0,0,0,0
SID_296,8475,I have the authority to bind Saturn Oil and Gas,0,0,0,0,0,0,0,0,0,0,0
SID_296,8476,"In accordance with our Code of Business Ethics, which serves as the cornerstone of our corporate culture and foundation of our commitment to ethical conduct, we have implemented measures to ensure Saturns internal and external stakeholders are operating in a transparent and ethical manner",0,0,0,0,0,0,0,0,0,0,0
SID_296,8477,"This code outlines our unwavering commitment to upholding the dignity and rights of all individuals involved in our operations, including employees, contractors, and suppliers",0,0,0,0,0,0,0,0,0,0,0
SID_296,8478,"In tandem with our recent growth, we released our second annual Environmental, Sustainability and Governance (ESG) Report which reflects Saturns commitment to safe, responsible and sustainable operations, all while focusing on delivering returns for our stakeholders",0,0,0,0,0,0,0,0,0,0,0
SID_296,8479,"As Saturn continues to expand and evolve, it is crucial that we remain steadfast in our commitment to ethical business practices and social responsibility",0,0,0,0,0,0,0,0,0,0,0
SID_296,8480,"I am proud to share Saturns first Modern Slavery Report, which highlights our commitment to operating ethically and responsibly across all aspects of our business, including addressing and mitigating the risk of modern slavery within our supply chain",0,0,0,0,0,0,0,0,0,0,0
SID_296,8481,"Modern slavery is a grave violation of human rights that continues to persist in various industries worldwide, including our own",0,0,0,0,0,0,0,0,0,0,0
SID_296,8482,We recognize the responsibility we bear in ensuring that our operations and supply chains are free from any form of exploitation or forced labor,0,0,0,0,0,0,0,0,0,0,0
SID_296,8483,"INTRODUCTION OUR COMMITMENTS POLICIES & DUE DILIGENCE RISK ASSESSMENT EDUCATION & AWARENESS CONCLUSION ABOUT THIS REPORT The information contained in this report is intended for Saturn Oil & Gas Inc.s (Saturn, or the Company, or we) internal and external stakeholders and focuses on the activities and initiatives undertaken from January 1, 2023, to December 31, 2023",0,0,0,0,0,0,0,0,0,0,0
SID_296,8484,The following Modern Slavery Act (the Report) has been prepared to ensure compliance with the Fighting Against Forced Labour and Child Labour In Supply Chains Act (the Act),0,0,0,0,0,0,0,0,0,0,0
SID_296,8485,"This report covers the timeframe spanning from January 1, 2023, to December 31, 2023, and provides detailed insights into the measures and protocols implemented by Saturn Oil and Gas Inc (Saturn, the Company, or the Organization) to mitigate all risks associated with the Act",0,0,0,0,0,0,0,0,0,0,0
SID_296,8486,"In accordance with the requirements of the Act, and in particular section 11 thereof, this report was approved by the Board of Directors",1,0,0,0,0,0,0,0,0,0,0
SID_296,8487,"This report is guided by the Fighting Against Forced Labour and Child Labour in Supply Chains Act, S.C",0,0,0,0,0,0,0,0,0,0,0
SID_296,8488,"2023, c.9, highlighting Saturns commitment to ethical business practices",0,0,0,0,0,0,0,0,0,0,0
SID_296,8489,"ABOUT SATURN Legacy Saturn assets assemble an attractive portfolio of free-cash flowing, low-decline operated assets in Southeastern Saskatchewan and West Central Saskatchewan that provide a deep inventory of long-term economic drilling opportunities across multiple zones",0,0,0,0,1,0,0,0,0,0,0
SID_296,8490,"With an unwavering commitment to building an ESG-focused culture, Saturns goal is to increase reserves, production and cash flows with positive returns on invested capital",0,0,0,0,0,0,0,0,0,0,0
SID_296,8491,"On February 28, 2023, Saturn completed the transformative acquisition of Ridgeback, a producer focused on light oil production in Saskatchewan and Alberta",0,0,0,1,1,0,0,0,0,0,0
SID_296,8492,The acquisition provided a new core area for the Company with an entry into the Alberta Cardium play,0,0,0,0,1,0,0,0,0,0,0
SID_296,8493,"These assets benefit from responsibly deployed capital directed to abandonment and reclamation programs with limited inactive liabilities and strong Liability Management Ratings (""LMR"") of over 3x",0,0,0,0,1,0,0,0,0,0,0
SID_296,8494,"Saturns shares are listed for trading on the TSX under ticker SOIL, on the Frankfurt Stock Exchange under symbol SMKA and on the OTCQX under the ticker OILSF",0,0,0,0,0,0,0,0,0,0,0
SID_296,8495,"INTRODUCTION OUR COMMITMENTS POLICIES & DUE DILIGENCE RISK ASSESSMENT EDUCATION & AWARENESS CONCLUSION The Companys supply chain is a complex network of vendors, suppliers, and service providers that play a critical role in various stages of exploration, production, and distributing processes",0,0,0,0,0,1,0,0,0,0,0
SID_296,8496,"Saturns vendor composition is comprised of, but not limited to, the following",0,0,0,0,0,1,0,0,0,0,0
SID_296,8497,Equipment suppliers,0,0,0,0,0,1,0,0,0,0,0
SID_296,8498,Technology providers,0,0,0,0,0,1,0,0,0,0,0
SID_296,8499,Engineering and construction firms,0,0,0,0,0,1,0,0,0,0,0
SID_296,8500,Logistics and transportation companies,0,0,0,0,0,1,0,0,0,0,0
SID_296,8501,Chemical suppliers,0,0,0,0,0,1,0,0,0,0,0
SID_296,8502,Services contractors,0,0,0,0,0,1,0,0,0,0,0
SID_296,8503,Environmental and safety consultants,0,0,0,0,0,1,0,0,0,0,0
SID_296,8504,"Support services In 2023, Saturns collective vendor base totaled approximately 9,600 active vendors",0,0,0,0,0,1,0,0,0,0,0
SID_296,8505,Saturn makes concerted efforts to utilize goods and services that have been procured from North America,0,0,0,0,0,1,0,0,0,0,0
SID_296,8506,Canadian vendors make up 97% of Saturns vendor base,0,0,0,0,0,1,0,0,0,0,0
SID_296,8507,SUPPLY CHAIN Vendor Locations Canada US 97% Canadian-based Vendors,0,0,0,0,0,1,0,0,0,0,0
SID_296,8508,INTRODUCTION OUR COMMITMENTS POLICIES & DUE DILIGENCE RISK ASSESSMENT EDUCATION & AWARENESS CONCLUSION OUR COMITTMENTS Saturn is dedicated to maintaining the utmost standards of ethical conduct and business practices,0,0,0,0,0,0,0,0,0,0,0
SID_296,8509,"Through a culture of accountability and transparency, we empower our team and partners to uphold these principles, weaving ethics into the very fabric of our business",0,0,0,0,0,0,0,0,0,0,0
SID_296,8510,Saturn is committed to guaranteeing that both our employees and suppliers maintain the utmost standards of ethical conduct and business practices,0,0,0,0,0,0,0,0,0,0,0
SID_296,8511,We remain dedicated in our responsibility to conducting thorough due diligence processes to prevent the occurrence of child or forced labor practices in any aspect of our supply chains or operations,0,0,0,0,0,0,0,0,0,0,0
SID_296,8512,"By fostering a culture of accountability and transparency, we empower our employees and suppliers to uphold these standards, ensuring that ethical considerations are woven into every aspect of our business dealings",0,0,0,0,0,0,0,0,0,0,0
SID_296,8513,This unwavering commitment reflects our deep-seated values and underscores our responsibility to not only meet but exceed ethical expectations in all facets of our operations,0,0,0,0,0,0,0,0,0,0,0
SID_296,8514,INTRODUCTION OUR COMMITMENTS POLICIES & DUE DILIGENCE RISK ASSESSMENT EDUCATION & AWARENESS CONCLUSION POLICIES At the core of our company's values is a commitment to ethical conduct and responsible leadership,0,0,0,0,0,0,0,0,0,0,0
SID_296,8515,"Our policies not only clarify expectations for stakeholders but also serve as a roadmap, guiding us toward principled actions in all aspects of our operations",0,0,0,0,0,0,0,0,0,0,0
SID_296,8516,"Grounded in integrity, these policies form the foundation of our business practices, ensuring that we maintain the highest standards of transparency, fairness, and honesty",0,0,0,0,0,0,0,0,0,0,0
SID_296,8517,"By adhering to these principles, we nurture a culture of trust and accountability, strengthening our relationships with stakeholders and reaffirming our dedication to making a positive impact",0,0,0,0,0,0,0,0,0,0,0
SID_296,8518,"Code of Business Ethics The Organization's Code of Business Ethics stands as the cornerstone of our operations, embodying our fundamental values and guiding our decision-making processes",0,0,0,0,0,0,0,0,0,0,0
SID_296,8519,"It provides a robust framework that reflects our commitment to integrity, transparency, and ethical conduct in all aspects of our business",0,0,0,0,0,0,0,0,0,0,0
SID_296,8520,"It not only defines our organization, but it also underscores our commitment to fostering a business environment characterized by integrity, respect, and social responsibility",0,0,0,0,0,0,0,0,0,0,0
SID_296,8521,"Whistle Blower Policy The Whistleblower Policy implemented by the Organization offers a channel for employees to report any suspicions of misconduct without apprehension of retaliation, discrimination, or negative repercussions",0,0,0,0,0,0,0,1,0,0,0
SID_296,8522,It aims to promote a culture where employees feel empowered to address significant concerns internally rather than disregarding issues or seeking external resolutions,0,0,0,0,0,0,0,0,0,0,0
SID_296,8523,"This policy is applicable to all employees and contractors working for the Organization and extends to stakeholders such as suppliers, customers, and shareholders, providing them with a means to express any apprehensions regarding Saturn's business practices",0,0,0,0,0,0,0,1,0,0,0
SID_296,8524,"INTRODUCTION OUR COMMITMENTS POLICIES & DUE DILIGENCE RISK ASSESSMENT EDUCATION & AWARENESS CONCLUSION DUE DILIGENCE Saturn diligently evaluates its supply chains, partnerships and business practices to ensure compliance with ethical standards and to mitigate risks",0,0,0,0,0,0,0,0,0,0,0
SID_296,8525,"Saturn acknowledges the possibility of employees within supply chains being vulnerable to child or forced labor, and as of now, Saturn has not uncovered any instances of this within its operations",0,0,0,0,0,0,1,0,0,0,0
SID_296,8526,"Nevertheless, our commitment to continuous improvement in due diligence remains unwavering to prevent any potential exposure",0,0,0,0,0,0,0,0,0,0,0
SID_296,8527,"We will continue to prioritize sourcing from supply chains predominantly based in the United States and Canada, where the prevalence of child and forced labor is comparatively low",0,0,0,0,0,0,0,1,0,0,0
SID_296,8528,Saturn will also assess business practices to determine any policies and procedures we can implement to further mitigate risks,0,0,0,0,0,0,0,0,0,0,0
SID_296,8529,"8 INTRODUCTION OUR COMMITMENTS POLICIES & DUE DILIGENCE RISK ASSESSMENT EDUCATION & AWARENESS CONCLUSION Mitigating Our Risk The following outlines the steps that we are taking to mitigate any potential risk associated with child labour, forced labour or trafficking",0,0,0,0,0,0,0,1,0,0,0
SID_296,8530,Prioritize sourcing from supply chains predominantly in the United States and Canada,0,0,0,0,0,0,0,1,0,0,0
SID_296,8531,Monitoring and updating Company policies to reflect our commitment to working with service providers and vendors that embody the same fundamental values that Saturn does; and,0,0,0,0,0,0,0,0,0,0,0
SID_296,8532,Reviewing internal recruitment and hiring practices to implement controls that ensure that employees and consultants are hired voluntarily,0,0,0,0,0,0,0,1,0,0,0
SID_296,8533,"Remediating Our Risk To date, the Company has not discovered any occurrences of child or forced labor following an initial comprehensive evaluation of supply chains",0,0,0,0,0,0,1,0,0,0,0
SID_296,8534,"Based on these findings, Saturn has not been compelled to enact any remedial measures",0,0,0,0,0,0,0,0,1,0,0
SID_296,8535,We are dedicated to continually assessing our risk evaluation practices and will promptly address any identified instances should they arise,0,0,0,0,0,0,0,0,0,0,0
SID_296,8536,"In the event that a concerning report, or a breach of the Act has occurred in our business or one of our supply chains, we may use any one of the following remediation measures",0,0,0,0,0,0,0,0,1,0,0
SID_296,8537,Compensation for the victims of forced labour which may include psychosocial support for the person/people impacted,0,0,0,0,0,0,0,0,1,0,0
SID_296,8538,"Enhanced policies, practices, procedures to mitigate any future risk; or",0,0,0,0,0,0,0,1,0,0,0
SID_296,8539,Broadened training opportunities to include all stakeholders on the importance of reporting concerns and identifying questionable practices,0,0,0,0,0,0,0,1,0,0,0
SID_296,8540,RISK ASSESSMENT Saturns Risk Assessment Assessing Our Risk We recognize that there are countries in the world that rely heavily on child or forced labour practices to ensure their costs are kept as low as possible,0,0,0,0,0,0,0,0,0,0,0
SID_296,8541,"At Saturn, we refuse to provide business to any supplier that we know, or suspect, uses modern slavery to run their business however, we recognize that this can happen without us knowing so",0,0,0,0,0,0,0,1,0,0,0
SID_296,8542,The Organization makes concerted efforts to utilize goods and services that have been procured from North America,0,0,0,0,0,0,0,0,0,0,0
SID_296,8543,"As part of Saturns ongoing risk assessment practices, we are committed to",0,0,0,0,0,0,0,1,0,0,0
SID_296,8544,A regular review of corporate policies as they relate to the Act; and,0,0,0,0,0,0,0,0,0,1,0
SID_296,8545,Review of business practices to determine any additional policies and procedures Saturn can implement to reduce risks,0,0,0,0,0,0,0,0,0,0,0
SID_296,8546,INTRODUCTION OUR COMMITMENTS POLICIES & DUE DILIGENCE RISK ASSESSMENT EDUCATION & AWARENESS CONCLUSION TRAINING By fostering a collaborative environment of awareness and action we aim to drive meaningful change and uphold our responsibility to respect human rights across all facets of our business,0,0,0,0,0,0,0,0,0,0,0
SID_296,8547,"The Company mandates that all employees and consultants adhere to the Code of Conduct, a comprehensive framework outlining the ethical standards and behaviors expected of every individual within our organization",0,0,0,0,0,0,0,0,0,0,0
SID_296,8548,"We guarantee that the Whistleblower Policy is transparent and easily accessible to everyone, providing a secure avenue for reporting any concerns or violations of ethical standards",0,0,0,0,0,0,0,1,0,0,0
SID_296,8549,"Furthermore, Saturn is actively engaged in reviewing and identifying appropriate training programs tailored to the requirements of the Act",0,0,0,0,0,0,0,1,0,0,0
SID_296,8550,"By investing in ongoing education and development initiatives, we aim to empower our staff with the knowledge and tools necessary to recognize and address any potential risks within our supply chain",0,0,0,0,0,0,0,0,0,0,0
SID_296,8551,This proactive approach not only strengthens our ability to identify and mitigate risks but also reinforces our commitment to ethical sourcing and responsible business practices,0,0,0,0,0,0,0,0,0,0,0
SID_296,8552,"INTRODUCTION OUR COMMITMENTS POLICIES & DUE DILIGENCE RISK ASSESSMENT EDUCATION & AWARENESS CONCLUSION CONCLUSION At the forefront of our commitment to transparency and accountability, this Modern Slavery Report encapsulates Saturns dedication in combatting modern slavery and forced labour practices",0,0,0,0,0,0,0,0,0,0,0
SID_296,8553,"Through internal company policies and procedures, and proactive measures to educate and empower Stakeholders, we strive to uphold the highest ethical standards across our operations",0,0,0,0,0,0,0,0,0,0,0
SID_296,8554,"While we acknowledge that complexities and challenges are inherent in eradicating modern slavery, we remain steadfast in our dedication to continuous improvement and accountability",0,0,0,0,0,0,0,0,0,0,0
SID_298,8555,"Equicapita Canadas Modern Slavery Act Report For the year ended December 31, 2023 Introduction Equicapita (Equicapita Income Trust and Equicapita Income LP, combined Equicapita) is a Calgary-based investment company focused on private-equity investment in the Canadian marketplace",0,0,0,0,1,0,0,0,0,0,0
SID_298,8556,This report constitutes the rst report prepared by Equicapita pursuant to the Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Act),0,0,0,0,0,0,0,0,0,0,0
SID_298,8557,"The following information represents a joint report of Equicapita and its aliated entities as outlined below (together, the Reporting Entities) for the nancial year ended December 31, 2023 (the Reporting Period)",0,0,0,0,0,0,0,0,0,0,0
SID_298,8558,"Equicapita is committed to respecting human rights across our business operations in accordance with the Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work",0,0,0,0,0,0,0,0,0,0,0
SID_298,8559,"During the Reporting Period, the Reporting Entities did not have formal processes in place to prevent or reduce forced labour and/or child labour in its supply chain, however, Equicapita was not aware of any child labour, forced labour or other abusive or unsafe working conditions, in the Reporting Entities supply chains, in the Reporting Period",0,0,0,0,0,0,0,1,0,1,0
SID_298,8560,"Structure, Activities and Supply Chains Equicapita was founded in 2013 to access the emerging SME buyout investment thesis",0,0,0,0,0,0,0,0,0,0,0
SID_298,8561,It has successfully partnered with management teams in multiple transactions and continues to grow both the number and scale of portfolio companies,0,0,0,0,1,0,0,0,0,0,0
SID_298,8562,"Head oce for group administrative and leadership operations is located at Suite 300, 4954 Richard Road SW, Calgary, Alberta",0,0,0,1,0,0,0,0,0,0,0
SID_298,8563,"In total, Equicapita, the business, employs 18 permanent sta",0,0,0,1,0,0,0,0,0,0,0
SID_298,8564,"It is estimated that Equicapitas portfolio companies employ approximately 1,200 people working on a full-time equivalent basis",0,0,0,1,0,0,0,0,0,0,0
SID_298,8565,"From an operational perspective, all sta in all ownership and operational entities are located in Canada and the United States, countries considered to be low risk of forced labour and child labour incidences and vulnerability",0,0,0,0,1,0,0,0,0,0,0
SID_298,8566,An individuals performance and compensation are reviewed annually with management personnel to ensure employee retention and that Equicapita portfolio companies continue to be viewed in the industry as fair and desirable employers,0,0,0,0,0,0,0,0,0,0,0
SID_298,8567,"Equicapitas majority owned and aliated entities, the Reporting Entities, include the following: Ownership and Management Service Entities Operational Entities Equicapita Income Trust A&R Metal Industries Ltd Equicapita Income LP and GP ESP Salon Sales Inc Equicapita Investment Corp Hallmark Dental Laboratory Limited Equicapita Services LP and GP I-XL Building Products Inc",0,0,0,1,0,0,0,0,0,0,0
SID_298,8568,Ownership and Management Service Entities Operational Entities Omnigence Corp Levys Machine Works Ltd Corpus Partners GP and LP The Master Mechanic Inc Averine Partners GP and LP Master Mechanic Limited Oset GP and LP Metercor Inc Perceptos Partners GP and LP Metercor US Inc Varistream Partners GP and LP Metro Testing & Engineering Ltd Canadian Dental Laboratory Limited Partnership and GP McIntyre Associates Software Ltd 2181376 Alberta Ltd Metro Testing & Engineering Ltd - Western Geotechnical Consultants Ltd Equicapita Employee Share Plan Ltd Nutters Bulk and Natural Foods Inc Equicapita Income (NR) L.P,0,0,0,1,0,0,0,0,0,0,0
SID_298,8569,Protec Dental Laboratories (2021) Inc,0,0,0,1,0,0,0,0,0,0,0
SID_298,8570,Shaw Dental Laboratory Inc,0,0,0,1,0,0,0,0,0,0,0
SID_298,8571,Best Value Ceramics Inc,0,0,0,1,0,0,0,0,0,0,0
SID_298,8572,Smittys Canada Inc,0,0,0,1,0,0,0,0,0,0,0
SID_298,8573,Alberta Ltd,0,0,0,1,0,0,0,0,0,0,0
SID_298,8574,Visage Cosmetics Limited,0,0,0,1,0,0,0,0,0,0,0
SID_298,8575,CBV Cosmetics Limited,0,0,0,1,0,0,0,0,0,0,0
SID_298,8576,Caryl Baker Visage Cosmetics Ltd,0,0,0,1,0,0,0,0,0,0,0
SID_298,8577,Wingenback Ltd,0,0,0,1,0,0,0,0,0,0,0
SID_298,8578,"While some sector targeting is purposeful in the Equicapita portfolio (eg dental and beauty and wellness industries), the commonality of portfolio companies is excellent management teams and Equicapitas majority ownership",0,0,0,0,1,0,0,0,0,0,0
SID_298,8579,"Operating portfolio companies, and their key activities, are described below: A&R Metal Industries Ltd was founded in 1969 and is based in Richmond, British Columbia",0,0,0,0,1,0,0,0,0,0,0
SID_298,8580,"A&R is a leading manufacturer of high-quality metal parts used in the automotive, commercial nishings & architecture, exhaust & ltration, construction & agriculture, and safety industries",0,0,0,0,1,0,0,0,0,0,0
SID_298,8581,"ESP Salon Sales Inc was founded in 1990 and is headquartered in Saskatoon, Saskatchewan, with 7 additional locations across Canada",0,0,0,1,1,0,0,0,0,0,0
SID_298,8582,"ESP is a leading wholesale distributor of hair and beauty products to professional stylists and salons across ve provinces with over 4,000 active customers, best in class suppliers and approximately 100 employees",0,0,0,1,1,0,0,0,0,0,0
SID_298,8583,"Founded in 1981 and based in Halifax, Hallmark Dental Laboratory Limited is the largest dental laboratory in Atlantic Canada serving greater than 500 dentists with a long-standing reputation of technical leadership, customer service and education",0,0,0,0,1,0,0,0,0,0,0
SID_298,8584,"Founded in 1983, I-XL Building Products Inc is one of the largest importers and distributors of brick, stone and building products in Canada with roots dating back to 1912",0,0,0,0,1,0,0,0,0,0,0
SID_298,8585,"With a focus on premier products from around the world, I-XL oers customers one of the most comprehensive selections of building envelope products available",0,0,0,0,1,0,0,0,0,0,0
SID_298,8586,"Located in Calgary, Levy's Machine Works Ltd was founded in 1980 and is a custom design and specialty manufacturing company that services a diverse customer base in the energy, electronics, medical, agriculture, aviation and instrumentation sectors",0,0,0,0,1,0,0,0,0,0,0
SID_298,8587,"Founded in 1982, The Master Mechanic Inc is one of the leading franchisors of aftermarket automotive maintenance and repair service centers in Ontario",0,0,0,0,1,0,0,0,0,0,0
SID_298,8588,"With 39 locations located throughout Ontario, Master Mechanic has established enduring franchisee relationships and a reputation for outstanding customer service",0,0,0,0,1,0,0,0,0,0,0
SID_298,8589,"Metercor Inc was founded in 1997 and is one of Canada's leading utility meter solutions (sales, installation, and service) providers focusing on water and natural gas",0,0,0,0,1,0,0,0,0,0,0
SID_298,8590,The Calgary headquartered company also services the emerging electricity smart metering market,0,0,0,0,1,0,0,0,0,0,0
SID_298,8591,"Metro Testing & Engineering Ltd was founded in 1987 and is headquartered in Burnaby, British Columbia",0,0,0,1,0,0,0,0,0,0,0
SID_298,8592,Metro is an engineering and materials testing company with 250 employees,0,0,0,1,0,0,0,0,0,0,0
SID_298,8593,Metros diverse and fully integrated oering make them a key partner on many of the countrys largest infrastructure projects,0,0,0,0,1,0,0,0,0,0,0
SID_298,8594,"Founded in 1982 and headquartered in Medicine Hat, Alberta, Nutters Bulk and Natural Foods Inc is a retailer, franchisor, and packager of vitamins and natural foods",0,0,0,1,1,0,0,0,0,0,0
SID_298,8595,"With 23 stores (11 corporate and 12 franchised) located throughout Western Canada and 150 employees, Nutters has developed a successful business model that attracts loyal customers, top quality sta, entrepreneurial franchisees and suppliers of unique natural personal care, health, and organic products",0,0,0,0,1,0,0,0,0,0,0
SID_298,8596,"Founded in 1983 and based in Vancouver, Protec Dental Laboratories (2021) Inc is the leading dental laboratory in British Columbia",0,0,0,1,1,0,0,0,0,0,0
SID_298,8597,"Protec serves over 2,500 dentists across Canada and is considered a Canadian market leader in dental lab technology including 3D printing and digital scanning",0,0,0,0,1,0,0,0,0,0,0
SID_298,8598,"Founded in 1944, Shaw Dental Laboratory Inc is the leading network of dental laboratories in Ontario, with locations in Toronto, London, Ottawa and Kingston",0,0,0,0,1,0,0,0,0,0,0
SID_298,8599,"Shaw Lab Group, whose diverse customer base includes over 1,500 dentists, has an established reputation for technical leadership and outstanding customer service",0,0,0,0,1,0,0,0,0,0,0
SID_298,8600,"Smitty's Canada Inc was founded in 1960 and is headquartered in Calgary, Alberta",0,0,0,1,0,0,0,0,0,0,0
SID_298,8601,"With 85 locations across Canada (81 franchise locations and 1 corporate location), Smitty's is one of Canada's largest family restaurant chains",0,0,0,0,1,0,0,0,0,0,0
SID_298,8602,"Smitty's has developed a long-term sustainable business model that attracts loyal customers, entrepreneurial franchisees, and has a strong supplier and franchise support system",0,0,0,0,0,0,0,0,0,0,0
SID_298,8603,"Founded in 1969, Visage Cosmetics Limited is the leading franchisor of retail beauty and cosmetics services and products in Ontario",0,0,0,0,1,0,0,0,0,0,0
SID_298,8604,"With 31 locations throughout Ontario and one in Alberta, Visage Cosmetics has established enduring franchisee relationships and a reputation for outstanding guest service",0,0,0,0,1,0,0,0,0,0,0
SID_298,8605,"Founded in 1975, Wingenback Ltd is one of Canadas premier industrial and commercial logistics businesses",0,0,0,0,1,0,0,0,0,0,0
SID_298,8606,"Wingenback provides businesses and organizations across Canada with premier solutions in ATM-related products, high-end industrial moving and project management services",0,0,0,0,1,0,0,0,0,0,0
SID_298,8607,Wingenback serves,0,0,0,0,1,0,0,0,0,0,0
SID_298,8608,a broad span of industries with roots in the nancial and banking sector,0,0,0,0,1,0,0,0,0,0,0
SID_298,8609,"Wingenback has ve divisions that service Canada with their head oce in Calgary, Alberta",0,0,0,1,1,0,0,0,0,0,0
SID_298,8610,"Equipment utilized to facilitate the various production processes in manufacturing, solutions and logistics related entities is sourced from a broad range of both domestic vendors and international vendors, who manufacture or source their resale products from a variety of domestic and international vendors",0,0,0,0,0,1,0,0,0,0,0
SID_298,8611,"Resale goods entities generally source their products from internationally based vendors who source their goods, or components of their goods, from a wide geographic array of providers",0,0,0,0,0,1,0,0,0,0,0
SID_298,8612,"Dental industry participants generally source a signicant portion of dental treatment components and devices from international vendors, with India and China being key sourcing geographies",0,0,0,0,0,1,0,0,0,0,0
SID_298,8613,The Reporting Entities are not generally able to exert a high level of inuence over suppliers of key materials or equipment,0,0,0,0,0,0,0,0,0,0,0
SID_298,8614,The Reporting Entities combined supply chain is comprised of thousands of large and small vendors,0,0,0,0,0,1,0,0,0,0,0
SID_298,8615,"The Reporting Entities have over 4000 trade and service provider vendors, approximately 260 of which each spend over $100 thousand per annum, representing over 70% of the scal 2023 expenditure completed with non aliated trade vendors",0,0,0,0,0,1,0,0,0,0,0
SID_298,8616,Policies and its due diligence processes in relation to forced labour and child labour,0,0,0,0,0,0,0,0,0,0,0
SID_298,8617,"Modern Slavery is identied by the International Labour Organization (ILO) as an umbrella term covering practices such as forced labour, debt bondage, forced marriage, child labour and human tracking",0,0,0,0,0,0,0,0,0,0,0
SID_298,8618,"Essentially, it refers to situations of exploitation that a person cannot refuse or leave employment because of threats, violence, coercion, deception, and/or abuse of power",0,0,0,0,0,0,0,0,0,0,0
SID_298,8619,"Due to the nature of activities, the Reporting Entities are aware that modern slavery risks may possibly exist within its combined supply chain and has commenced the implementation of due diligence processes to identify and address these risks through mitigation procedures",0,0,0,0,0,0,0,0,0,0,0
SID_298,8620,Its due diligence process is generally based on the principles as outlined in the OECD Due Diligence Guidance for Responsible Business Conduct and includes the following,0,0,0,0,0,0,0,0,0,0,0
SID_298,8621,The Reporting Entities have committed to understanding and endeavoring to mitigate the risks of modern slavery within the combined supply chain,0,0,0,0,0,0,0,0,0,0,0
SID_298,8622,Risk Assessment: The Reporting Entities will endeavour to conduct a risk assessment of new and existing direct suppliers to identify potential modern slavery risks or other human rights violations,0,0,0,0,0,0,0,1,0,0,0
SID_298,8623,"This may include reviewing internet articles and reference materials and any modern slavery act statements submitted in Canada or other jurisdictions (eg Australia, the UK, California)",0,0,0,0,0,0,0,0,0,0,0
SID_298,8624,"Reference sources include information from authorities such as the US government, NGOs and industry partners such as ILO Better Work, and The Institute for Human Rights and Business or industry bodies",0,0,0,0,0,0,0,1,0,0,0
SID_298,8625,Supplier Engagement: The Reporting Entities will endeavor to engage with direct suppliers to communicate expectations and requirements regarding modern slavery risks,0,0,0,0,0,0,0,1,0,0,0
SID_298,8626,This may include the communication and acknowledgement of a Vendor Code of Conduct,0,0,0,0,0,0,0,0,0,0,0
SID_298,8627,Remediation: The Reporting Entities will endeavor to work with direct suppliers to address any identied risks,0,0,0,0,0,0,0,0,1,0,0
SID_298,8628,Monitoring: The Reporting Entities will endeavor to monitor direct suppliers' compliance with policies,0,0,0,0,0,0,0,1,0,0,0
SID_298,8629,Disclosure and Communication: The Reporting Entities will endeavor to report on ndings and activities regarding modern slavery risks to the Board of Directors of Equicapita Income GP and seek to implement continuous improvement diligence policies and processes,0,0,0,0,0,0,0,1,0,0,0
SID_298,8630,The Reporting Entities will not tolerate the use of forced/child labour in supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_298,8631,Pertaining directly to point b,0,0,0,0,0,0,0,0,0,0,0
SID_298,8632,"above, supplier risk assessment will be conducted based on consideration of four parameters",0,0,0,0,0,0,0,0,0,0,0
SID_298,8633,risk relating to the nature of the suppliers activity,0,0,0,0,0,0,0,0,0,0,0
SID_298,8634,risk relating to the country in which the supplier carries out its main activities (as evidenced by risk mapping work),0,0,0,0,0,0,0,0,0,0,0
SID_298,8635,the Reporting Entities current and anticipated spend with the supplier; and,0,0,0,0,0,0,0,0,0,0,0
SID_298,8636,the Reporting Entities dependency on the supplier,0,0,0,0,0,0,0,0,0,0,0
SID_298,8637,"The combination of the four selected criteria leads to the identication of the most critical suppliers to which the Reporting Entities are exposed in their supply chains, who will be prioritised in the implementation of further assessment and monitoring measures",0,0,0,0,0,0,0,0,0,0,0
SID_298,8638,The parts of its business and supply chains that carry a risk of forced labour or child labour being used and the steps it has taken to assess and manage that risk,0,0,0,0,0,0,0,0,0,0,0
SID_298,8639,"The Reporting Entities conduct manufacturing and service operations strictly within Canada, sourcing manufacturing inputs directly from continental providers",0,0,0,0,1,1,0,0,0,0,0
SID_298,8640,Canada and the USA have both been rated by the Walk-Free Global Slavery Index as low risk for incidences and vulnerability related to forced labour (source: Global Slavery Index 2023),0,0,0,0,0,0,0,0,0,0,0
SID_298,8641,"Some of the equipment, production materials or resale products the Reporting Entities source, however, originate from international suppliers, notably from suppliers conducting operations in higher risk countries, as identied by the Walk Free Global Slavery Index",0,0,0,0,0,1,1,0,0,0,0
SID_298,8642,"To better identify and understand the exposure to risks of modern slavery, the Reporting Entities have, to the extent possible, mapped the operational areas of its key tier 1 suppliers, as well as the operational locations of the suppliers to those suppliers (ie tier 2 suppliers)",0,0,0,0,0,0,0,1,0,0,0
SID_298,8643,"The Reporting Entities understand that supply chains reaching back to the resources extraction sector as related to mining for the components of steel and other metals, may be broadly considered a high-risk industry due to the risks relating to the geographies in which such businesses or their supply chains operate",0,0,0,0,0,1,1,0,0,0,0
SID_298,8644,"Risks, for example, relate to",0,0,0,0,0,0,1,0,0,0,0
SID_298,8645,"the presence of militias, criminal organisations and corrupt governments in countries that are conict aected or prone to instability",0,0,0,0,0,0,1,0,0,0,0
SID_298,8646,the demand for base-skill workers in construction of infrastructure,0,0,0,0,0,0,1,0,0,0,0
SID_298,8647,frequent outsourcing of labour to third party contractors,0,0,0,0,0,0,1,0,0,0,0
SID_298,8648,low visibility over multi-tiered supply chains; and,0,0,0,0,0,0,1,0,0,0,0
SID_298,8649,"chartering and contracting sea transport, which is a known high-risk sector",0,0,0,0,0,0,1,0,0,0,0
SID_298,8650,"(Source: Resources, Energy and Modern Slavery, author the Australian Human Rights Commission) For this reason, the Reporting Entities will endeavor to develop diligence processes as outlined in the previous section and will endeavor to develop remediation processes and monitoring mechanisms",0,0,0,0,0,0,0,0,0,0,0
SID_298,8651,These steps may include improved communication avenues with tier 1 vendors and an eort to investigate deeper into the supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_298,8652,Measures taken to remediate any forced labour or child labour,0,0,0,0,0,0,0,0,0,0,0
SID_298,8653,"After due diligence in completing this report, the Reporting Entities are not currently aware of any forced labour or child labour transgressions",0,0,0,0,0,0,1,0,0,0,0
SID_298,8654,"Moving forward, the Reporting Entities will endeavor to develop response policies to ensure they are ready to react and remediate should incidences of forced or child labour be identied",0,0,0,0,0,0,0,0,0,0,0
SID_298,8655,Policies and practices to identify and remediate forced labour incidents may include the following,0,0,0,0,0,0,0,0,0,0,0
SID_298,8656,the institution of grievance mechanisms,0,0,0,0,0,0,0,0,0,0,0
SID_298,8657,directed communications and actions to remediate transgression practices; and,0,0,0,0,0,0,0,0,0,0,0
SID_298,8658,policies intended to prevent recurrence,0,0,0,0,0,0,0,0,0,0,0
SID_298,8659,Measures taken to remediate the loss of income to the most vulnerable families that results from any measure taken to eliminate the use of forced labour or child labour in its activities and supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_298,8660,"To date, the Reporting Entities, after diligence completed to submit this report, are not aware of instances of child labour or forced labour in their supply chains",0,0,0,0,0,0,1,0,0,0,0
SID_298,8661,It thus follows that the Reporting Entities have not been able to identify any instances of income loss of vulnerable families that result from measures taken to eliminate the use of forced labour or child labour in its supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_269,8662,Training provided to employees on forced labour and child labour,0,0,0,0,0,0,0,0,0,0,0
SID_298,8663,The Reporting Entities did not oer any formal training to employees on the issues of forced labour and child labour during the Reporting Period,0,0,0,0,0,0,0,1,0,0,0
SID_298,8664,"However, the Reporting Entities will endeavor to provide training for key leadership personnel and procurement teams to heighten awareness of modern slavery and to enhance awareness of how to mitigate modern slavery risks, as well as to promote understanding of internal due diligence processes",0,0,0,0,0,0,0,1,0,0,0
SID_298,8665,Eectiveness in ensuring that forced labour and child labour are not being used in its business and supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_298,8666,"As of the Reporting Period, no actions have been taken to formally assess the eectiveness of measures taken to date",0,0,0,0,0,0,0,0,0,1,0
SID_298,8667,Performance Indicators The Reporting Entities are in the process of designing a program to endeavor to measure eectiveness in making progress in eorts to combat modern slavery,0,0,0,0,0,0,0,0,0,0,0
SID_298,8668,"The Reporting Entities will endeavor to track key performance indicators, which may include",0,0,0,0,0,0,0,0,0,1,0
SID_298,8669,The % of annual total system expenditure of the global Tier 1 supply chain investigated (risk mapped),0,0,0,0,0,0,0,0,0,1,0
SID_298,8670,The number of suppliers who have acknowledged the Vendor Code of Conduct,0,0,0,0,0,0,0,0,0,0,0
SID_298,8671,The number of key suppliers who have instituted Supplier Codes of Conduct,0,0,0,0,0,0,0,0,0,0,0
SID_298,8672,The number of reported incidents of modern slavery by tier 1 vendors submitting modern slavery act reports,0,0,0,0,0,0,0,0,0,1,0
SID_298,8673,The Reporting Entities will endeavor to use performance indicators to identify areas that require improvement,0,0,0,0,0,0,0,0,0,0,0
SID_298,8674,"Additionally, the Reporting Entities will endeavour to review policies and procedures related to forced labour and child labour",0,0,0,0,0,0,0,0,0,1,0
SID_298,8675,Conclusion and Approval The Reporting Entities will endeavor to regularly assess progress and identify areas of improvement,0,0,0,0,0,0,0,0,0,0,0
SID_298,8676,"This report has been approved by the Board of Directors of Equicapita Income GP, the Administrator of Equicapita Income Trust and the General Partner of Equicapita Income LP pursuant to subparagraph 11 (4)(b)(ii) of the Act",1,0,0,0,0,0,0,0,0,0,0
SID_298,8677,"In accordance with the requirements of the Act, and in particular, section 11 thereof, I attest that I have reviewed the information contained in the report for the Reporting Entities listed above",0,0,0,0,0,0,0,0,0,0,0
SID_298,8678,"Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the Reporting Period",0,0,0,0,0,0,0,0,0,0,0
SID_298,8679,"I make the above attestation in my capacity as a director of the board of Equicapita Income GP Inc for and on behalf of the board of Equicapita Income GP Inc, administrator of Equicapita Income Trust and General Partner of Equicapita Income LP",0,0,0,0,0,0,0,0,0,0,0
SID_298,8680,"Stephen Johnston signed Director May 31, 2024",0,1,0,0,0,0,0,0,0,0,0
SID_298,8681,I have the authority to bind Equicapita Income LP and Equicapita Income Trust,0,0,0,0,0,0,0,0,0,0,0
SID_301,8728,"Page 1 of 6 Jim Pattison Developments Ltd Modern Slavery Report 2023 This Modern Slavery Report (the Report) addresses the period from January 1, 2023 to December 31, 2023 and has been prepared in compliance with Bill S-211, An Act to enact the Fighting Against Forced Labour and Child Labour in Supply Chains Act and to amend the Customs Tariff (Canada) (the Act)",0,0,0,0,0,0,0,0,0,0,0
SID_301,8729,This Report is made on behalf of Jim Pattison Developments Ltd (JPD) and is not a joint report,0,0,0,0,0,0,0,0,0,0,0
SID_301,8730,Page 2 of 6,0,0,0,0,0,0,0,0,0,0,0
SID_301,8731,"INTRODUCTION Forced labour and child labour, each as defined in the Act, are crimes and serious violations of human rights",0,0,0,0,0,0,0,0,0,0,0
SID_301,8732,"As the rapidly growing real estate business of Canadas largest private company The Jim Pattison Group, Jim Pattison Developments Ltd recognizes the essential role that we have in ensuring that the supply chains that support our business operations adhere to the highest ethical standards, including the prevention and identification of forced labour and child labour in our supply chain",0,0,0,0,1,0,0,0,0,0,0
SID_301,8733,"This Report sets out the overview of our company, the steps we undertake, and the processes and policies to be implemented in order to prevent and reduce the risk that forced labour or child labour may be used in any facet of our operations",0,0,0,0,0,0,0,0,0,0,0
SID_301,8734,II,0,0,0,0,0,0,0,0,0,0,0
SID_301,8735,CORPORATE OVERVIEW AND SUPPLY CHAINS Company Structure and Background JPD is a private corporation incorporated in December 2001 under business registration number 122022882 BC0001,0,0,0,1,0,0,0,0,0,0,0
SID_301,8736,JPD is a company of The Jim Pattison Group which has been in operation since December 2001,0,0,0,1,0,0,0,0,0,0,0
SID_301,8737,"JPD is operated by a leadership team including the President, Senior Vice President, Vice President, Development & Investment, Vice President, Finance, Vice President, Construction & Project Management, and Directors of Property Management, Finance & Accounting, and Real Estate & Lease Administration",0,0,0,0,1,0,0,0,0,0,0
SID_301,8738,The leadership team provides the framework and support for each of its departments daily operations,0,0,0,0,0,0,0,0,0,0,0
SID_301,8739,"The head office of JPD is located at #200 879 Marine Drive, North Vancouver, British Columbia with satellite offices currently located in Surrey and Nelson, British Columbia, as well as in Edmonton and Calgary, Alberta, employing 42 direct employees at present",0,0,0,1,1,0,0,0,0,0,0
SID_301,8740,Company Activities JPD owns and manages a portfolio of 19 million square feet of income producing properties throughout Canada and the United States under Jim Pattison Developments (U.S.) Inc (JPDUS) (a company incorporated under the State of Washington),0,0,0,1,1,0,0,0,0,0,0
SID_301,8741,The JPD portfolio includes the largest portfolio of grocery anchored shopping centres in British Columbia and Alberta,0,0,0,0,1,0,0,0,0,0,0
SID_301,8742,Our portfolio overall is conservatively valued at over $4 billion,0,0,0,0,0,0,0,0,0,0,0
SID_301,8743,"JPD supports the real estate operations of The Jim Pattison Group companies, which are identified on The Jim Pattison Groups website (www.jimpattison.com), through property development, construction, management, and investment",0,0,0,0,1,0,0,0,0,0,0
SID_301,8744,"In addition, JPD undertakes independent projects which span retail, office, industrial, and residential development",0,0,0,0,1,0,0,0,0,0,0
SID_301,8745,Page 3 of 6 Supply Chain JPDs supply chain includes businesses that are based in both Canada and the United States,0,0,0,0,0,1,0,0,0,0,0
SID_301,8746,These businesses provide contractual services and products in final form to our company on an as required basis,0,0,0,0,0,1,0,0,0,0,0
SID_301,8747,"JPD engages various businesses such as those that provide property services to assist with the maintenance, operations, and upkeep of its diverse portfolio to a first-class condition and standard, in addition to, consultants and contractors to help facilitate property development and construction",0,0,0,0,0,1,0,0,0,0,0
SID_301,8748,"Our procurement management process involves the review and approval by JPDs executive team, in respect of its property and asset management, development, and construction departments",0,0,0,0,0,0,0,0,0,0,0
SID_301,8749,"This process includes planning for the required needs, budgeting, sourcing of goods and services using a competitive analysis and evaluation of reputable suppliers",0,0,0,0,0,0,0,0,0,0,0
SID_301,8750,"In respect of our business operations in Canada, in 2022, JPD procured goods and services from approximately 810 suppliers and contractors with total expenditures being approximately $82 million",0,0,0,0,0,1,0,0,0,0,0
SID_301,8751,"While in 2023, JPD procured goods and services from approximately 896 suppliers and contractors with total expenditures being approximately $124 million",0,0,0,0,0,1,0,0,0,0,0
SID_301,8752,"In respect of our business operations in the United States, in 2022, JPDUS procured goods and services from approximately 55 suppliers and contractors with total expenditures being approximately $15 million",0,0,0,0,0,1,0,0,0,0,0
SID_301,8753,"While in 2023, JPDUS procured goods and services from approximately 88 suppliers and contractors with total expenditures being approximately $66 million",0,0,0,0,0,1,0,0,0,0,0
SID_301,8754,III,0,0,0,0,0,0,0,0,0,0,0
SID_301,8755,"POLICIES AND DUE DILIGENCE PROCESSES Policies and Procedures With our Whistle Blower Policy enforced in June 2022, we communicate our values and expectations, setting a high bar for ourselves and our third-party suppliers and contractors, and make it clear that we do not tolerate any forms of injustice",0,0,0,0,0,0,0,1,0,0,0
SID_301,8756,We are committed to consistently evolve and improve our approach and policies,0,0,0,0,0,0,0,0,0,0,0
SID_301,8757,JPD is committed to maintaining high ethical standards and conducting legitimate business practices,0,0,0,0,0,0,0,0,0,0,0
SID_301,8758,"This is the foundation of our company, its policies, and principles",0,0,0,0,0,0,0,0,0,0,0
SID_301,8759,JPD strives on professionalism and lawful and ethical conduct of its employees,0,0,0,0,0,0,0,0,0,0,0
SID_301,8760,These are the expectations required of our employees and also of our suppliers and contractors in that they comply with all applicable legal requirements in the jurisdictions in which they operate and consistently monitor and enforce the upmost lawful conduct,0,0,0,0,0,0,0,0,0,0,0
SID_301,8761,We also expect our suppliers to share in our commitment to respect human rights and strive to meet the highest ethical business standards and best practices for responsible business conduct,0,0,0,0,0,0,0,0,0,0,0
SID_301,8762,"Through our Whistleblower Policy, we encourage the identification and prevention of any misconduct that may impact our commitment",0,0,0,0,0,0,0,1,0,0,0
SID_301,8763,This policy allows our employees to raise any serious concerns with the assurance that they will be protected from reprisal for whistleblowing in good faith,0,0,0,0,0,0,0,1,0,0,0
SID_301,8764,"Page 4 of 6 Roles and Responsibilities JPD does not tolerate child, forced or bonded labour in any of our operations, or in the operations of our suppliers, subcontractors, and other business partners",0,0,0,0,0,0,0,0,0,0,0
SID_301,8765,"Our executive leadership team makes every effort to mitigate this risk, either directly or through JPDs employees, including carrying out our due diligence and audits to monitor the performance of our suppliers and to prevent our activities harming human rights",0,0,0,0,0,0,0,1,0,0,0
SID_301,8766,Risk Assessment Process We expect third parties with which we work to adhere to business principles and values similar to our own and to comply with all applicable laws and regulations,0,0,0,0,0,0,0,0,0,0,0
SID_301,8767,"Before making any commitments towards third parties, we take steps to appropriately evaluate the relationship and mitigate any associated risks by carrying out risk-based due diligence and checks",0,0,0,0,0,0,0,0,0,0,0
SID_301,8768,"To mitigate this risk, we follow a due diligence approach that includes the following steps",0,0,0,0,0,0,0,1,0,0,0
SID_301,8769,Supplier visits,0,0,0,0,0,0,0,1,0,0,0
SID_301,8770,Supplier confirmation; and,0,0,0,0,0,0,0,0,0,0,0
SID_301,8771,Embedding responsible business conduct into policies and management systems,0,0,0,0,0,0,0,0,0,0,0
SID_301,8772,IV,0,0,0,0,0,0,0,0,0,0,0
SID_301,8773,"RISK ASSESSMENT AND MANAGEMENT JPD intends to engage in various activities to identify, assess, and manage supplier risk",0,0,0,0,0,0,0,0,0,0,0
SID_301,8774,"In assessing the risk of forced and child labour in our business and supply chains, we will engage with our peers to discuss risks",0,0,0,0,0,0,0,1,0,0,0
SID_301,8775,"To identify the business activities with the greatest exposure to these risks, we consider the following factors",0,0,0,0,0,0,0,1,0,0,0
SID_301,8776,Reliance on low skilled workforce,0,0,0,0,0,0,0,1,0,0,0
SID_301,8777,Dangerous or undesirable work; and,0,0,0,0,0,0,0,1,0,0,0
SID_301,8778,Presence of migrant workers,0,0,0,0,0,0,0,1,0,0,0
SID_301,8779,"Our exposure to the risk of forced labour and/or child labour may occur when we engage with third parties, particularly in categories such as construction and property maintenance",0,0,0,0,0,0,1,0,0,0,0
SID_301,8780,We recognize that our exposure to forced labour and/or child labour increases when we engage with suppliers who may source goods from countries where forced labour exploitation is known to occur,0,0,0,0,0,0,0,0,0,0,0
SID_301,8781,"As such, we continue to follow a risk-based approach to our due diligence activities",0,0,0,0,0,0,0,0,0,0,0
SID_301,8782,"Our due diligence is prioritized to the most significant adverse impacts based on severity and the likelihood of harm, which is where we focus our attention and resources",0,0,0,0,0,0,0,0,0,0,0
SID_301,8783,Our approach to prevent and reduce the risks of forced labour and child labour in higher risk areas of the supply chain include: gathering information on worker recruitment and maintaining internal controls to ensure that all workers are recruited voluntarily; prioritizing due diligence efforts on the most severe risks of forced and child labour; requiring suppliers to have in place policies and procedures for identifying and prohibiting the use of forced labour and/or child labour in their activities and supply chains; and monitoring suppliers,0,0,0,0,0,0,0,1,0,0,0
SID_301,8784,Page 5 of 6,0,0,0,0,0,0,0,0,0,0,0
SID_301,8785,MODERN SLAVERY REMEDIATION MEASURES JPD requires our suppliers to adhere to high standards of ethical conduct,0,0,0,0,0,0,0,0,0,0,0
SID_301,8786,Forced and child labour is strictly prohibited,0,0,0,0,0,0,0,1,0,0,0
SID_301,8787,We also undertake diligence efforts to ensure that the risk of forced labour and child labour is mitigated in our business,0,0,0,0,0,0,0,1,0,0,0
SID_301,8788,"If we discover any forced labour or child labour in our business and supply chains, we take the following measures to remediate such forced labour or child labour",0,0,0,0,0,0,0,0,1,0,0
SID_301,8789,"Suspension or termination of a supplier, sub-supplier or contractor",0,0,0,0,0,0,0,0,1,0,0
SID_301,8790,Actions to prevent forced labour or child labour and associated harms from reoccurring,0,0,0,0,0,0,0,0,1,0,0
SID_301,8791,Actions to support victims of forced labour or child labour,0,0,0,0,0,0,0,0,1,0,0
SID_301,8792,Grievance mechanisms; and,0,0,0,0,0,0,0,0,1,0,0
SID_301,8793,Formal apologies,0,0,0,0,0,0,0,0,1,0,0
SID_301,8794,VI,0,0,0,0,0,0,0,0,0,0,0
SID_301,8795,LOSS OF INCOME REMEDIATION MEASURES JPD does not currently have measures in place to remediate any forced or child labour in our supply chain,0,0,0,0,0,0,0,0,1,0,0
SID_301,8796,"As of the writing of this Report, we have no knowledge of forced or child labour being used in our supply chain, but we are committed to the addition of processes to help identify these instances and support the development of an appropriate remediation approach",0,0,0,0,0,0,0,0,0,1,0
SID_301,8797,VII,0,0,0,0,0,0,0,0,0,0,0
SID_301,8798,"TRAINING JPD personnel, at all levels, undergo a mandatory training process to ensure that our policies and procedures are understood and properly applied to our daily activities",0,0,0,0,0,0,0,1,0,0,0
SID_301,8799,Employees are educated on our values and policies and informed of how to report wrongdoing under our Whistleblower Policy,0,0,0,0,0,0,0,1,0,0,0
SID_301,8800,We provide employees with ongoing and periodic training opportunities to ensure that all employees have current knowledge,0,0,0,0,0,0,0,0,0,0,0
SID_301,8801,All personnel ensure the applicable policies and procedures are provided to all suppliers,0,0,0,0,0,0,0,0,0,0,0
SID_301,8802,JPD currently does not have specific training measures in place on forced and child labour,0,0,0,0,0,0,0,1,0,0,0
SID_301,8803,VIII,0,0,0,0,0,0,0,0,0,0,0
SID_301,8804,ASSESSING EFFECTIVENESS Monitoring Approach JPD monitors compliance with our policies on an ongoing basis,0,0,0,0,0,0,0,0,0,0,0
SID_301,8805,We also review any concerns raised through our Whistleblower Policy and other informal mechanisms of employee feedback,0,0,0,0,0,0,0,0,0,1,0
SID_301,8806,"To date, no significant concerns or complaints have been identified",0,0,0,0,0,0,1,0,0,0,0
SID_301,8807,We also assess the effectiveness of our policies by,0,0,0,0,0,0,0,0,0,0,0
SID_301,8808,Setting up a regular review or audit of the organizations policies and procedures related to forced labour and child labour; and,0,0,0,0,0,0,0,0,0,1,0
SID_301,8809,"Tracking relevant performance indicators, such as levels of employee awareness, number of cases reported and solved through grievance mechanisms and number of contracts with anti- forced labour and child labour clauses",0,0,0,0,0,0,0,0,0,1,0
SID_301,8810,Page 6 of 6 Progress on Prior Year JPD is at the relative beginning of creating formalized processes and policies to address forced labour and child labour in our supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_301,8811,We endeavor to have full visibility of the risk and metrics in order to effectively measure potential solutions to address these underlying issues going forward,0,0,0,0,0,0,0,0,0,0,0
SID_301,8812,IX,0,0,0,0,0,0,0,0,0,0,0
SID_301,8813,APPROVAL AND SIGN-OFF This Report has been approved by the President of JPD and has been submitted to the Minister of Public Safety and Emergency Preparedness in Canada,0,0,0,0,0,0,0,0,0,0,0
SID_301,8814,This Report will be made available on our company website (www.jpdevelopments.com),0,0,0,0,0,0,0,0,0,0,0
SID_301,8815,"In accordance with the requirements of the Act, and in particular Section 11 thereof, I attest that I have reviewed the information contained in this Report for JPD",0,0,0,0,0,0,0,0,0,0,0
SID_301,8816,"Based on my knowledge, and having exercised reasonable diligence, I attest that the information in this Report is true, accurate, and complete in all material respects for the purposes of the Act for the reporting year listed above",0,0,0,0,0,0,0,0,0,0,0
SID_301,8817,"Date: May 31, 2024 Jim Pattison Developments Ltd Per: __________________________ David Bell, President I have the authority to bind the Company",0,1,0,0,0,0,0,0,0,0,0
SID_302,8818,"77232922.1 2023 Supply Chain Act Annual Report Melloul-Blamey Construction Inc (Melloul-Blamey, we, us or our) produces this inaugural Annual Report (the Report) pursuant to section 11(1) of the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Supply Chains Act or the Act) for the twelve-month financial year ended December 31, 2023 (the Reporting Period)",0,0,0,0,0,0,0,0,0,0,0
SID_302,8819,"Our Structure, Operations and Supply Chains Melloul-Blamey was incorporated under the Ontario Business Corporations Act and has its registered and head office in Waterloo, Ontario, Canada",0,0,0,1,0,0,0,0,0,0,0
SID_302,8820,"Since its inception in 1982, Melloul- Blamey has become one of the largest General Contractors in Canadas Technology Triangle which comprise the cities of Cambridge, Kitchener and Waterloo in Southwestern Ontario",0,0,0,0,1,0,0,0,0,0,0
SID_302,8821,"Over the years, Melloul-Blamey has continued to evolve and adapt to the ever-changing construction market",0,0,0,0,0,0,0,0,0,0,0
SID_302,8822,"Today, we offers a full range of services to meet the needs of our clients",0,0,0,0,0,0,0,0,0,0,0
SID_302,8823,"Melloul-Blameys portfolio of services includes: general contracting, construction management, design-build, real estate development services, specialty contracts and green building",0,0,0,0,1,0,0,0,0,0,0
SID_302,8824,"As of December 31, 2023, Melloul-Blamey had approximately 260 employees",0,0,0,1,0,0,0,0,0,0,0
SID_302,8825,Melloul-Blamey does not manufacture goods or handle raw materials,0,0,0,0,1,0,0,0,0,0,0
SID_302,8826,"As a construction company, Melloul-Blamey works with more than 800 suppliers and subcontractors",0,0,0,0,0,1,0,0,0,0,0
SID_302,8827,We are committed to carrying out our business in a way that is respectful of human rights and in particular we want to reduce the risk of forced labour and child labour in our operation and supply chain,0,0,0,0,0,0,0,0,0,0,0
SID_302,8828,In the future we are planning to put in place an effective forced labour and child labour risk mitigation program,0,0,0,0,0,0,0,0,0,0,0
SID_302,8829,"The Steps We Have Taken during the Reporting Period to Prevent and Reduce the Risk of Forced Labour and Child Labour During the Reporting Period, we initiated a reflection on the shape our policies regarding forced labour and child labour in our supply chain should take",0,0,0,0,0,0,0,0,0,0,0
SID_302,8830,No other action was taken by Melloul- Blamey in this area during the Reporting Period,0,0,0,0,0,0,0,1,0,0,0
SID_302,8831,"Policies, Due Diligence and Controls At the moment, Melloul-Blamey does not have policies regarding forced labour, child labour or human rights in general",0,0,0,0,0,0,0,1,0,0,0
SID_302,8832,We have not developed due diligence processes or controls in regards to these topics,0,0,0,0,0,0,0,1,0,0,0
SID_302,8833,"Nonetheless, we aim to develop policies tackling these issues to ensure that instances of forced labour or child labour in our supply chain are uncovered and addressed",0,0,0,0,0,0,0,1,0,0,0
SID_302,8834,"Risk Assessment Methodology and Results of Assessment During the Reporting Period, we did not make any assessment of the potential risk related to forced labour and child labour in our operations and supply chains",0,0,0,0,0,0,0,1,0,0,0
SID_302,8835,"In the future, we plan to roll- out a compliance program which may include a questionnaire designed to specifically addressed the issue of forced labour and child labour which we initially plan to send to our Tier 1 (direct) suppliers",0,0,0,0,0,0,0,1,0,0,0
SID_302,8836,"Risks of Forced Labour and Child Labour in our Operations and Supply Chains To the best of our knowledge, during the Reporting Period we have not identified risks of forced labour and child labour in our operations and supply chains",0,0,0,0,0,0,1,0,0,0,0
SID_302,8837,"However, our risk assessment process with respect to this issue is currently non existence",0,0,0,0,0,0,0,1,0,0,0
SID_302,8838,We expect to set-up a compliance program to address this issue in the future,0,0,0,0,0,0,0,1,0,0,0
SID_302,8839,"Remedial Action Taken during the Reporting Period Since we have not identified any forced labour or child labour in our activities and supply chains during the Reporting Period, we have not taken any remediation measures",0,0,0,0,0,0,1,0,1,0,0
SID_302,8840,"Our remediation processes Since we have no compliance program addressing specifically the issue of forced labour and child labour in our operations and supply chains, we have currently no remediation process in place to deal with this issue",0,0,0,0,0,0,0,1,1,0,0
SID_302,8841,"Remediation actions for the loss of income to the most vulnerable families that results from any measure taken to eliminate forced labour and child labour from our operations and supply chains No, we have not taken any remediation measures",0,0,0,0,0,0,0,0,0,0,0
SID_302,8842,"Our training We have no director, officer or staff training in place at the moment dealing with forced labour and child labour in our operations and supply chains",0,0,0,0,0,0,0,1,0,0,0
SID_302,8843,Assessing our effectiveness No assessment of our effectiveness to prevent and reduce the occurrence of forced labour and child labour in our operations and supply chains was conducted during the Reporting Period and until we put in place a compliance program to address this issue we are not contemplating doing so,0,0,0,0,0,0,0,0,0,1,0
SID_302,8844,"Our consultation and governance process In preparing this Report, we have consulted our external legal counsel",0,0,0,0,0,0,0,0,0,0,0
SID_302,8845,"Approval This Report was approved by the board of directors of Melloul-Blamey Inc pursuant to Subsection 11(4)(a) of the Act on May 15, 2024",1,0,0,0,0,0,0,0,0,0,0
SID_302,8846,Conclusion We are committed to preventing forced labour and child labour from taking place in our businesses and in our supply chain,0,0,0,0,0,0,0,0,0,0,0
SID_302,8847,"Accordingly, we expect to develop policies, procedures and practices to address these risks in the future",0,0,0,0,0,0,0,0,0,0,0
SID_302,8848,"Attestation In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the Report for the entity or entities listed above",0,0,0,0,0,0,0,0,0,0,0
SID_302,8849,Based,0,0,0,0,0,0,0,0,0,0,0
SID_302,8850,"on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above",0,0,0,0,0,0,0,0,0,0,0
SID_302,8851,"Dated this 15th day of May, 2024 Mellloul-Blamey Construction Inc",0,0,0,0,0,0,0,0,0,0,0
SID_302,8852,Per: /s/ Joel Melloul,0,1,0,0,0,0,0,0,0,0,0
SID_302,8853,"Joel Melloul, Director, I have the authority to bind Melloul-Blamey Construction Inc",0,1,0,0,0,0,0,0,0,0,0
SID_304,8948,"2023 Report American Textile Company, Incorporated (ATC) is a Pennsylvania corporation entirely owned by its holding company American Textile Company, Incorporated (a Delaware corporation)",0,0,0,1,0,0,0,0,0,0,0
SID_304,8949,"ATC is a manufacturer and distributor of utility bedding including pillows, mattress protectors, and other bedding items",0,0,0,0,1,0,0,0,0,0,0
SID_304,8950,"ATC maintains its corporate headquarters in Duquesne, Pennsylvania, USA",0,0,0,1,0,0,0,0,0,0,0
SID_304,8951,ATC does not have any employees in Canada,0,0,0,1,0,0,0,0,0,0,0
SID_304,8952,"ATC has over 1,000 employees located primarily in the United States, with a small office in Shanghai, China",0,0,0,1,1,0,0,0,0,0,0
SID_304,8953,ATC serves as importer of record to Canada for one retail customer,0,0,0,0,0,1,0,0,0,0,0
SID_304,8954,ATC is aware of the risk of forced labor and child labor particularly in textile mills and vets all supplier and partners,0,0,0,0,0,0,1,1,0,0,0
SID_304,8955,ATC will not engage suppliers or partners if ATC suspects the entity is involved in forced labor or child labor,0,0,0,0,0,0,0,0,0,0,0
SID_304,8956,"ATCs suppliers are located primarily in China, India and Pakistan",0,0,0,0,0,1,0,0,0,0,0
SID_304,8957,For the year 2023 ATC and its auditors not identified any evidence of slavery or child labor in ATCs supply chain,0,0,0,0,0,0,1,0,0,0,0
SID_304,8958,ATC takes the following steps to eliminate slavery and child labor from its supply chain: (1) Verification of product supply chains to evaluate and address risks of slavery and child labor,0,0,0,0,0,0,0,1,0,0,0
SID_304,8959,"ATC uses an independent third-party in its verification activities to identify, assess and manage risks of human trafficking in its product supply chain and to evaluate the risk of noncompliance in slavery, human trafficking and other human rights and labor issues",0,0,0,0,0,0,0,1,0,0,0
SID_304,8960,Audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_304,8961,ATC has an independent third party audit its suppliers compliance with ATCs standards for slavery and child labor in its supply chain,0,0,0,0,0,0,0,1,0,0,0
SID_304,8962,"Our suppliers are on varying audit schedules which are scheduled, announced and confirmed with our suppliers",0,0,0,0,0,0,0,0,0,0,0
SID_304,8963,Certification by direct suppliers that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business,0,0,0,0,0,0,0,1,0,0,0
SID_304,8964,"Our direct suppliers are required to agree to a comprehensive agreement which, among other things, requires them to comply with all applicable laws (which include those regarding slavery and child labor)",0,0,0,0,0,0,0,1,0,0,0
SID_304,8965,Internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking,0,0,0,0,0,0,0,0,0,0,0
SID_304,8966,ATC maintains internal accountability standards and procedures applicable to both employees and contractors who may fail to meet company standards,0,0,0,0,0,0,0,0,0,0,0
SID_304,8967,If an employee fails to meet the accountability standards and procedures they are subject to disciplinary action which may include termination,0,0,0,0,0,0,0,0,1,0,0
SID_304,8968,"If a contractor is in breach of our accountability standards and procedures, the contractor must cure all violations in a timely manner consistent with their contractual obligations or we may terminate our relationship with them",0,0,0,0,0,0,0,0,1,0,0
SID_304,8969,"Training of company employees and management who have direct responsibility for supply chain management on issues of human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products",0,0,0,0,0,0,0,1,0,0,0
SID_304,8970,"We conduct specific mandatory training on slavery and child labor and on our Code of Conduct with employees and management teams, including our sourcing teams that have a relationship with our suppliers",0,0,0,0,0,0,0,1,0,0,0
SID_304,8971,"ATC also reports pursuant to, and has fulfilled the requirements of, the California Transparency in Supply Chains Act",0,0,0,0,0,0,0,0,0,0,0
SID_304,8972,ATTESTATION AND SIGNATURE PAGE FOLLOWS,0,0,0,0,0,0,0,0,0,0,0
SID_308,9044,"Anti-Slavery and Forced Labour Report Next Hydrogen Solutions Inc 2024-05-31 Introduction This report provides an overview of the corporation's commitment and efforts to eradicate slavery and forced labour from its business activities and supply chain, in compliance with the relevant laws and regulations, such as the Canadian Modern Slavery Act 2018 and the US Trafficking Victims Protection Act 2000",0,0,0,0,0,0,0,0,0,0,0
SID_308,9045,"The report also outlines the main challenges and risks that the corporation faces in this area, and the measures it takes to mitigate them",0,0,0,0,0,0,0,0,0,0,0
SID_308,9046,"Our Policies and Principles The corporation has a zero-tolerance policy towards slavery and forced labour in any form and respects and upholds the human rights of all its employees, contractors, suppliers, and customers",0,0,0,0,0,0,0,1,0,0,0
SID_308,9047,The corporation adheres to the following principles and standards that guide its actions and decisions in this regard,0,0,0,0,0,0,0,1,0,0,0
SID_308,9048,"The Universal Declaration of Human Rights and the International Labour Organization's Declaration on Fundamental Principles and Rights at Work, which prohibit slavery, servitude, forced or compulsory labour, and human trafficking",0,0,0,0,0,0,0,1,0,0,0
SID_308,9049,"The United Nations Guiding Principles on Business and Human Rights, which provide a framework for the corporation to respect, protect, and remedy human rights impacts in its operations and supply chain",0,0,0,0,0,0,0,1,0,0,0
SID_308,9050,"The OECD Guidelines for Multinational Enterprises, which recommend that the corporation conducts due diligence to identify, prevent, and address actual or potential adverse human rights impacts in its business activities and supply chain",0,0,0,0,0,0,0,1,0,0,0
SID_308,9051,"The Ethical Trading Initiative Base Code, which sets out the minimum labour standards that the corporation expects from its suppliers and contractors, including the prohibition of slavery and forced labour",0,0,0,0,0,0,0,1,0,0,0
SID_308,9052,"The Corporation's Code of Conduct, which denes the values and principles that the corporation and its employees must follow in their daily work, and the ethical and legal obligations that they must comply with",0,0,0,0,0,0,0,1,0,0,0
SID_308,9053,"The Corporation's Supplier Code of Conduct, which will specify the requirements and expectations that the corporation has for its suppliers and contractors regarding their social, environmental, and ethical practices, including the prohibition of slavery and forced labour",0,0,0,0,0,0,0,1,0,0,0
SID_308,9054,"Our Actions and Initiatives The corporation implements a range of actions and initiatives to prevent and combat slavery and forced labour in its operations and supply chain, such as",0,0,0,0,0,0,0,0,0,0,0
SID_308,9055,"Conducting regular human rights due diligence to identify, assess, and address the potential and actual risks and impacts of slavery and forced labour in its business activities and supply chain, in consultation with relevant stakeholders, such as employees, suppliers, customers, civil society, and government agencies",0,0,0,0,0,0,0,1,0,0,0
SID_308,9056,"Establishing and enforcing contractual clauses and agreements with its suppliers and contractors that require them to comply with the corporation's policies and standards on slavery and forced labour, and to provide evidence of their compliance upon request",0,0,0,0,0,0,0,1,0,0,0
SID_308,9057,"Providing training and awareness-raising programs for its employees, managers, and suppliers on the corporation's policies and standards on slavery and forced labour, and the roles and responsibilities that they have in ensuring their implementation and compliance",0,0,0,0,0,0,0,1,0,0,0
SID_308,9058,"Developing and implementing a grievance mechanism that allows its employees, suppliers, contractors, and other stakeholders to report any concerns or complaints related to slavery and forced labour in the corporation's operations and supply chain, and to receive a prompt and fair response and remedy",0,0,0,0,0,0,0,1,0,0,0
SID_308,9059,"Engaging and collaborating with external partners and initiatives, such as industry associations, multi-stakeholder platforms, civil society organizations, and government agencies, to share best practices, learn from others, and contribute to the collective efforts to eradicate slavery and forced labour from the global economy",0,0,0,0,0,0,0,1,0,0,0
SID_308,9060,"Our Challenges and Risks The corporation recognizes that slavery and forced labour are complex and pervasive issues that affect many sectors and regions of the world, and that it faces various challenges and risks in its efforts to prevent and combat them, such as",0,0,0,0,0,0,0,0,0,0,0
SID_308,9061,"The lack of reliable and comprehensive data and information on the prevalence and nature of slavery and forced labour in some of the countries and industries where the corporation operates or sources its products and services, which hampers its ability to identify and assess the risks and impacts accurately and effectively",0,0,0,0,0,0,1,0,0,0,0
SID_308,9062,"The potential exposure to legal, reputational, and operational risks and liabilities, if the corporation or any of its suppliers or contractors are found to be involved in or linked to slavery and forced labour, which could result in nes, sanctions, lawsuits, boycotts, protests, or loss of contracts, customers, or investors",0,0,0,0,0,0,0,0,0,0,0
SID_308,9063,"The dynamic and evolving nature of the regulatory and societal expectations and demands on the corporation's performance and reporting on slavery and forced labour, which requires the corporation to constantly review and update its policies, standards, and practices, and to communicate and disclose its progress and challenges in a clear and credible manner",0,0,0,0,0,0,0,0,0,0,0
SID_308,9064,"Conclusion The corporation is committed to preventing and combating slavery and forced labour in its operations and supply chain, and to respecting and promoting the human rights of all its stakeholders",0,0,0,0,0,0,0,0,0,0,0
SID_308,9065,"The corporation acknowledges that it has a responsibility and an opportunity to contribute to the global efforts to eradicate these abhorrent practices, and that it also faces signicant challenges and risks in this endeavour",0,0,0,0,0,0,0,0,0,0,0
SID_308,9066,"The corporation will continue to implement and improve its policies, standards, and initiatives in this area, and to engage and collaborate with its internal and external partners and stakeholders, to achieve its goals and objectives, and to address its gaps and shortcomings",0,0,0,0,0,0,0,1,0,0,0
SID_308,9067,"The corporation welcomes any feedback or suggestions on how it can enhance its performance and reporting on slavery and forced labour, and invites anyone who has any concerns or complaints related to this issue to contact the corporation through its grievance mechanism or other channels",0,0,0,0,0,0,0,1,0,0,0
SID_309,9068,"This report is Impact Development Group Inc (IDG or the company) response to Bill S-211, An Act to enact the Fighting Against Forced Labour and Child Labour in Supply Chains Act and to amend the Customs Tariff (the Act), sections 11(1) and 11(3)",0,0,0,0,0,0,0,0,0,0,0
SID_309,9069,"IDG satisfies the definition of an Entity within the Act by having a place of business in Canada, doing business in Canada, having assets in Canada and meeting both the revenue and asset thresholds",0,0,0,0,0,0,0,0,0,0,0
SID_309,9070,"The financial reporting year of IDG covered by this report is January 1, 2023, to December 31, 2023",0,0,0,0,0,0,0,0,0,0,0
SID_309,9071,Steps to Prevent and Reduce Risks of Forced Labour and Child Labour The Act requires reporting entities to describe what steps they have taken in the previous financial year to prevent and reduce the risk that forced labour or child labour is used at any step of the production of goods produced or imported into Canada by the entity,0,0,0,0,0,0,0,0,0,0,0
SID_309,9072,"As described in greater detail below, IDG builds homes in the Republic of Panama and has established corporate policies and due diligence processes to reduce the risk of forced labour and child labour in its supply chains",0,0,0,0,1,0,0,1,0,0,0
SID_309,9073,"Structure, Activities and Supply Chains IDG is a real estate development company, headquartered in Ontario Canada, providing affordable housing solutions supported by longstanding government subsidy programs",0,0,0,1,1,0,0,0,0,0,0
SID_309,9074,"The principal business of IDG is to build and develop affordable, high quality subsidized homes in the Republic of Panama to support the emerging middle-class market",0,0,0,0,1,0,0,0,0,0,0
SID_309,9075,IDG sells directly to the end consumer ie residential homeowners,0,0,0,0,1,0,0,0,0,0,0
SID_309,9076,"The vision of IDG is effectuated by a vertically integrated model which coordinates all services necessary to develop high-quality residential and commercial buildings; including but not limited to land acquisition, financing, architectural, engineering, off-site manufacturing, general contracting, property management, and administration",0,0,0,0,1,0,0,0,0,0,0
SID_309,9077,IDGs active construction operations are restricted to the boundaries of the Republic of Panama at two construction sites Sona and Santiago,0,0,0,0,1,0,0,0,0,0,0
SID_309,9078,"Upon review of the Walkfree global slavery index and the US Department of Labour, IDG acknowledges that the Republic of Panama is identified to have a moderate risk of child labour and or forced labour",0,0,0,0,0,0,1,1,0,0,0
SID_309,9079,The Company engages in both direct and indirect procurement of goods and services for its operations primarily in the Republic of Panama,0,0,0,0,0,1,0,0,0,0,0
SID_309,9080,"IDGs main supplies that are procured for the companys operations include: timber, electronics, large construction resources (gravel, cement, etc.), bathroom & kitchen accessories, and small construction materials (nails, paint, steel, etc.)",0,0,0,0,0,1,0,0,0,0,0
SID_309,9081,"Using the Walk Free Global Slavery Index and the US Department of Labors List of Goods Produced by Child Labor or Forced Labor, IDG had a risk assessment conducted on the types of goods purchased from suppliers",0,0,0,0,0,0,0,1,0,0,0
SID_309,9082,These goods have been evaluated on a range of low to extreme inherent risks of forced and/or child labour,0,0,0,0,0,0,1,0,0,0,0
SID_309,9083,IDG is aware that the purchase of highly complex finished goods from manufacturers and/or distributors may contain a different risk profile within these goods due to the multiple parts used in the manufacturing process,0,0,0,0,0,0,0,0,0,0,0
SID_309,9084,"The most extreme inherent risks of goods procured include timber, electronics, and large construction materials",0,0,0,0,0,0,1,0,0,0,0
SID_309,9085,"IDG does not currently have access to the country of origin for the procured goods, and this may affect the risk ratings of materials purchased",0,0,0,0,0,0,0,0,0,0,0
SID_309,9086,"Direct procurement in the Republic of Panama includes engaging local subcontractors for construction of homes at its Sona and Santiago projects and sourcing of construction materials, from local and domestic suppliers in the Republic of Panama",0,0,0,0,0,1,0,0,0,0,0
SID_309,9087,Contracts with subcontractors are subject to laws and regulations defined by the Ministry of Labour in the Republic of Panama,0,0,0,0,0,1,0,1,0,0,0
SID_309,9088,The Companys indirect procurement in the Republic of Panama consists of purchasing construction material from local suppliers who may import raw materials and finished goods from outside of Republic of Panama before selling to IDG,0,0,0,0,0,1,0,0,0,0,0
SID_309,9089,"For the financial year ended December 31, 2023, the Company employed approximately 11 employees in Canada and the Republic of Panama, including full-time, part-time, contract and seasonal employees, and approximately 120 sub-contractors staff at its construction sites in the Republic of Panama",0,0,0,1,0,1,0,0,0,0,0
SID_309,9090,"The Company procured from approximately 90 vendors in the year ended December 31, 2023 and all were located in the Republic of Panama",0,0,0,0,0,1,0,0,0,0,0
SID_309,9091,out of these 90 vendors individually contributed to more than one percent of total procurement spend in the year,0,0,0,0,0,1,0,0,0,0,0
SID_309,9092,Policies and Due Diligence Processes IDG has the following corporate policies and processes designed to support ethical business conduct and mitigate the modern slavery risks in its supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_309,9093,"IDG Corporate Policies and Commitment to Ethical practices The IDG Board has adopted the Code of Business Conduct and Ethics (the Code of Conduct) that is based on our core values of honesty, social responsibility, and integrity",0,0,0,0,0,0,0,0,0,0,0
SID_309,9094,"The Code of Conduct applies to all employees and independent contractors and includes policies addressing conflict of interest, confidentiality, anti-corruption, the outside activities of employees and officers, gifts and entertainment",0,0,0,0,0,0,0,0,0,0,0
SID_309,9095,"All employees must read, understand, and comply with the Code of Conduct, and compliance must be certified annually, following training which is provided on, at a minimum, an annual basis",0,0,0,0,0,0,0,1,0,0,0
SID_309,9096,The IDG Board and Management is committed to ethical business practices with zero tolerance to fraud and misconduct and has adopted a Fraud Risk Management Policy (the Fraud Risk policy),0,0,0,0,0,0,0,0,0,0,0
SID_309,9097,The Fraud Risk policy establishes managements framework of internal controls for the prevention and detection of fraud and misconduct as well as protocols for conducting internal investigations,0,0,0,0,0,0,0,0,0,0,0
SID_309,9098,"The fraud risk management program, as defined in this policy, is administered by the Compliance Officer and the Chief Executive Officer who reports the matters to the Board",0,0,0,0,0,0,0,0,0,0,0
SID_309,9099,"The policy mandate specifically includes the following: Business process control activities including the use of authority and responsibility limits and process/criteria to select vendors and contractors, as well as human resource procedures such as employee background investigations, training, employee surveys, and exit interviews",0,0,0,0,0,0,0,1,0,0,0
SID_309,9100,"Physical access control activities address admittance to the Companys facilities and right to use of assets, such as inventory and construction sites",0,0,0,0,0,0,0,0,0,0,0
SID_309,9101,Logical access control activities address access rights to sensitive information,0,0,0,0,0,0,0,0,0,0,0
SID_309,9102,"Transaction control activities address procurement procedures, managerial approval limits and requirements and segregation of duties",0,0,0,0,0,0,0,0,0,0,0
SID_309,9103,Promotion of a speak up culture and provision of multiple channels to report all incidents of fraud and misconduct,0,0,0,0,0,0,0,0,0,0,0
SID_309,9104,"Procedures to be followed by the Compliance Officer and legal counsel after a misconduct is reported including adequate investigation measures, escalation to management and the Board and reporting to the regulatory authorities and law enforcement, as necessary",0,0,0,0,0,0,0,0,1,0,0
SID_309,9105,"In addition, the Company has a health and safety policy, general HR policies and employee training which aim to provide a secure workplace environment",0,0,0,0,0,0,0,1,0,0,0
SID_309,9106,"In addition, IDG construction sites are regularly",0,0,0,0,0,0,0,1,0,0,0
SID_309,9107,"inspected by the Ministry of Labour to enforce safety, health and labour code regulations",0,0,0,0,0,0,0,1,0,0,0
SID_309,9108,"Combined these policies provide an environment where the risk of exploitation, including forced labour and child labour, is minimized",0,0,0,0,0,0,0,0,0,0,0
SID_309,9109,"The Fraud Risk policy provides multiple avenues to the employees to report wrongdoings, unethical behaviours or unsafe environment, including direct supervisors, HR, Compliance Officer, CEO and the Board",0,0,0,0,0,0,0,1,0,0,0
SID_309,9110,These policies can be leveraged and adapted in future if an issue were to arise related to forced labour or child labour and incorporate practices that ensure compliance with non use of forced labour and child labour practices in production and the supply chain,0,0,0,0,0,0,0,0,0,0,0
SID_309,9111,Due Diligence Processes IDGs due diligence processes differ between its subcontractors and suppliers given the differences in purchasing scope and applicability of certain legal and procurement activities,0,0,0,0,0,0,0,0,0,0,0
SID_309,9112,IDG engages with multiple subcontractors for construction activities at the Sona and Santiago project sites,0,0,0,0,0,1,0,0,0,0,0
SID_309,9113,These subcontractors are selected after a thorough due diligence process ensuring their HR policies are compliant with the laws and regulations defined by the Ministry of Labour in the Republic of Panama,0,0,0,0,0,0,0,1,0,0,0
SID_309,9114,"The due diligence process includes review of subcontractors legal documents, good standing, review of their hiring and HR policies and compliance to Panamanian labour laws relating to employment contracts, minimum wage laws, working hours, occupational safety, accident prevention and active business license",0,0,0,0,0,0,0,1,0,0,0
SID_309,9115,Each site has an inspector hired by IDG to inspect the documents of each staff hired by the subcontractor to work at the site including valid social security and an active contract with the subcontractor,0,0,0,0,0,0,0,1,0,0,0
SID_309,9116,These inspections are done on daily basis and a weekly meeting is held with the subcontractor to review any irregularities and ensure compliance with Industrial Safety and Occupational Health reporting to the Ministry of Labour,0,0,0,0,0,0,0,1,0,0,0
SID_309,9117,"In addition, government agencies have authority to inspect construction projects to ensure compliance with local laws, regulations, and standards",0,0,0,0,0,0,0,0,0,0,0
SID_309,9118,"These inspections cover various aspects such as safety, environmental impact, labor conditions, and building codes, and are aleatory",0,0,0,0,0,0,0,0,0,0,0
SID_309,9119,"IDG hires suppliers for construction materials after a due diligence process including multiple bids, review of their legal documents, good standing, financial position and their social and corporate responsibility policy for each bidder",0,0,0,0,0,1,0,1,0,0,0
SID_309,9120,IDG ensures it works with companies with strong corporate responsibility and ethical practices,0,0,0,0,0,0,0,0,0,0,0
SID_309,9121,IDG regularly monitors its suppliers with monthly project status meetings,0,0,0,0,0,0,0,1,0,0,0
SID_309,9122,"Any compliance or performance issues are addressed proactively and directly with the supplier and escalated to management and Board, as necessary",0,0,0,0,0,0,0,0,0,0,0
SID_309,9123,"In the future, the Company will develop new standard contractual language requiring suppliers where feasible to attest to compliance with certain standards, including the requirement that suppliers either meet or exceed the labour standards as reflected in applicable laws in the Republic of Panama",0,0,0,0,0,0,0,1,0,0,0
SID_309,9124,"In addition, the Company will formalize the processes to monitor its suppliers throughout the contractual term",0,0,0,0,0,0,0,1,0,0,0
SID_309,9125,Remediation Measures (including Remediation of Loss of Income) IDG has not identified any instances of forced labour or child labour in its supply chains and therefore the question of remediation is not applicable,0,0,0,0,0,0,1,0,0,0,0
SID_309,9126,Training IDG provides health and safety training to all new hires as part of onboarding at the time of hiring,0,0,0,0,0,0,0,0,0,0,0
SID_309,9127,Additional training is provided if the employees job changes or additional work responsibilities are assigned,0,0,0,0,0,0,0,0,0,0,0
SID_309,9128,This training is repeated by each employee every quarter,0,0,0,0,0,0,0,0,0,0,0
SID_309,9129,"In addition, the employee receives technical skills training covering quality control, construction techniques and best practices based on the job responsibilities",0,0,0,0,0,0,0,0,0,0,0
SID_309,9130,"Going forward, IDG will enhance the training programs to include materials on human rights, ethical labour practices, modern slavery and importance to eliminating child labour and forced labour in efforts to empower employees with the knowledge to identify, prevent, and address instances of forced labor and child labor within their operations and supply chains",0,0,0,0,0,0,0,1,0,0,0
SID_309,9131,"Assessing Effectiveness To assess the effectiveness of the foregoing measures, IDG will implement measures including, but is not limited to, periodic reviews of its corporate policies to determine whether updates are warranted, and working with suppliers to measure the effectiveness of their actions to address forced labour and child labour",0,0,0,0,0,0,0,0,0,1,0
SID_309,9132,"Workplace, Health and Safety Activities IDG will continue to track workplace incidents and review all inspection reports, investigating each report to ascertain any relevance to forced labor or child labor",0,0,0,0,0,0,0,0,0,1,0
SID_309,9133,"IDG maintains a zero-tolerance policy towards workplace harassment, ensuring all reported incidents are promptly conveyed to the executive management and Board, as necessary, along with a corrective action plan for timely resolution",0,0,0,0,0,0,0,0,0,0,0
SID_309,9134,Supplier Activities IDG has identified the need to understand their key suppliers better,0,0,0,0,0,0,0,0,0,0,0
SID_309,9135,This may include further collaboration on where suppliers source their materials from as part of the supplier due diligence process and if suppliers have identified any forced labour or child labour within their company activities currently or in the past,0,0,0,0,0,0,0,1,0,0,0
SID_309,9136,Steps Taken to Prevent & Reduce Risk of Child or Forced Labour IDG is currently exploring potential approaches and will look to select the most applicable avenue that is applicable to IDGs business eco-system to prevent forced labour and/or child labour at the companys operating sites,0,0,0,0,0,0,0,1,0,0,0
SID_309,9137,"Some of these approaches may include: Mapping supply chains and regular supplier audits and reassessments Supplier questionnaires during selection process to assess supplier hiring and procurement policies and code of conduct to be adhered to by the supplier Anti-forced labour and/or child labour contractual clauses Anti-forced labour and/or child labour standards, codes of conduct and/or compliance checklists for employees, subcontractors and suppliers Assessment of risks of forced labour and/or child labour in the organizations activities and supply chains including continuous reporting to the Board Enacting measures to remediate the income loss of forced labour and/or child labour Training and awareness materials to employees and subcontractors Procedures to track performance",0,0,0,0,0,0,0,1,0,0,0
SID_309,9138,Concluding statement on Identifying Forced Labour and Child Labour Risks IDG acknowledges that no industry can be assumed to be entirely free of forced labour and child labour risks and is aware of the need to identify risks in its supply chain,0,0,0,0,0,0,0,0,0,0,0
SID_309,9139,IDG has not done a comprehensive internal assessment to identify the categories of goods that it procures from foreign jurisdictions through its suppliers with known or suspected forced or child labour violations,0,0,0,0,0,0,0,1,0,0,0
SID_309,9140,IDG is currently working on this assessment and concurrently in the process of maturing its Fraud Risk policy and procurement due diligence procedures to address evolving risks and incorporate best practices,0,0,0,0,0,0,0,0,0,0,0
SID_309,9141,"As part of this work, IDG will develop a risk assessment framework to be used to review IDGs supply chains and identify any areas that may carry increased risks",0,0,0,0,0,0,0,1,0,0,0
SID_309,9142,This exercise will be completed and will be addressed in IDGs next disclosure,0,0,0,0,0,0,0,0,0,0,0
SID_309,9143,"Statement of Approval: This statement was approved for publication by the Chief Executive Officer of IDG on May 30, 2024",0,0,0,0,0,0,0,0,0,0,0
SID_309,9144,"Attestation: In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for the entity or entities listed above",0,0,0,0,0,0,0,0,0,0,0
SID_309,9145,"Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above",0,0,0,0,0,0,0,0,0,0,0
SID_309,9146,Full name: Thomas Wenz Title: Chief Executive Officer,0,1,0,0,0,0,0,0,0,0,0
SID_309,9147,Date: May 31st 2024,0,0,0,0,0,0,0,0,0,0,0
SID_309,9148,Signature: _____________________,0,0,0,0,0,0,0,0,0,0,0
SID_309,9149,I have the authority to bind IDG,0,1,0,0,0,0,0,0,0,0,0
SID_311,9150,"Fighting Against Forced Labour and Child Labour in Supply Chains Act Reporting Part 1 Identifying Information Name of Government Institution: Canadian Museum of Nature Financial Reporting Year: April 1, 2023 March 31, 2024 This is not a revised report",0,0,0,0,0,0,0,0,0,0,0
SID_311,9151,This is a report produced by a federal Crown corporation,0,0,0,1,0,0,0,0,0,0,0
SID_311,9152,"The Canadian Museum of Nature (CMN) is a Crown Corporation located in the National Capital Region with 2 facilities: The Victoria Memorial Museum Building (VMMB) in Ottawa, ON and the Natural Heritage Campus (NHC) in Gatineau, QC",0,0,0,0,1,1,0,0,0,0,0
SID_311,9153,"First opened in 1912, CMN became a Crown corporation on July 1, 1990, through the Museums Act",0,0,0,1,0,0,0,0,0,0,0
SID_311,9154,CMN is named in Part I of Schedule III to the Financial Administration Act and reports to Parliament through the Minister of Canadian Heritage,0,0,0,1,0,0,0,0,0,0,0
SID_311,9155,"The sectors, or industries in which CMN operates in are",0,0,0,0,1,0,0,0,0,0,0
SID_311,9156,Information and cultural industries,0,0,0,0,1,0,0,0,0,0,0
SID_311,9157,Real estate and rental and leasing (rentals of facilities),0,0,0,0,1,0,0,0,0,0,0
SID_311,9158,"Professional, scientific and technical services",0,0,0,0,1,0,0,0,0,0,0
SID_311,9159,Educational services,0,0,0,0,1,0,0,0,0,0,0
SID_311,9160,"Arts, entertainment and recreation",0,0,0,0,1,0,0,0,0,0,0
SID_311,9161,"Part 2 Report Contents 2.1 Information on the government institutions structure, activities and supply chains CMNs purpose is to increase throughout Canada and internationally, interest in, knowledge of and appreciation and respect for the natural world by establishing, maintaining and developing for research and posterity a collection of natural history objects, with special but not exclusive reference to Canada, and by demonstrating the natural world, the knowledge derived from it and the understanding it represents",0,0,0,0,1,0,0,0,0,0,0
SID_311,9162,"CMNs activities include purchasing goods in Canada and outside Canada, as well as distributing goods in Canada",0,0,0,0,1,1,0,0,0,0,0
SID_311,9163,"These activities are described under CMNs capacity and powers in the Museum Act including, but not limited to",0,0,0,0,1,0,0,0,0,0,0
SID_311,9164,"Sell, exchange, give away, or otherwise dispose of natural history objects and other museum material, other than primary type specimens, in its collection and use any revenue obtained therefrom to further its collection",0,0,0,0,1,0,0,0,0,0,0
SID_311,9165,"Acquire property by gift, bequest or otherwise and hold in trust or otherwise expend, invest, administer and dispose of that property",0,0,0,0,1,0,0,0,0,0,0
SID_311,9166,"Develop, operate and maintain branches or exhibition centres",0,0,0,0,1,0,0,0,0,0,0
SID_311,9167,"Operate restaurants, lounges, parking facilities, shops and other facilities for the use of the public",0,0,0,0,1,0,0,0,0,0,0
SID_311,9168,Lease or otherwise make available any of its facilities to other persons,0,0,0,0,1,0,0,0,0,0,0
SID_311,9169,"Charge for goods, services and admission and use the revenue obtained therefrom for its own purposes",0,0,0,0,1,0,0,0,0,0,0
SID_311,9170,"Information on the steps taken to prevent and reduce the risk that forced labour or child labour is used at any step of the production of goods produced, purchased or distributed by the government institution",0,0,0,0,0,0,0,0,0,0,0
SID_311,9171,"In the previous financial year CMN has engaged with experts and other stakeholders on the issue of addressing forced labour and/or child labour but given the recent coming- into-force date of the Supply Chains Act, no measures or action plans to prevent or reduce the risk that forced labour or child labour is used in any step of the production of goods, purchased or distributed in its activities and supply chains have been implemented at this time",0,0,0,0,0,0,0,1,0,0,0
SID_311,9172,Information on the policies and due diligence processes in relation to forced labour and child labour,0,0,0,0,0,0,0,0,0,0,0
SID_311,9173,"CMN does not currently have policies and due diligence processes in place related to forced labour and/or child labour, but it is working on embedding responsible business conduct into policies and management systems throughout the upcoming fiscal year",0,0,0,0,0,0,0,1,0,0,0
SID_311,9174,Information on the parts of its activities and supply chains that carry a risk of forced labour or child labour being used and the steps taken to assess and manage that risk,0,0,0,0,0,0,0,0,0,0,0
SID_311,9175,"CMN has started to initiate the process of identifying areas that carry a risk of forced labour or child labour being used in its activities and supply chains, but there are still gaps in its assessments",0,0,0,0,0,0,0,1,0,0,0
SID_311,9176,"CMN has leveraged the Risk Analysis of Human Trafficking, Forced Labour, and Child Labour in Public Works and Government Services Canadas (PWGSCs) Procurement Supply Chains report to determine what level of risk may be present in its own supply chains",0,0,0,0,0,0,0,1,0,0,0
SID_311,9177,"Based on the Goods and Service Identification Number (GSIN) codes that represent the highest risk of Human trafficking, forced labour, and child labour in PWGSCs supply chains, CMN has made a preliminary assumption that its supply chain may also presents similar risks with respect to the following product categories: office supplies & devices, lighting fixtures & lamps, textiles, leather, furs, apparel, shoe findings, tents & flags, clothing, individual equipment & insignia, alarm",0,0,0,0,0,1,1,0,0,0,0
SID_311,9178,"signal & security detection systems, electrical & electronic equipment components, and service & trade equipment",0,0,0,0,0,1,1,0,0,0,0
SID_311,9179,"Since CMNs supply chain may differ from PWGSCs, more analysis required to uncover and validate all risks",0,0,0,0,0,0,0,0,0,0,0
SID_311,9180,"CMN has identified potential forced labour or child labour risks in its activities and supply chains related to any of the following sectors and industries, however it has not yet completed an in-depth assessment",0,0,0,0,0,0,1,1,0,0,0
SID_311,9181,Transportation and warehousing,0,0,0,0,0,0,1,0,0,0,0
SID_311,9182,Risks identified in supply chain in industries and sectors CMN does business in are preliminary and only potential and have been identified only through research and discussion,0,0,0,0,0,0,0,1,0,0,0
SID_311,9183,"No specific or concrete risks have yet been identified, however CMN is aware that risks may exists and plans to examine further in the coming year",0,0,0,0,0,0,1,0,0,0,0
SID_311,9184,Information on any measures taken to remediate any forced labour or child labour,0,0,0,0,0,0,0,0,0,0,0
SID_311,9185,CMN has not yet taken any measures to remediate any forced labour or child labour in its activities and supply chains since a complete risk identification process has not yet been completed,0,0,0,0,0,0,0,1,1,0,0
SID_311,9186,Information on any measures taken to remediate the loss of income to the most vulnerable families that results from any measure taken to eliminate the use of forced labour or child labour in the institutions activities and supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_311,9187,CMN has not identified any loss of income to vulnerable families resulting from measures taken to eliminate the use of forced labour or child labour in our activities and has therefore not taken any measures to remediate the loss of income to the most vulnerable families that results from any measure taken to eliminate the use of forced or child labour in its activities and supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_311,9188,Information on the training provided to employees on forced labour and child labour,0,0,0,0,0,0,0,0,0,0,0
SID_311,9189,CMN does not currently provide training to employees on forced labour and/or child labour but plans to develop and implement training in the near future for employees making contracting and or purchasing decisions,0,0,0,0,0,0,0,1,0,0,0
SID_311,9190,Information on how the government institution assesses its effectiveness in ensuring that forced labour and child labour are not being used in its activities and supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_311,9191,"No, CMN does not currently have policies and procedures in place to assess the effectiveness of ensuring that forced labour and child labour are not being used in its activities and supply chains",0,0,0,0,0,0,0,0,0,1,0
SID_315,9321,"Mennonite Central Committee (MCC) British Columbia Modern Slavery Report For the year ended March 31, 2024 Introduction: Canadas Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Act) requires entities meeting certain criteria to submit a report detailing the steps taken to prevent and reduce the risk of forced labour and child labour, both in operations and supply chains, on an annual basis",0,0,0,0,0,0,0,0,0,0,0
SID_315,9322,"An entity with business activities that include producing, selling, or distributing goods in Canada or elsewhere; importing goods into Canada; or controlling an entity engaged in producing, selling, distributing or importing goods is a reporting entity under the Act if it either",0,0,0,0,0,0,0,0,0,0,0
SID_315,9323,is listed on a stock exchange in Canada; or,0,0,0,0,0,0,0,0,0,0,0
SID_315,9324,"has a place of business in Canada, does business in Canada or has assets in Canada and that, based on its consolidated nancial statements, meets at least two of the following conditions for at least one of its two most recent nancial years",0,0,0,0,0,0,0,0,0,0,0
SID_315,9325,"it has at least $20 million in assets, ii",0,0,0,0,0,0,0,0,0,0,0
SID_315,9326,"it has generated at least $40 million in revenue, and iii",0,0,0,0,0,0,0,0,0,0,0
SID_315,9327,it employs an average of at least 250 employees,0,0,0,0,0,0,0,0,0,0,0
SID_315,9328,"Mennonite Central Committee (MCC) British Columbia (MCC BC), BN 107690927, is a reporting entity under the Act, meeting all the criteria listed under (b)",0,0,0,0,0,0,0,0,0,0,0
SID_315,9329,"This report covers the scal year April 1, 2023 to March 31, 2024",0,0,0,0,0,0,0,0,0,0,0
SID_315,9330,"MCC BCs registered address is 201 33933 Gladys Avenue, Abbotsford, B.C., V2S 2E8",0,0,0,1,0,0,0,0,0,0,0
SID_315,9331,"Structure, activities and supply chains: MCC BC was established as a not-for-prot society in 1968 and is incorporated under the Societies Act (British Columbia)",0,0,0,1,0,0,0,0,0,0,0
SID_315,9332,"It is a registered charity that strives to share Gods love and compassion for all through relief, development and peacebuilding",0,0,0,1,0,0,0,0,0,0,0
SID_315,9333,"Through local programs, MCC BC works to meet needs of those within its provincial boundaries",0,0,0,0,1,0,0,0,0,0,0
SID_315,9334,"MCC BC also supports the broader MCC networks work in over 40 countries around the world by raising funds, mobilizing materials and providing international workers",0,0,0,0,1,0,0,0,0,0,0
SID_315,9335,"In addition to charitable programming and fundraising, MCC BC operates social enterprises including nine thrift shops throughout B.C., a fairtrade retail store operating as Ten Thousand Villages, and a caf operating as Common Place Caf",0,0,0,1,1,0,0,0,0,0,0
SID_315,9336,"MCC BCs suppliers used in charitable programming, fundraising, and thrift shop and caf operations are primarily based in Canada and subject to provincial employment standards",0,0,0,0,0,1,0,0,0,0,0
SID_315,9337,"Ten Thousand Villages sells fairtrade goods from various countries around the globe, primarily purchased through fairtrade and small business wholesalers in Canada and the United States",0,0,0,0,1,1,0,0,0,0,0
SID_315,9338,Care is taken to ensure that the values and ethical standards of Ten Thousand Villages suppliers are in line with MCC BCs values and ethical standards,0,0,0,0,0,0,0,0,0,0,0
SID_315,9339,Policies and due diligence processes: MCC BC has policies in place that help identify and address risks related to forced labour and child labour,0,0,0,0,0,0,0,1,0,0,0
SID_315,9340,These policies include: Personal Conduct Policy Abuse Prevention Policy Workplace Harassment Policy Anti-Fraud and Corruption Policy Grievance Policy These policies are included in MCC BCs sta handbook and are provided to sta as part of the onboarding process,0,0,0,0,0,0,0,1,0,0,0
SID_315,9341,"As prescribed by policy, criminal record checks are obtained for all sta when hired, and every three years thereafter",0,0,0,0,0,0,0,0,0,0,0
SID_315,9342,"For sta working with children or vulnerable adults, an additional level of screening is required",0,0,0,0,0,0,0,0,0,0,0
SID_315,9343,"Agreements with third party partner organizations contain wording consistent with MCC BC standards, practices, and expectations, particularly with regards to safeguarding",0,0,0,0,0,0,0,0,0,0,0
SID_315,9344,"On an annual basis, MCC BC senior management conducts an organization wide risk assessment, including ranking of risks and reporting on the previous years risks to the Board of Directors",0,0,0,0,0,0,0,1,0,0,0
SID_315,9345,Forced labour and child labour risks: MCC BC acknowledges that no activities are immune from the risk of using forced labour and child labour,0,0,0,0,0,0,0,0,0,0,0
SID_315,9346,"However, due to the nature of its activities in charitable fundraising and programming, MCC BC has not identied any signicant risks of modern slavery with regards to domestic operations and suppliers",0,0,0,0,0,0,1,0,0,0,0
SID_315,9347,The highest risk area for MCC BC lies within the supply chain of Ten Thousand Villages,0,0,0,0,0,0,1,0,0,0,0
SID_315,9348,"Coee, chocolate, and other agricultural goods supplied for resale at Ten Thousand Villages present a higher risk due to the agriculture industry being more vulnerable to forced and child labour",0,0,0,0,0,1,1,0,0,0,0
SID_315,9349,"Other items sold by Ten Thousand Villages are produced internationally, such as textiles, clothing, and household goods",0,0,0,0,0,1,0,0,0,0,0
SID_315,9350,These also represent a higher risk as some regions in which they are produced are not subject to regulations or the enforcement of regulations in line with those in Canada,0,0,0,0,0,0,1,0,0,0,0
SID_315,9351,"Ten Thousand Villages mission is to create opportunities for artisans in developing countries to earn income by bringing their products and stories to North American markets through long-term, fair trading relationships",0,0,0,0,0,0,0,1,0,0,0
SID_315,9352,Ten Thousand Villages sources goods from wholesalers who are aligned with its mission and are committed to ethical practices and appropriate screening of suppliers,0,0,0,0,0,1,0,0,0,0,0
SID_315,9353,The majority of suppliers are members of the Fair Trade Federation,0,0,0,0,0,1,0,0,0,0,0
SID_315,9354,A small number of products sold by Ten Thousand Villages are produced within Canada,0,0,0,0,0,1,0,0,0,0,0
SID_315,9355,Remediation measures: MCC BC has not identied any forced labour or child labour in its activities and supply chains and therefore no remediation measures have been taken,0,0,0,0,0,0,1,0,1,0,0
SID_315,9356,MCC BC has not identied any loss of income to vulnerable families as a result of its eorts to prevent and reduce the risk of forced labour and child labour therefore no measures have been taken in this area,0,0,0,0,0,0,0,0,0,0,0
SID_315,9357,Training: MCC BC sta are required to complete safeguarding training which includes training on child protection,0,0,0,0,0,0,0,1,0,0,0
SID_315,9358,No training specic to forced labour and child labour was provided during the year,0,0,0,0,0,0,0,1,0,0,0
SID_315,9359,Assessing eectiveness: MCC BC has a Grievance Policy with a clearly dened procedure for reporting grievances,0,0,0,0,0,0,0,1,0,0,0
SID_315,9360,The Abuse Prevention Policy outlines steps for reporting instances of child abuse,0,0,0,0,0,0,0,1,0,0,0
SID_315,9361,"All reported grievances, allegations of abuse, and incident reports are tracked",0,0,0,0,0,0,0,0,0,1,0
SID_315,9362,The tracking of reported instances provides a measure to assess MCC BCs eectiveness in ensuring that forced labour and child labour are not being used in its operations,0,0,0,0,0,0,0,0,0,1,0
SID_315,9363,"Attestation: In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for the entity listed above",0,0,0,0,0,0,0,0,0,0,0
SID_315,9364,"Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above",0,0,0,0,0,0,0,0,0,0,0
SID_315,9365,I have the authority to bind MCC BC,0,0,0,0,0,0,0,0,0,0,0
SID_315,9366,"_______________________________________ _______________________________________ Peter Wolfe, Board Chair",0,0,0,0,0,0,0,0,0,0,0
SID_315,9367,Date,0,1,0,0,0,0,0,0,0,0,0
SID_315,9368,"May 27, 2024",0,0,0,0,0,0,0,0,0,0,0
SID_316,9369,STARTECH.COM LTD,0,0,0,0,0,0,0,0,0,0,0
SID_316,9370,FY 2023 Bill S-211 Report on Forced Labour and Child Labour in Supply Chains,0,0,0,0,0,0,0,0,0,0,0
SID_316,9371,"May 15, 2024",0,0,0,0,0,0,0,0,0,0,0
SID_316,9372,Introduction,0,0,0,0,0,0,0,0,0,0,0
SID_316,9373,StarTech.com is committed to acting ethically in all our business dealings,0,0,0,0,0,0,0,0,0,0,0
SID_316,9374,We accept and agree with the role that global companies must play in combatting forced labour and child labour in their supply chains and are working to enhance and improve our efforts in this area,0,0,0,0,0,0,0,0,0,0,0
SID_316,9375,We view this report and the efforts described herein as part of our wider framework of corporate social responsibility (referred to as CSR),0,0,0,0,0,0,0,0,0,0,0
SID_316,9376,"We believe that StarTech.coms continuing efforts to be a socially responsible company are not only expected by our customers, our partners and our employees, but that they underpin the competitive abilities and ultimately, of the long-term sustainability of the company",0,0,0,0,0,0,0,0,0,0,0
SID_316,9377,"This report has been prepared in compliance with Canadas new Fighting Against Forced Labour and Child Labor in Supply Chains Act (the Act) by StarTech.com Ltd (StarTech.com or the Company or our or we) for the scal year ended November 30, 2023 (the Reporting Period)",0,0,0,0,0,0,0,0,0,0,0
SID_316,9378,"The statement applies to StarTech.com Ltd, a company incorporated pursuant to the laws of the Province of Ontario, Canada",0,0,0,1,0,0,0,0,0,0,0
SID_316,9379,"StarTech.com Limited, a subsidiary of the Company, also reports under the UK Modern Slavery Act 2015",0,0,0,1,0,0,0,0,0,0,0
SID_316,9380,Steps to prevent and reduce risks of forced labour and child labour,0,0,0,0,0,0,0,0,0,0,0
SID_316,9381,"In general terms, StarTech.com took the following steps during the Reporting Period to prevent and reduce the risk of forced labour or child labour in the business and supply chains",0,0,0,0,0,0,0,1,0,0,0
SID_316,9382,On-site vendor audits engaging with a 3rd party auditor or StarTech.com employees for compliance with various laws and the expectations set out in the Vendor Questionnaire and CSR Vendor Audit Checklist,0,0,0,0,0,0,0,1,0,0,0
SID_316,9383,"Annual declaration from vendors for support and respect of internationally proclaimed human rights, elimination of all forms of forced and compulsory labour, and abolition of child labour",0,0,0,0,0,0,0,1,0,0,0
SID_316,9384,"Continued development of CSR policies and procedures, including training material on human trafficking including forced and child labour for employees to complete through online modules beginning in 2024",0,0,0,0,0,0,0,1,0,0,0
SID_316,9385,The details of the above actions are outlined in this Report,0,0,0,0,0,0,0,0,0,0,0
SID_316,9386,"Entitys structure, activities, and supply chains",0,0,0,0,0,0,0,0,0,0,0
SID_316,9387,"StarTech.com creates, distributes, and sells a portfolio of IT accessories",0,0,0,0,1,0,0,0,0,0,0
SID_316,9388,"The Companys purpose is to empower its customers, IT professionals, and business users to improve performance by easily creating the critical connection between them and their productivity tools",0,0,0,0,1,0,0,0,0,0,0
SID_316,9389,"The Companys strategic intent is to make its products easy to identify, nd, obtain, and use, when and where they are needed, which it reects in its proprietary expression Hard to Find Made Easy",0,0,0,0,1,0,0,0,0,0,0
SID_316,9390,"Currently, StarTech.com has approximately 4,300 active SKUs which are in turn divided into product categories including the following: cables and network cables; computer cards and adapters; data",0,0,0,0,1,0,0,0,0,0,0
SID_316,9391,"storage; digital display cables; display and video adapters; display mounts; docking stations and hubs; keyboard/video/mouse switches; multiport adapters, networking cables and networking; racks and enclosures; video display connectivity; and workstation accessories",0,0,0,0,1,0,0,0,0,0,0
SID_316,9392,StarTech.com partners with approximately 121 suppliers in eight countries to manufacture its products,0,0,0,0,0,1,0,0,0,0,0
SID_316,9393,"StarTech.com engages with these suppliers in an Original Design Manufacturer (ODM) arrangement, where the supplier designs and manufactures the product and then applies the StarTech.com brand",0,0,0,0,0,0,0,0,0,0,0
SID_316,9394,"StarTech.com Ltd is headquartered in London, Ontario, Canada and is the parent company to a number of global subsidiaries",0,0,0,1,0,0,0,0,0,0,0
SID_316,9395,"StarTech.com Ltd is responsible for identifying, sourcing, and maintaining relationships with vendors and suppliers, and does so pursuant to inter-company arrangements with its global subsidiaries",0,0,0,0,0,0,0,0,0,0,0
SID_316,9396,The description of actions throughout the report taken by StarTech.com apply to the Company as well as its global subsidiaries,0,0,0,0,0,0,0,0,0,0,0
SID_316,9397,Policies and due diligence processes in relation to forced labour and child labour,0,0,0,0,0,0,0,0,0,0,0
SID_316,9398,Policy StarTech.com communicates its expectation that its supply chain is free of forced labour and child labour to new suppliers and to suppliers with which it has ongoing relationships,0,0,0,0,0,0,0,1,0,0,0
SID_316,9399,"In addition, as part of its annual Vendor Questionnaire process and CSR Vendor Audit Checklist, StarTech.com requests its suppliers make the following declarations regarding human rights and labour practices",0,0,0,0,0,0,0,1,0,0,0
SID_316,9400,Vendor agrees to support and respect the protection of internationally proclaimed human rights; and make sure they are not complicit in human rights abuses,0,0,0,0,0,0,0,0,0,0,0
SID_316,9401,Vendor agrees to uphold the elimination of all forms of forced and compulsory labour; the effective abolition of child labour; and the elimination of discrimination in respect of employment and occupation,0,0,0,0,0,0,0,1,0,0,0
SID_316,9402,StarTech.com expects its suppliers to cascade these requirements to their respective supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_316,9403,"If a supplier does not make the declarations noted above in its annual Vendor Questionnaire, StarTech.coms Supply Chain organization will follow up with the supplier to determine the reasons why the declaration was or cannot be made",0,0,0,0,0,0,0,1,0,0,0
SID_316,9404,The risk assessment and management processes below detail the consequences of a non-declaration by a supplier,0,0,0,0,0,0,0,0,0,0,0
SID_316,9405,"StarTech.com continues to work at formalizing its expectations with respect to ethical sourcing, forced labour and/or child labour, human trafficking and human rights into formal policies",0,0,0,0,0,0,0,1,0,0,0
SID_316,9406,StarTech.com is working on a new employee Code of Conduct and a Modern Slavery and Human Trafficking Policy,0,0,0,0,0,0,0,1,0,0,0
SID_316,9407,"In the future, StarTech.com intends to record its supplier expectations in a formal Supplier Code of Conduct",0,0,0,0,0,0,0,1,0,0,0
SID_316,9408,StarTech.com has base policies which all new employees are expected to review and sign upon entering the company,0,0,0,0,0,0,0,0,0,0,0
SID_316,9409,"In addition, it has initiated a global ethics hotline for employees to report unethical behaviors",0,0,0,0,0,0,0,1,0,0,0
SID_316,9410,Employees are encouraged to report potential compliance violations to their,0,0,0,0,0,0,0,1,0,0,0
SID_316,9411,"supervisor or through the hotline, which would include reporting on any potential violations related to forced labour and/or child labour",0,0,0,0,0,0,0,1,0,0,0
SID_316,9412,"Due Diligence In scal year 2023, StarTech.com employed or engaged a dedicated IRCA certied Social Systems Auditor, a Project Manager and a third-party auditor, all located geographically close to its supply chain, to perform audits for compliance with various laws and the expectations set out in the Vendor Questionnaire and CSR Vendor Audit Checklist",0,0,0,0,0,0,0,1,0,0,0
SID_316,9413,"These audits can include either (a) in person inspections of supplier facilities where StarTech.com products are manufactured; and/or (b) completion of the Vendor Questionnaire coupled with proof of CSR certication from a reputable third-party certication body (certications from bodies such as BSCI, SMETA, SA8000 or EICC are accepted)",0,0,0,0,0,0,0,1,0,0,0
SID_316,9414,"The results of those audits are communicated to senior employees in StarTech.coms Supply Chain organization and if appropriate, elevated to senior management in accordance with StarTech.coms risk escalation policies and procedures",0,0,0,0,0,0,0,1,0,0,0
SID_316,9415,"In addition to the regular audit process above, StarTech.com has developed specic procedures related to vendor sourcing and selection including a CSR impact and risk assessment sheet that ranks suppliers against high-risk vs low-risk regions",0,0,0,0,0,0,0,0,0,0,0
SID_316,9416,"As part of StarTech.coms vendor sourcing process, all potential new vendors must answer a vendor self-audit questionnaire, which includes CSR questions on forced labour and/or child labour",0,0,0,0,0,0,0,1,0,0,0
SID_316,9417,The vendor sourcing process is only completed when all concerns on CSR which may be identied in the self-audit have been addressed to StarTech.coms satisfaction,0,0,0,0,0,0,0,1,0,0,0
SID_316,9418,The new vendor selection process also includes a manufacturing audit and a CSR audit by either a StarTech.com employee or representative or a third-party auditor,0,0,0,0,0,0,0,1,0,0,0
SID_316,9419,The vendor must have a passing score to be approved and added to StarTech.coms vendor database,0,0,0,0,0,0,0,0,0,0,0
SID_316,9420,"During the scal year ended November 30, 2023, StarTech.com performed the following activities in regard to its due diligence and management of forced labour and/or child labour risks and CSR program",0,0,0,0,0,0,0,1,0,0,0
SID_316,9421,The SA8000 Certied Social System Auditor and Senior Supplier Quality Engineer (SQE) visited 7 new vendors,0,0,0,0,0,0,0,0,0,1,0
SID_316,9422,Fourteen third party vendor audits were completed at the request of StarTech.com; and,0,0,0,0,0,0,0,0,0,1,0
SID_316,9423,"% of the annual Vendor Questionnaire and corporate social responsibility (CSR) Vendor Audit Checklist were completed with existing vendors, with additional questions posed to various vendors throughout the year",0,0,0,0,0,0,0,0,0,1,0
SID_316,9424,"As at year end 2023, 33% of StarTech.coms current vendor base has provided CSR certications from third-party certication bodies",0,0,0,0,0,0,0,0,0,1,0
SID_316,9425,Parts of the business and supply chains that carry a risk of forced labour or child labour being used and steps it has taken to assess and manage risk,0,0,0,0,0,0,0,0,0,0,0
SID_316,9426,StarTech.com has identied that the risk of forced labour or child labour taking place occurs in its supply chain,0,0,0,0,0,0,1,0,0,0,0
SID_316,9427,"As StarTech.com does not manufacture products directly and substantially all its global employees are located in Canada, the United States of America, the United Kingdom and the",0,0,0,0,1,0,0,0,0,0,0
SID_316,9428,"European Union, StarTech.com does not believe that it has any risk of forced labour and/or child labour in any other area of its business",0,0,0,0,0,0,1,0,0,0,0
SID_316,9429,"Following each audit or annual Vendor Questionnaire cycle, results are analyzed, and an impact assessment is prepared by StarTech.coms Supply Chain organization",0,0,0,0,0,0,0,0,0,1,0
SID_316,9430,"Depending on the impact, improvement plans will be launched with the supplier containing specic deliverables and timelines to complete the improvement activities",0,0,0,0,0,0,0,0,0,0,0
SID_316,9431,StarTech.com reserves the right to terminate a supplier relationship if its audits show the supplier has failed to adhere to the expectations set out in the Vendor Questionnaire or if the audit reveals slavery or human trafficking activities within a supplier relationship,0,0,0,0,0,0,0,0,1,0,0
SID_316,9432,"Measures taken to remediate any forced labour or child labour, and measures taken to remediate the loss of income to the most vulnerable families that result from any measure taken to eliminate the use of forced labour or child labour in activities and supply chains",0,0,0,0,0,0,0,0,0,0,0
SID_316,9433,"StarTech.com did not identify any instances of forced or child labour in scal 2023; as a result, no remediation measures were required",0,0,0,0,0,0,1,0,1,0,0
SID_269,9434,Training provided to employees on forced labour and child labour,0,0,0,0,0,0,0,0,0,0,0
SID_316,9435,StarTech.com has secured online learning resources for employees,0,0,0,0,0,0,0,0,0,0,0
SID_316,9436,"In addition, employees involved in supply chain activities have access and are encouraged to access widely available resources (such as those available through the Stronger Together initiative) to advance their understanding of forced labour and/or child labour issues, risks, and their role in combatting them",0,0,0,0,0,0,0,1,0,0,0
SID_316,9437,"All new employees working from the London, Ontario head office are required to take training on the Ontario Human Rights Code which also increases their understanding of foundational principles underpinning the Fighting Against Forced Labour and Child Labour in Supply Chains Act and UK Modern Slavery Act",0,0,0,1,0,0,0,1,0,0,0
SID_316,9438,"Beginning in scal 2024, StarTech.com will provide training on human trafficking including forced and child labour to employees in designated departments",0,0,0,0,0,0,0,1,0,0,0
SID_316,9439,How StarTech.com assesses the effectiveness in ensuring that forced labour and child labour are not being used in its business and supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_316,9440,StarTech.com assesses whether its expectations are being followed by suppliers through the annual Vendor Questionnaire and/or CSR Vendor Audit Checklist and audit process,0,0,0,0,0,0,0,0,0,0,0
SID_316,9441,StarTech.com continues to develop both a road map and internal measures to more formally assess the effectiveness of its current procedures to combat forced labour and/or child labour,0,0,0,0,0,0,0,0,0,1,0
SID_316,9442,It is intended that the analysis of StarTech.coms internal processes and incentive structures will also mature over time to ensure that overall business performance indicators do not unintentionally create or increase forced labour or child labour risks within StarTech.coms supply chain,0,0,0,0,0,0,0,0,0,0,0
SID_316,9443,StarTech.com strives for continuous improvement,0,0,0,0,0,0,0,0,0,0,0
SID_316,9444,"StarTech.coms goals include aiming for zero (0) incidences of forced and child labour and actively tracking, deploying an updated Code of Conduct and training to formalize its expectations with respect to ethical sourcing, forced labour and/or child labour, human trafficking and human rights, and striving for the EcoVadis Commitment badge",0,0,0,0,0,0,0,1,0,0,0
SID_316,9445,"As we learn from our processes, policies, and stakeholders, we will update and improve annually, becoming more informed on how we can better protect those in our supply chain",0,0,0,0,0,0,0,0,0,0,0
SID_316,9446,Approval and Attestation,0,0,0,0,0,0,0,0,0,0,0
SID_316,9447,"In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for the entities listed above",0,0,0,0,0,0,0,0,0,0,0
SID_316,9448,"Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above",0,0,0,0,0,0,0,0,0,0,0
SID_316,9449,I have the authority to bind StarTech.com Ltd,0,0,0,0,0,0,0,0,0,0,0
SID_316,9450,"On behalf of StarTech.com Ltd, this report was approved by",0,0,0,0,0,0,0,0,0,0,0
SID_316,9451,Paul J,0,1,0,0,0,0,0,0,0,0,0
SID_316,9452,Seed Name: Paul J,0,1,0,0,0,0,0,0,0,0,0
SID_316,9453,"Seed Title: Executive Chairman and Director May 15, 2024",0,1,0,0,0,0,0,0,0,0,0
SID_322,9594,"2023 Annual Report Fighting against forced labour and child labour in supply chains act, s.c",0,0,0,0,0,0,0,0,0,0,0
SID_322,9595,"2023, c.9",0,0,0,0,0,0,0,0,0,0,0
SID_322,9596,"Introduction REPORTING ENTITY DETAILS Reporting entitys legal name: ENMAX Corporation Financial reporting year: January 1- to December 31, 2023 Joint report for: ENMAX Corporation, ENMAX Power Corporation and ENMAX Energy Corporation Sector/industry: Utilities Location: Headquarters in Calgary, Alberta ENMAX Corporation is a corporation that has a place of business and assets in Canada, imports goods into Canada, and controls entities (ENMAX Power Corporation and ENMAX Energy Corporation) that import goods into Canada",0,0,0,1,0,0,0,0,0,0,0
SID_322,9597,"Hereinafter ENMAX Corporation, ENMAX Power Corporation and ENMAX Energy Corporation will collectively be referred as ENMAX",0,0,0,1,0,0,0,0,0,0,0
SID_322,9598,BUSINESS NUMBERS ENMAX Corporation: 883105132 ENMAX Power Corporation: 872884895 ENMAX Energy Corporation: 870024940 Report Summary STEPS TAKEN TO PREVENT AND REDUCE RISKS OF FORCED LABOUR AND CHILD LABOUR IN ENMAXS SUPPLY CHAIN: Conducted an internal supplier mapping exercise to identify risks of forced labour and/or child labour in activities and supply chains,0,0,0,1,0,0,0,1,0,0,0
SID_322,9599,Initiated an assessment of tier one suppliers with high potential for risks of forced and child labour through a Modern Slavery Questionnaire,0,0,0,0,0,0,0,1,0,0,0
SID_322,9600,"Conducted Modern Slavery training for all employees in supply chain management department, which was facilitated by the Chartered Institute of Procurement & Supply (CIPS)",0,0,0,0,0,0,0,1,0,0,0
SID_322,9601,"Ensured that ENMAX executives and leaders are aware of the obligations, enforcement, and offences of the Fighting Against Forced Labour and Child Labour in Supply Chains Act, S.C",0,0,0,0,0,0,0,1,0,0,0
SID_322,9602,"2023, c",0,0,0,0,0,0,0,1,0,0,0
SID_322,9603,(Act) and support the development of a risk management program,0,0,0,0,0,0,0,1,0,0,0
SID_322,9604,"Worked cross functionally with various internal stakeholders and functions, including Legal, Compliance, ESG, and Supply Chain",0,0,0,0,0,0,0,1,0,0,0
SID_322,9605,Engaged with external consultants for their expertise and advise on identifying and addressing the issues of forced labour and/or child labour in our supply chain,0,0,0,0,0,0,0,1,0,0,0
SID_322,9606,Initiated the update of various due diligence policies to include more scrutiny of human rights,0,0,0,0,0,0,0,1,0,0,0
SID_322,9607,"ENMAX Structure & Activities COMPANY OVERVIEW The ENMAX group of companies is a leading provider of electricity services, products, and solutions",0,0,0,0,1,0,0,0,0,0,0
SID_322,9608,"We are headquartered in Calgary, Alberta with operations across Alberta and Maine",0,0,0,1,0,0,0,0,0,0,0
SID_322,9609,"Through our subsidiaries, ENMAX Power Corporation and Versant Power, we own and operate transmission and distribution utilities to safely and reliably deliver electricity to customers in Calgary and northern and eastern Maine",0,0,0,1,1,0,0,0,0,0,0
SID_322,9610,"Through ENMAX Energy Corporation, ENMAX owns and operates power generation facilities and offers a range of innovative electricity and natural gas products and services to residential, commercial, and industrial customers across Alberta",0,0,0,1,1,0,0,0,0,0,0
SID_322,9611,"LAND ACKNOWLEDGEMENT In the spirit of reconciliation, we respectfully acknowledge that we live and work on the traditional lands of Indigenous Peoples",0,0,0,0,0,0,0,0,0,0,0
SID_322,9612,"ENMAX headquarters is in Calgary, in southern Alberta, the traditional territory of the Blackfoot Confederacy, comprised of the Siksika, Kainai, Piikani, and Amskapi Piikuni Nations; the Tsuutina Nation; and the yrheNakoda Nations of Chiniki, Bearspaw, and Goodstoney; and home to citizens of the Mtis Nation, as well as many diverse Indigenous people who have made the city their home",0,0,0,1,0,0,0,0,0,0,0
SID_322,9613,"In Maine, we operate on the traditional lands of the Wabanaki people",0,0,0,0,1,0,0,0,0,0,0
SID_322,9614,"We are committed to strengthening relationships with Indigenous Nations and peoples in all communities where we operate, through respect and collaboration",0,0,0,0,0,0,0,0,0,0,0
SID_322,9615,"OUR SUBSIDIARIES ENMAX Power Corporation is our regulated Alberta-based wires business through which we own, operate, and maintain the transmission and distribution system in and around Calgary",0,0,0,0,1,0,0,0,0,0,0
SID_322,9616,"This system serves approximately 570,000 customers across 1,089 square kilometres",0,0,0,0,1,0,0,0,0,0,0
SID_322,9617,We are investing now and into the future over $300 million annually in system growth and maintenance to ensure we can reliably meet our customers energy needs,0,0,0,0,1,0,0,0,0,0,0
SID_322,9618,Our ENMAX Power business is subject to the oversight of the Alberta Utilities Commission,0,0,0,0,0,0,0,0,0,0,0
SID_322,9619,"ENMAX Energy Corporation is our Alberta-based competitive generation and retail business, providing electricity, natural gas, and customer care services to approximately 747,000 customers throughout the province",0,0,0,0,1,0,0,0,0,0,0
SID_322,9620,"Our Customer Care Centre, located in Calgary, serves our customers, and works on behalf of The City of Calgary under a service contract to bill for The Citys residential water, sanitary and storm sewer, solid waste disposal and recycling services",0,0,0,0,1,0,0,0,0,0,0
SID_322,9621,"Our ENMAX Energy business maintains a 1,522 MW generation portfolio, made up of 86 per cent natural gas and 14 per cent wind",0,0,0,0,1,0,0,0,0,0,0
SID_322,9622,"Versant Power is our electric transmission and distribution utility which owns, operates, and maintains an electrical system in northern and eastern Maine",0,0,0,0,1,0,0,0,0,0,0
SID_322,9623,It is fully regulated by the Maine Public Utilities Commission and the Federal Energy Regulatory Commission,0,0,0,0,0,0,0,0,0,0,0
SID_322,9624,"ENMAXs supply chains, policies and due diligence, supplier risk management, and workforce empowerment practices apply to all the Canadian subsidiaries",0,0,0,0,0,0,0,1,0,0,0
SID_322,9625,OUR PURPOSE Lighting the way to a brighter energy future,0,0,0,0,0,0,0,0,0,0,0
SID_322,9626,"OUR VALUES Safety: No one gets hurt Accountability: Own it Agility: Adapt and act Integrity: Do the right thing with courage and conviction Service: Act with others in mind Innovation: Create possibilities Teamwork: Better and stronger together OUR GOVERNANCE APPROACH At ENMAX, our Board of Directors (the Board or Directors) and Executive Team (the Executive) are committed to high standards of corporate governance",0,0,0,0,0,0,0,0,0,0,0
SID_322,9627,"We believe that sound corporate governance practices contribute to shareholder value, trust, and confidence in ENMAX",0,0,0,0,0,0,0,0,0,0,0
SID_322,9628,ENMAXs governance practices are key to how we make decisions,0,0,0,0,0,0,0,0,0,0,0
SID_322,9629,"Our governance framework guides how we assign accountability, delegate authority, and determine resources to support and enhance our decision-making process",0,0,0,0,0,0,0,0,0,0,0
SID_322,9630,"The Board is committed to maintaining high standards of corporate governance, and regularly reviews and updates its principles and policies to meet evolving best practices, expectations, and legal requirements",0,0,0,0,0,0,0,0,0,0,0
SID_322,9631,We have several committees with oversight of ENMAXs ESG targets and practices including,0,0,0,0,0,0,0,0,0,0,0
SID_322,9632,Audit Committee,0,0,0,0,0,0,0,0,0,0,0
SID_322,9633,Corporate Governance Committee,0,0,0,0,0,0,0,0,0,0,0
SID_322,9634,Human Resources Committee,0,0,0,0,0,0,0,0,0,0,0
SID_322,9635,"Safety, Environment and Sustainability Committee",0,0,0,0,0,0,0,0,0,0,0
SID_322,9636,"OUR SHAREHOLDER RELATIONSHIP ENMAX Corporation is a private corporation, incorporated under the Alberta Business Corporations Act, and our sole shareholder is The City of Calgary",0,0,0,1,0,0,0,0,0,0,0
SID_322,9637,Calgarys City Council acts in the capacity of the Shareholder on behalf of Calgarians,0,0,0,0,0,0,0,0,0,0,0
SID_322,9638,"OUR WORKFORCE In 2023, ENMAXs total Canadian workforce consists of 1,681 employees",0,0,0,1,0,0,0,0,0,0,0
SID_322,9639,We welcome the contributions of organized labour and respect the right of our employees to associate,0,0,0,0,0,0,0,1,0,0,0
SID_322,9640,More than 60 per cent of our workforce is represented by union members of the International Brotherhood of Electrical Workers (IBEW) Local 254 and the Canadian Union of Public Employees (CUPE) Local 38,0,0,0,0,0,0,0,1,0,0,0
SID_322,9641,"ENMAX Supply Chain To support ENMAXs corporate, capital, and operational core functions, our supply chain department operates in a centralized manner, procuring materials and services for all parts of our business, including the regulated power business, competitive generation, retail services, and corporate functions in Canada",0,0,0,0,0,1,0,0,0,0,0
SID_322,9642,"ENMAXs supply chains consist of local, national, and international third-party goods and services providers who support our business",0,0,0,0,0,1,0,0,0,0,0
SID_322,9643,"MAJOR PURCHASE CATEGORIES Electrical Instrumentation Material and Equipment Field Services Information Technology Construction Services Power Generation Material and Services Professional Services Direct Trades Vehicle Fleet Fuels, Chemicals and Gases SUPPLIER LANDSCAPE In 2023, ENMAX purchased products and services from approximately 1,200 tier one (direct) suppliers",0,0,0,0,0,1,0,0,0,0,0
SID_322,9644,"% of the tier one suppliers are based in North America, with Canada accounting for nearly 85%, USA nearly 15%, and less than 1% from international sources outside North America",0,0,0,0,0,1,0,0,0,0,0
SID_322,9645,"ENMAX tier one suppliers that are not located in Canada and USA have headquarters in Ireland, Australia, UK, Switzerland, Singapore, and Austria",0,0,0,0,0,1,0,0,0,0,0
SID_322,9646,The suppliers outside Canada and USA primarily provide IT software and technology solutions to ENMAX,0,0,0,0,0,1,0,0,0,0,0
SID_322,9647,"ENMAX Policies & Due Diligence WHY IT MATTERS TO ENMAX We are guided by strong principles of accountability, transparency and ethics in our decision making and behaviour",0,0,0,0,0,0,0,0,0,0,0
SID_322,9648,"We expect all directors, officers, and employees of ENMAX to act with honesty, integrity and impartiality",0,0,0,0,0,0,0,0,0,0,0
SID_322,9649,"This allows us to earn and maintain the trust of our Shareholder, employees, customers, and the communities in which we operate",0,0,0,0,0,0,0,0,0,0,0
SID_322,9650,PRINCIPLES OF BUSINESS ETHICS POLICY This policy establishes the appropriate and expected behaviour of ENMAX Personnel for maintaining ENMAXs reputation for honesty and integrity,0,0,0,0,0,0,0,0,0,0,0
SID_322,9651,"One of the key principles of the policy states compliance with all applicable laws, which would include the Act",0,0,0,0,0,0,0,1,0,0,0
SID_322,9652,"The policy applies to ENMAX Corporation and its subsidiaries, ENMAX Power Corporation and ENMAX Energy Corporation",0,0,0,1,0,0,0,0,0,0,0
SID_322,9653,Our Board reviews and approves the policy at least once every three years and works closely with the Executive to promote a strong governance culture that influences ENMAX at every level,0,0,0,0,0,0,0,0,0,0,0
SID_322,9654,"Annually, all employees acknowledge their responsibility to perform their duties at ENMAX in accordance with the Principles of Business Ethics Policy",0,0,0,0,0,0,0,0,0,0,0
SID_322,9655,SAFE AND RESPECTFUL WORKPLACE STANDARD This is a Standard developed by ENMAX with the purpose of promoting a safe and respectful workplace and preventing inappropriate behaviour and references the Alberta Human Rights Act,0,0,0,0,0,0,0,0,0,0,0
SID_322,9656,"Although not specific to our supply chain, these Standards cultivate a culture of a safe and respectful workplace",0,0,0,0,0,0,0,0,0,0,0
SID_322,9657,"ENMAX ESG FRAMEWORK ENMAX is advancing progress in energy affordability, reducing emissions, adapting to a changing climate, while enabling a diverse and inclusive team and ensuring continued access to safe and reliable energy",0,0,0,0,0,0,0,0,0,0,0
SID_322,9658,"In 2023, ENMAX advanced progress against our ESG framework, which includes climate change and the energy transition, energy affordability, diversity, inclusion and belonging, and governance",0,0,0,0,0,0,0,0,0,0,0
SID_322,9659,"ENMAX Supplier Risk Management SUPPLIER MAPPING In alignment with the United Nations Guiding Principles on Business and Human Rights (UNGP), we acknowledge the potential risks of forced labour and child labour within our supply chain",0,0,0,0,0,0,0,0,0,0,0
SID_322,9660,"Our understanding, consistent with the UNGP, suggests that our primary exposure to forced labour typically lies beyond the first tier of our supply chain",0,0,0,0,0,0,1,0,0,0,0
SID_322,9661,"In 2023, ENMAX examined its suppliers to identify the potential risks of modern slavery, including forced labour and child labour, in the supply chain",0,0,0,0,0,0,0,1,0,0,0
SID_322,9662,We performed a preliminary review of our tier one suppliers for risks of modern slavery based on the following key criteria,0,0,0,0,0,0,0,1,0,0,0
SID_322,9663,Country of location: modern slavery has a higher prevalence in certain jurisdictions or locations,0,0,0,0,0,0,0,1,0,0,0
SID_322,9664,Industry sector: certain industries present higher risks of modern slavery compared to others; and,0,0,0,0,0,0,0,1,0,0,0
SID_322,9665,Product/commodity: some products or commodities are deemed higher risk in terms of modern slavery,0,0,0,0,0,0,0,1,0,0,0
SID_322,9666,"The highest risk classification is where a supplier satisfies all three criteria, followed by medium risk where two criteria are satisfied, and low risk is where the supplier satisfies only one criterion",0,0,0,0,0,0,0,0,0,0,0
SID_322,9667,"Based on this initial mapping, none of ENMAXs tier one suppliers is classified as high-risk",0,0,0,0,0,0,1,0,0,0,0
SID_322,9668,ENMAX acknowledges that the exposure to forced and child labour risk may lie further down in the supply chain beyond tier one rather than arising directly from our business activities and will assess the risks by expanding the supplier mapping over time,0,0,0,0,0,0,1,1,0,0,0
SID_322,9669,SUPPLIER ASSESSMENT ENMAX requested suppliers who have been identified with a potential risk based on product/commodity or country of location to complete a Modern Slavery Supplier Questionnaire,0,0,0,0,0,0,0,1,0,0,0
SID_322,9670,The responses provided pursuant to the questionnaire will allow ENMAX to learn more about the steps they take within their operations to detect and address modern slavery risks,0,0,0,0,0,0,0,1,0,0,0
SID_322,9671,This questionnaire was sent to these suppliers in January 2024 and responses will be analyzed in 2024,0,0,0,0,0,0,0,1,0,0,0
SID_322,9672,REPORTING CONCERNS ENMAX has a confidential ethics hotline where individuals can anonymously express concerns about inappropriate business conduct through a confidential third-party service,0,0,0,0,0,0,0,1,0,0,0
SID_322,9673,Submissions to the ethics hotline are reported to the ENMAX Corporate Governance Committee,0,0,0,0,0,0,0,0,0,0,0
SID_322,9674,All reports are investigated with oversight of legal counsel,0,0,0,0,0,0,0,0,1,0,0
SID_322,9675,"In accordance with our Principles of Business Ethics Policy, the Directors and officers of ENMAX are also required to disclose conflicts of interest and declare outside business interests on an annual basis",0,0,0,0,0,0,0,0,0,0,0
SID_322,9676,This helps ensure Directors exercise independent judgment when considering transactions and agreements,0,0,0,0,0,0,0,0,0,0,0
SID_322,9677,"Where there is a conflict, the Board ensures the applicable Director does not participate in discussions or vote on matters",0,0,0,0,0,0,0,0,0,0,0
SID_322,9678,This helps ensure Directors exercise independent judgment when considering transactions and agreements,0,0,0,0,0,0,0,1,0,0,0
SID_322,9679,"MEASURES TAKEN Through the preliminary supplier risk mapping and assessment, ENMAX did not find any instances of forced and/or child labour in the supply chain; therefore, we did not need to deploy any remediation measures",0,0,0,0,0,0,1,0,1,0,0
SID_322,9680,"As ENMAXs supplier risk assessment process evolves, we will establish the necessary remediation procedures",0,0,0,0,0,0,0,0,0,0,0
SID_322,9681,"2024 INITIATIVES IN PROGRESS We are creating a roadmap to enhance the integration of sustainable procurement considerations and opportunities, including child, and forced labour, into our supply chain management strategies and initiatives",0,0,0,0,0,0,0,1,0,0,0
SID_322,9682,"As part of ongoing efforts to create and maintain an ethical supply chain, our 2024 plans include the development of the following elements: Implementation of the Supplier Code of Conduct; Sourcing a supplier onboarding portal; Creating supplier assessment questions for Request for Proposals and onboarding; and Enhancing existing policies and due diligence procedures",0,0,0,0,0,0,0,1,0,0,0
SID_322,9683,"ENMAX Workforce Empowerment MODERN SLAVERY TRAINING In 2023, ENMAX invested in educating and training all supply chain management employees to recognize the risks of modern slavery in our business and supply chains",0,0,0,0,0,0,0,1,0,0,0
SID_322,9684,"The Modern Slavery Training course was facilitated by CIPS, which is a global membership organisation and a leading professional education and training provider in supply chain",0,0,0,0,0,0,0,1,0,0,0
SID_322,9685,The training consisted of two four-hour online sessions and included: Identifying the importance of modern slavery within our supply chain; Recognizing the different types of modern slavery (including child and forced labour) and signs that it may be present; Overview of mapping the supply chain and explore ways of creating transparency; and Introducing tools and techniques to help prevent modern slavery,0,0,0,0,0,0,0,1,0,0,0
SID_322,9686,"This training was provided to all Supply Chain Management employees, which consisted of 17 members including individual contributors, team leads, managers, Director, and VP",0,0,0,0,0,0,0,1,0,0,0
SID_322,9687,"ENMAXs Executive has also been briefed, through a memo and presentation, about the obligations, enforcement, and offences of the Act and the Board of Directors has also been informed",0,0,0,0,0,0,0,1,0,0,0
SID_322,9688,"POLICIES AND DUE DILIGENCE TRAINING ENMAX requires all employees, including our contractors as assigned, to complete an online training on the Principles of Business Ethics Policy, Safe and Respectful Workplace, and Code of Conduct",0,0,0,0,0,0,0,1,0,0,0
SID_322,9689,The training is developed and delivered internally at ENMAX and is mandatory for all employees to complete annually,0,0,0,0,0,0,0,1,0,0,0
SID_322,9690,PROGRAM EFFECTIVENESS ENMAXs supply chain risk management program is still being developed,0,0,0,0,0,0,0,0,0,0,0
SID_322,9691,We are in the process of mapping our current state while concurrently developing interim and long-term plans with measures to assess the effectiveness of this program,0,0,0,0,0,0,0,0,0,0,0
SID_322,9692,"In 2023, members from the Legal, Compliance, ESG, and Supply Chain teams began collaborating to develop due diligence practices at ENMAX",0,0,0,0,0,0,0,0,0,0,0
SID_322,9693,"In 2024, ENMAX will establish a committee, which will include various members from across the organization, to continue to review, develop, and implement the supply chain risk management program",0,0,0,0,0,0,0,1,0,1,0
SID_322,9694,"The plan for the next few years includes establishing risk identification and mitigation processes, along with implementing relevant metrics to evaluate progress",0,0,0,0,0,0,0,0,0,0,0
SID_322,9695,ENMAX aims to work towards reducing the risk of forced and/or child labour that may exist in our supply chains as part of our future vision,0,0,0,0,0,0,0,0,0,0,0
SID_322,9696,"EXPERT CONSULTATION ENMAX acknowledges the complexity of addressing forced labour and child labour, and therefore, we actively engage with consultants, industry peers, and various stakeholders to identify best practices",0,0,0,0,0,0,0,1,0,0,0
SID_322,9697,This collaborative approach allows us to stay updated on the latest developments in ethical sourcing and improves our efforts in reducing the risk of modern slavery in our supply chains,0,0,0,0,0,0,0,1,0,0,0
SID_322,9698,"In 2023, ENMAX retained the services of third-party consultants to advise on the requirements and implications of the Act, assist us with reporting, support the development and implementation of the supply chain risk management program and develop our supplier assessment questionnaire",0,0,0,0,0,0,0,1,0,0,0
SID_322,9699,"Attestation In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for the entity or entities listed above",0,0,0,0,0,0,0,0,0,0,0
SID_322,9700,"Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above",0,0,0,0,0,0,0,0,0,0,0
SID_322,9701,"Full name: Charles Ruigrok Title: Chairman of the Board of Directors Date: May 23, 2024",0,1,0,0,0,0,0,0,0,0,0
SID_322,9702,I have the authority to bind ENMAX Corporation Signature,0,1,0,0,0,0,0,0,0,0,0
SID_349,11682,Darling International Canada Inc Report on Forced Labour in Canadian Supply Chains 2023 Fiscal Year,0,0,0,0,0,0,0,0,0,0,0
SID_349,11683,Report on Forced Labour in Canadian Supply Chains Darling International Canada Inc (DICI),0,0,0,0,0,0,0,0,0,0,0
SID_349,11684,Business Information,0,0,0,0,0,0,0,0,0,0,0
SID_349,11685,Legal Name: Darling International Canada Inc (DICI),0,0,0,0,0,0,0,0,0,0,0
SID_349,11686,"Financial Reporting Year: January 1, 2023 to December 30th, 2023",0,0,0,0,0,0,0,0,0,0,0
SID_349,11687,Is this a revised report? No,0,0,0,0,0,0,0,0,0,0,0
SID_349,11688,Business Number: 841520836,0,0,0,0,0,0,0,0,0,0,0
SID_349,11689,Is the entity subject to reporting requirements under supply chain legislation in another jurisdiction? No,0,0,0,0,0,0,0,0,0,0,0
SID_349,11690,Act Categorization,0,0,0,0,0,0,0,0,0,0,0
SID_349,11691,DICI has a Canadian business presence and assets in Canada,0,0,0,0,1,0,0,0,0,0,0
SID_349,11692,DICI meets the size-related thresholds to include,0,0,0,0,0,0,0,0,0,0,0
SID_349,11693,At least $20 million in assets ii,0,0,0,0,0,0,0,0,0,0,0
SID_349,11694,Generated at least $30 million in revenue for fiscal year 2023 iii,0,0,0,0,0,0,0,0,0,0,0
SID_349,11695,Employs more than 250 people on average in the last two years,0,0,0,0,0,0,0,0,0,0,0
SID_349,11696,DICI operates in the following industries,0,0,0,0,1,0,0,0,0,0,0
SID_349,11697,"Agriculture, forestry, fishing and hunting",0,0,0,0,1,0,0,0,0,0,0
SID_349,11698,Manufacturing,0,0,0,0,1,0,0,0,0,0,0
SID_349,11699,"DICI is headquartered in Ontario, Canada",0,0,0,1,0,0,0,0,0,0,0
SID_349,11700,"Our Structure Darling International Canada Inc (DICI) is a Canadian corporation incorporated in the province of New Brunswick on September 2nd, 2013",0,0,0,1,0,0,0,0,0,0,0
SID_349,11701,"DICI is headquartered in Ontario, Canada with six plant locations to include three in Ontario and one plant in Manitoba, Quebec, and Nova Scotia",0,0,0,1,1,0,0,0,0,0,0
SID_349,11702,"In total, DICI has approximately 550 employees",0,0,0,1,0,0,0,0,0,0,0
SID_349,11703,"DICI is a subsidiary of Darling Ingredients, a publicly traded company headquartered in Irving, Texas, listed on the NYSE under the ticker symbol DAR",0,0,0,1,0,0,0,0,0,0,0
SID_349,11704,"Including DICI, Darling Ingredients has more than 15,000 employees at over 260 facilities, spread across 15 countries, on five continents",0,0,0,1,1,0,0,0,0,0,0
SID_349,11705,"At Darling Ingredients, Environmental Social Governance (ESG) is a critical element of the way we do business",0,0,0,0,0,0,0,0,0,0,0
SID_349,11706,Our more than 150 product innovations speak for themselves,0,0,0,0,0,0,0,0,0,0,0
SID_349,11707,We are always looking for ways to maximize resources and move the world to a more circular economy,0,0,0,0,0,0,0,0,0,0,0
SID_349,11708,"With our unique skillset and scale, we make industries less wasteful and more sustainable",0,0,0,0,0,0,0,0,0,0,0
SID_349,11709,"Oversight of our ESG strategy starts at the highest level of the organization, with our Board of Directors; specifically, with the Board ESG Committee, chaired by Michael Rescoe",0,0,0,0,0,0,0,0,0,0,0
SID_349,11710,"The Board ESG Committee meets frequently with management to receive updates on strategy, programs and initiatives",0,0,0,0,0,0,0,0,0,0,0
SID_349,11711,This responsibility then filters from executive management to each and every Darling Ingredients employee across the globe because it is the responsibility of every employee to deliver continued innovation and meaningful progress against our targets and commitments,0,0,0,0,0,0,0,0,0,0,0
SID_349,11712,"Our 2022 Sustainability Report describes our environmental, social and governance (ESG) programs, progress and performance, and demonstrates how, at Darling Ingredients, sustainability is central to the way we operate",0,0,0,0,0,0,0,0,0,0,0
SID_349,11713,"In our report, we disclose information in line with the Global Reporting Initiative (GRI), Sustainability Accounting Standards Board (SASB), the United Nations Sustainable Development Goals (UN SDGs) and the Task Force on Climate-related Financial Disclosures (TCFD)",0,0,0,0,0,0,0,0,0,0,0
SID_349,11714,"The report includes information from our fiscal year, January 2 December 31, 2022, unless otherwise noted",0,0,0,0,0,0,0,0,0,0,0
SID_349,11715,Our 2023 Sustainability report will be published on our Darling website in July 2024,0,0,0,0,0,0,0,0,0,0,0
SID_349,11716,Darling Ingredients has been recognized as a leader in the ESG world by the following publications,0,0,0,0,0,0,0,0,0,0,0
SID_349,11717,Listed among Americas Most Responsible Companies by Newsweek,0,0,0,0,0,0,0,0,0,0,0
SID_349,11718,Recognized as an ESG Industry Top Rated Company by Sustainalytics,0,0,0,0,0,0,0,0,0,0,0
SID_349,11719,Ranked among the 100 Best ESG Companies by Investors Business Daily,0,0,0,0,0,0,0,0,0,0,0
SID_349,11720,"Winner of Innovation in Food and Beverage for 2023 from D Magazine Our Activities At Darling Ingredients, we transform the unused into the invaluable",0,0,0,0,0,0,0,0,0,0,0
SID_349,11721,"Over the last 140 years, Darling Ingredients has become an important platform for extracting the hidden potential of our worlds resources and turning them into sustainable solutions for everyday life",0,0,0,0,1,0,0,0,0,0,0
SID_349,11722,We take what would typically be considered refuse and efficiently transform it into invaluable ingredients and in-demand products,0,0,0,0,1,0,0,0,0,0,0
SID_349,11723,"In the meat production process, only about 50% of an animal makes it to a dinner plate",0,0,0,0,0,0,0,0,0,0,0
SID_349,11724,"Keeping the other 50% out of landfills and incinerators requires innovative, sustainable solutions",0,0,0,0,0,0,0,0,0,0,0
SID_349,11725,"Darling Ingredients creates those solutions, repurposing approximately 15% of the worlds meat industry waste into value added products, including essential products like green energy, renewable diesel, collagen, fertilizer, animal proteins and meals, and pet food ingredients",0,0,0,0,1,0,0,0,0,0,0
SID_349,11726,Our innovative services not only prevent waste from entering landfills but also reduce waste-related emissions around the world,0,0,0,0,1,0,0,0,0,0,0
SID_349,11727,"In Canada, DICI collects animal by-products and used cooking oil from the food processing and restaurant industry",0,0,0,0,1,0,0,0,0,0,0
SID_349,11728,The animal byproducts are transported back to our facilities and rendered into fats and proteins,0,0,0,0,1,0,0,0,0,0,0
SID_349,11729,"The fat is sold as ingredients into the renewable diesel market, agricultural feed or pet food market",0,0,0,0,1,0,0,0,0,0,0
SID_349,11730,"The proteins are sold as ingredients into the agricultural feed, pet food or the fertilizer industry",0,0,0,0,1,0,0,0,0,0,0
SID_349,11731,"The finished products are shipped to customers within Canada and the United States by rail, an outside trucking company or our own truck fleet",0,0,0,0,1,1,0,0,0,0,0
SID_349,11732,Our Supply Chain DICIs raw material supply chain is primarily made up of the agricultural and restaurant industries,0,0,0,0,0,1,0,0,0,0,0
SID_349,11733,"Within the agricultural and restaurant industries, animal by-products and used cooking oil are the main input of raw material that produces our finished products",0,0,0,0,0,1,0,0,0,0,0
SID_349,11734,"For non-raw material suppliers, utility companies supply DICI with natural gas and hydro for our production process",0,0,0,0,0,1,0,0,0,0,0
SID_349,11735,"In addition, DICI uses rail lines and trucking companies to transport our products to their end users",0,0,0,0,0,1,0,0,0,0,0
SID_349,11736,"Our Policies At Darling Ingredients, we conduct business ethically and in compliance with all applicable laws and regulations",0,0,0,0,0,0,0,0,0,0,0
SID_349,11737,"Our policies are based on our core values of integrity, transparency and entrepreneurship",0,0,0,0,0,0,0,0,0,0,0
SID_349,11738,We do not not condone or tolerate efforts or activities to achieve results through illegal or unethical dealings,0,0,0,0,0,0,0,0,0,0,0
SID_349,11739,"These policies extend to our operations throughout the world, including our operations in Canada",0,0,0,0,1,0,0,0,0,0,0
SID_349,11740,"We have developed the Darling Code of Conduct, Supplier Code of Conduct and Human Rights Policy to set clear expectations for our employees and suppliers",0,0,0,0,0,0,0,0,0,0,0
SID_349,11741,These documents outline the way we conduct business and are intended to embed responsible business conduct into our everyday actions,0,0,0,0,0,0,0,0,0,0,0
SID_349,11742,"Specifically in our Supplier Code of Conduct and Human Rights Policy, we prohibit the use of child labour, forced or compulsory labour, and human trafficking",0,0,0,0,0,0,0,1,0,0,0
SID_349,11743,We will not do business with individuals or companies that abuse the rights of others,0,0,0,0,0,0,0,0,0,0,0
SID_349,11744,"In addition, we have developed a Speak Up Line and Retaliation Policy",0,0,0,0,0,0,0,1,0,0,0
SID_349,11745,This allows and encourages employees and third parties to report any violations to our Code of Conduct or policies in an anonymous and confidential manner,0,0,0,0,0,0,0,1,0,0,0
SID_349,11746,"Darling Ingredients, including DICI, uses an independent third party to operate a hotline that is available 24/7, 365 days a year with translation and interpretation support",0,0,0,0,0,0,0,1,0,0,0
SID_349,11747,"Due Diligence Our supply chain in Canada includes more than 11,000 raw material suppliers, which is comprised of food processing facilities, livestock farms, grocery and retail stores",0,0,0,0,0,1,0,0,0,0,0
SID_349,11748,"Within this mix, 95% of our raw material comes from our top 200 suppliers",0,0,0,0,0,1,0,0,0,0,0
SID_349,11749,"This year, 70% of our raw material supply chain have attested to follow our Supplier Code of Conduct and Human Rights Policy or provided their own equivalent policy",0,0,0,0,0,0,0,0,0,1,0
SID_349,11750,"Over the next two years, DICI plans to work with the remaining top suppliers on signature authorization of our Supplier Code of Conduct",0,0,0,0,0,0,0,1,0,0,0
SID_349,11751,"Forced and Child Labour Risk To evaluate the risk in the DICI supply chain, we mapped and grouped our supply chain by major classification",0,0,0,0,0,0,0,1,0,0,0
SID_349,11752,"Using these classifications, we evaluated our direct suppliers and the source of their direct supply",0,0,0,0,0,0,0,1,0,0,0
SID_349,11753,"Based on this exercise, we do not see significant risk due to the geographic location (predominantly Canada, almost entirely North America) and the nature of the agricultural industry in which we operate",0,0,0,0,0,0,1,0,0,0,0
SID_349,11754,Darling International Canada Inc Supply Chain Map,0,0,0,0,0,0,0,0,0,0,0
SID_349,11755,"Remediation Measures and Remediation of Loss of Income DICI has not experienced forced or child labour within its activities or supply chain, as such the question of remediation is not applicable",0,0,0,0,0,0,1,0,0,0,0
SID_349,11756,"Training on Forced and Child Labour Annually, Darling Ingredients requires all employees, including DICI employees, to review and complete training on our Darling Code of Conduct",0,0,0,0,0,0,0,1,0,0,0
SID_349,11757,"The Code of Conduct includes a section on human rights, which specifically cites forced and child labour as a prohibited practice",0,0,0,0,0,0,0,1,0,0,0
SID_349,11758,The training is an interactive web-based program,0,0,0,0,0,0,0,1,0,0,0
SID_349,11759,Employees watch videos and read sections of content and answer knowledge testing questions throughout the training,0,0,0,0,0,0,0,1,0,0,0
SID_349,11760,The training is adaptive learning which means employees will continue to test until questions are answered correctly,0,0,0,0,0,0,0,1,0,0,0
SID_349,11761,"Furthermore, at the end of the training all employees attest to follow Darlings Code of Conduct",0,0,0,0,0,0,0,1,0,0,0
SID_349,11762,Assessing effectiveness DICI does not have a formal policy or audit procedure in place to assess the effectiveness of ensuring forced and child labour are not being used in their activities and supply chain,0,0,0,0,0,0,0,1,0,0,0
SID_349,11763,"Through our Supplier Code of Conduct and Human Rights Policy, DICI has engaged with their top suppliers to ensure there is alignment of high ethical standards and being a partner of choice that uphold fundamental human rights, including the prohibition of forced and child labour",0,0,0,0,0,0,0,1,0,0,0
SID_351,11764,Report on Forced and Child Labour in Supply Chains Fiscal Year 2023,0,0,0,0,0,0,0,0,0,0,0
SID_351,11765,"Gillfor Distribution Inc (Gillfor) is committed to building partnerships from coast-to-coast with premier vendors and customers by promoting the highest quality products and providing exceptional service through an honest, engaged and dedicated team",0,0,0,0,0,0,0,0,0,0,0
SID_351,11766,Gillfor is committed to understanding our supply chain and implementing measures to prevent and reduce the risk of forced labour or child labour in its operating activities and in those of its supply chain,0,0,0,0,0,0,0,0,0,0,0
SID_351,11767,Structure/Activities/Supply Chain,0,0,0,0,0,0,0,0,0,0,0
SID_351,11768,Gillfor Distribution Inc is a leading distributor of building products in Canada,0,0,0,0,1,0,0,0,0,0,0
SID_351,11769,Gillfor Distribution is Canadas largest privately held distribution company and is proudly 100% Canadian owned and operated,0,0,0,1,1,0,0,0,0,0,0
SID_351,11770,"With 13 strategically located distribution centers across Canada, Gillfor Distribution is your one stop shop for residential, commercial and industrial building materials from coast to coast",0,0,0,0,1,0,0,0,0,0,0
SID_351,11771,"During the 2023 Fiscal Year, virtually all of Gillfors purchases were made from North American Suppliers",0,0,0,0,0,1,0,0,0,0,0
SID_351,11772,"With approximately 75% of Gillfors business coming from the sale of lumber and other forestry products which is sourced from within Canada and the US, the risk of forced labour or child labour is mitigated",0,0,0,0,0,1,0,0,0,0,0
SID_351,11773,Gillfor does understand that Canadian and US suppliers may source products from other downstream suppliers and we are reviewing best practices to diminish any potential risk from outside sources,0,0,0,0,0,1,0,0,0,0,0
SID_351,11774,Policies and Due Diligence,0,0,0,0,0,0,0,0,0,0,0
SID_351,11775,Gillfor is committed to strengthening and enforcing policies to ensure that we are purchasing from Companies that are committed to reducing or omitting the risk of forced labour and child labour in the supply chain,0,0,0,0,0,0,0,0,0,0,0
SID_351,11776,"As part of Gillfors commitment to fight against forced labour and child labour in supply chains, Gillfor is dedicated to perform employee training to help employees identify and report any suspected instances, more notably on the purchasing side",0,0,0,0,0,0,0,1,0,0,0
SID_351,11777,"We encourage our employees to know the supplier and perform plant tours, to speak up and ask questions",0,0,0,0,0,0,0,1,0,0,0
SID_351,11778,Risk Assessment,0,0,0,0,0,1,0,0,0,0,0
SID_351,11779,Gillfor has long term relationships with many our suppliers,0,0,0,0,0,1,0,0,0,0,0
SID_351,11780,"The risk of forced labour and child labour in the supply chain is minimal due to the location of our suppliers, many of which are public companies",0,0,0,0,0,1,1,0,0,0,0
SID_351,11781,Gillfors global supply chain is limited to countries where protection against breaches of human rights are limited,0,0,0,0,0,0,0,0,0,0,0
SID_351,11782,The nature of Gillfors business is wholesale distribution of lumber and building materials,0,0,0,0,1,0,0,0,0,0,0
SID_351,11783,This is a low sector risk company as the majority of the business is not purchasing manufactured goods,0,0,0,0,0,0,1,0,0,0,0
SID_351,11784,Transaction risks are low as Gillfor is dealing with Canadian and US banks only,0,0,0,0,1,0,1,0,0,0,0
SID_351,11785,The supplier and business partnerships that have been established are long term partnerships and an excellent knowledge of partners operations and policies has been established,0,0,0,0,0,1,0,0,0,0,0
SID_351,11786,Any new relationships we believe would be low risk as proper due diligence is conducted,0,0,0,0,0,0,1,0,0,0,0
SID_351,11787,"In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for the entity listed above",0,0,0,0,0,0,0,0,0,0,0
SID_351,11788,"Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above",0,0,0,0,0,0,0,0,0,0,0
SID_351,11789,______________________,0,0,0,0,0,0,0,0,0,0,0
SID_351,11790,"May 28, 2024 Navjot Dosanjh",0,1,0,0,0,0,0,0,0,0,0
SID_351,11791,Date,0,0,0,0,0,0,0,0,0,0,0
SID_351,11792,President/CEO Gillfor Distribution Inc,0,1,0,0,0,0,0,0,0,0,0
SID_352,11793,Dear Stakeholders,0,0,0,0,0,0,0,0,0,0,0
SID_352,11794,"On May 11, 2023, the Canadian government introduced Bill S-211, Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Act), which came into effect January 1, 2024",0,0,0,0,0,0,0,0,0,0,0
SID_352,11795,The Act imposes an obligation on certain government institutions and private-sector entities to report on the measures taken to prevent and reduce the risk that forced labour or child labour is used by them or in their supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_352,11796,The Act provides for an inspection regime applicable to entities and gives the Minister of Public Safety and Emergency Preparedness (the Minister) the power to require an entity to provide certain information,0,0,0,0,0,0,0,0,0,0,0
SID_352,11797,"Pursuant to the Act, entities must, on or before May 31 of each year, submit a report to the Minister which includes",0,0,0,0,0,0,0,0,0,0,0
SID_352,11798,the steps the entity has taken during its previous financial year to prevent and reduce the risk; that forced labour or child labour is used at any step of the production of goods in Canada or elsewhere by the entity or of goods imported into Canada by the entity,0,0,0,0,0,0,0,0,0,0,0
SID_352,11799,"its structure, activities and supply chains",0,0,0,0,0,0,0,0,0,0,0
SID_352,11800,its policies and due diligence processes in relation to forced labour and child labour,0,0,0,0,0,0,0,0,0,0,0
SID_352,11801,the parts of its business and supply chains that carry a risk of forced labour or child labour being used and the steps it has taken to assess and manage that risk,0,0,0,0,0,0,0,0,0,0,0
SID_352,11802,any measures taken to remediate any forced labour or child labour,0,0,0,0,0,0,0,0,0,0,0
SID_352,11803,any measures taken to remediate the loss of income to the most vulnerable families that results from any measure taken to eliminate the use of forced labour or child labour in its activities and supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_352,11804,the training provided to employees on forced labour and child labour; and,0,0,0,0,0,0,0,0,0,0,0
SID_352,11805,how the entity assesses its effectiveness in ensuring that forced labour and child labour are not being used in its business and supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_352,11806,"PesoRama Inc (PesoRama), together with its wholly-owned subsidiaries, PesoRama Holdings Inc., Canmex Dollar Stores, S.A",0,0,0,1,0,0,0,0,0,0,0
SID_352,11807,"de C.V., Joi Canadian Stores, S.A",0,0,0,1,0,0,0,0,0,0,0
SID_352,11808,"de C.V., PesoRama Stores Services, S.A",0,0,0,1,0,0,0,0,0,0,0
SID_352,11809,"de C.V., and PesoRama Consulting Services, S.A",0,0,0,1,0,0,0,0,0,0,0
SID_352,11810,"de C.V., (altogether, the Company), meet the guidelines of an entity that is required to report under the Act, and is therefore releasing this report as part of meeting these reporting requirements, for the year ended January 31, 2024",0,0,0,1,0,0,0,0,0,0,0
SID_352,11811,"Joi Canadian Stores brand (Joi), a wholly- owned subsidiary of PesoRama, operates discount retail stores in Mexico, offering consumers a high variety of products, providing Mexican shoppers in dense urban areas the same convenience, quality, and consistency as dollar stores in Canada and the United States",0,0,0,1,1,0,0,0,0,0,0
SID_352,11812,"In doing so, the Company utilizes a global supply chain",0,0,0,0,0,0,0,0,0,0,0
SID_352,11813,"The Company is committed to upholding human rights and working conditions across its supply chain, and this includes identifying ways to ensure that forced labour and child labour is not being used",0,0,0,0,0,0,0,0,0,0,0
SID_352,11814,"PesoRama nor its wholly owned subsidiaries own or have financial interest in any manufacturing facility, but the Company works with global suppliers, as well as suppliers within Mexico",0,0,0,0,0,1,0,0,0,0,0
SID_352,11815,"The global economy brings people together from around the world who contribute to the creation of a product, from extracting materials, to processing, production, packaging and transportation to the Companys stores, through to the final sale to its customers",0,0,0,0,0,0,0,0,0,0,0
SID_352,11816,"There is a risk that along the Companys supply chain, forced labour or child labour could be used, whether in the manufacturing facility of one of our suppliers, in the operations of raw material providers to those suppliers, or by logistics companies that are involved in the transport of raw materials or finished goods",0,0,0,0,0,0,1,0,0,0,0
SID_352,11817,All employees of the Company are governed by a code of conduct (the Code of Conduct),0,0,0,0,0,0,0,0,0,0,0
SID_352,11818,"One of the requirements for employment at PesoRama or any of its wholly owned subsidiaries is to sign the Code of Conduct, understanding that any violations of the Code of Conduct can result in discipline or loss of employment",0,0,0,0,0,0,0,1,1,0,0
SID_352,11819,The Code of Conduct states that no minors will work for the Company as well as expressing the compliance with the laws and regulations of Mexico,0,0,0,0,0,0,0,1,0,0,0
SID_352,11820,"Under the Political Constitution of the United Mexican States, the minimum age for employment is 15 years of age",0,0,0,0,0,0,0,0,0,0,0
SID_352,11821,"The Political Constitution of the United Mexican States also prescribes a prohibition of children over 15, and under 18 years of age who have not finished their compulsory basic education, except in the event of an authorization from the competent labour authority, which decides whether employment is compatible with studying",0,0,0,0,0,0,0,0,0,0,0
SID_352,11822,The Company requires proof of identification to accurately verify the age of each potential employee,0,0,0,0,0,0,0,1,0,0,0
SID_352,11823,Suppliers are governed by the Protocol of Suppliers (the Protocol),0,0,0,0,0,0,0,0,0,0,0
SID_352,11824,"As part of the onboarding process, all suppliers are required to sign and acknowledge the terms of the Protocol set forth by the Company",0,0,0,0,0,0,0,1,0,0,0
SID_352,11825,The Company reserves the right to terminate the relationship with any supplier or factory that violates the Protocol,0,0,0,0,0,0,0,0,1,0,0
SID_352,11826,"All facilities producing direct import merchandise, as well as Mexican facilities that produce merchandise for PesoRama or its wholly owned subsidiaries are visited by management on a regular basis",0,0,0,0,0,1,0,1,0,0,0
SID_352,11827,"During these visits, not only is the manufacturing process and product quality examined, but also the working conditions of the suppliers employees",0,0,0,0,0,0,0,1,0,0,0
SID_352,11828,"To date, the Company has not identified the use of forced labour or child labour by any of its suppliers, and therefore has not had to take any remediation measures",0,0,0,0,0,0,1,0,1,0,0
SID_352,11829,The Company only seeks partnerships with those who share its core values and beliefs about the fair treatment of people,0,0,0,0,0,0,0,0,0,0,0
SID_352,11830,"The Company knows that its customers, shareholders, and employees trust the Company to responsibly source the products that are sold by PesoRama and its wholly owned subsidiaries",0,0,0,0,0,0,0,0,0,0,0
SID_352,11831,The Companys resolve on this remains the same regardless of where in the world the Company conducts its business,0,0,0,0,0,0,0,0,0,0,0
SID_352,11832,"In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for the entity or entities listed above",0,0,0,0,0,0,0,0,0,0,0
SID_352,11833,"Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above",0,0,0,0,0,0,0,0,0,0,0
SID_352,11834,"Rahim Bhaloo Chief Executive Officer May 23th, 2024 I have the authority to bind Pesorama Inc, Pesorama, Holdings",0,1,0,0,0,0,0,0,0,0,0
SID_356,12123,"{01992982; 2; 4770-3 }{01992982; 2; 2704-9 } {3334245; 3; 02704-016} SCHEDULE A LEAFFILTER NORTH OF CANADA, INC",0,0,0,0,0,0,0,0,0,0,0
SID_356,12124,"FIGHTING AGAINST FORCED LABOUR AND CHILD LABOUR IN SUPPLY CHAINS FISCAL YEAR 2023 REPORT Introduction This report is made in accordance with the Fighting Against Forced Labour and Child Labour in Supply Chain Act for LeafFilter North of Canada, Inc (LeafFilter, we or us)",0,0,0,0,0,0,0,0,0,0,0
SID_356,12125,"The report, for the fiscal year ending December 31, 2023 (Fiscal 2023), includes steps taken to prevent and reduce risks of child labour and forced labour in our operations and supply chains",0,0,0,0,0,0,0,0,0,0,0
SID_356,12126,"Structure, Activities and Supply Chain LeafFilter is a home improvement company focused on providing leading gutter cover systems",0,0,0,0,1,0,0,0,0,0,0
SID_356,12127,"LeafFilter is based in Mississauga, Ontario and operates across Canada",0,0,0,1,1,0,0,0,0,0,0
SID_356,12128,LeafFilter employs 242 employees in Canada across 13 field office locations and 2 distribution centres,0,0,0,1,1,0,0,0,0,0,0
SID_356,12129,"LeafFilter imports its finished goods from its United States suppliers, including its US affiliate, who import certain pieces of raw goods from various countries, including a small percentage from China",0,0,0,0,0,1,0,0,0,0,0
SID_356,12130,"LeafFilter is part of a broader group of companies, known as the Leaf Home group of companies (Leaf Home)",0,0,0,1,0,0,0,0,0,0,0
SID_356,12131,"As LeafFilter is part of Leaf Home, all of Leaf Homes procedures and policies as set out below apply to LeafFilter",0,0,0,1,0,0,0,0,0,0,0
SID_356,12132,"Steps Taken to Prevent and Reduce Risks in Fiscal 2023 LeafFilter is committed to the health, safety, and wellbeing of its employees",0,0,0,0,0,0,0,0,0,0,0
SID_356,12133,We strive to not only meet but exceed employee expectations as an employer of choice in the marketplace,0,0,0,0,0,0,0,0,0,0,0
SID_356,12134,We are committed to conduct our business with integrity and in compliance with applicable laws,0,0,0,0,0,0,0,0,0,0,0
SID_356,12135,"In 2023, Leaf Home: x Conducted an internal assessment to develop an action plan for improvements to make to supply chain management; x Conducted an assessment of existing key suppliers by connecting with them to assess their existing risk mitigation strategies; x Developed and launched the Leaf Home Master Vendor Contracts",0,0,0,0,0,0,0,1,0,0,0
SID_356,12136,"The US entitys import contracts now include language focused on social and ethical responsibilities, health and safety requirements, and labor laws",0,0,0,0,0,0,0,1,0,0,0
SID_356,12137,All import suppliers are required to supply Leaf Home with the results of a 3rd party conducted social audit which must be scheduled immediately after the first Purchase Order is placed;  
 
 
     ,0,0,0,0,0,0,0,1,0,0,0
SID_356,12138,"{01992982; 2; 4770-3 }{01992982; 2; 2704-9 } {3334245; 3; 02704-016} x Established a partnership with Bureau Veritas as a governance resource to conduct any needed social audits on behalf of Leaf Home; x Started the framework for a supplier questionnaire, with targeted social compliance questions, as part of our vetting process for new partners; and x Created a robust Vendor Relationship Guide, which will be launched in 2024",0,0,0,0,0,0,0,1,0,0,0
SID_356,12139,"The Vendor Relationship Guide will include language specific to a Vendor Workplace Code of Conduct, a factory audit program, and the consequences of non-compliance",0,0,0,0,0,0,0,1,0,0,0
SID_356,12140,Policies and Due Diligence Processes Corporate Code of Conduct LeafFilter abides by the Leaf Home Corporate Code of Business Conduct and Ethics,0,0,0,0,0,0,0,0,0,0,0
SID_356,12141,The Code promotes and expects ethical behaviour in all aspects of our business,0,0,0,0,0,0,0,0,0,0,0
SID_356,12142,"The applies to all LeafFilter employees, affiliates, suppliers, contractors, and associates of the Company",0,0,0,0,0,0,0,0,0,0,0
SID_356,12143,"Failure to follow our Code can result in disciplinary action, including termination of employment",0,0,0,0,0,0,0,0,0,0,0
SID_356,12144,Conduct not consistent with our Code may also result in the termination of the business relationship with LeafFilter,0,0,0,0,0,0,0,0,0,0,0
SID_356,12145,"Other processes Leaf Home has established an ESG Steering Committee to oversee and execute aspects of ESG strategy and governance including finance, legal, human capital management, and operations, including for LeafFilter",0,0,0,0,0,0,0,0,0,0,0
SID_356,12146,"Forced Labour and Child Labour Risks Through Leaf Home, we have started the process of identifying risks of forced labour and child labour in our supply chain",0,0,0,0,0,0,0,1,0,0,0
SID_356,12147,This process has included performing a Leaf Home Assessment and Existing Supplier Assessments,0,0,0,0,0,0,0,1,0,0,0
SID_356,12148,"x Through the Leaf Home Assessment, we have identified that the greatest risk of child/and or forced labour are products sourced by its US affiliate suppliers from China",0,0,0,0,0,0,1,0,0,0,0
SID_356,12149,"Through Leaf Homes Existing Supplier Assessments, Leaf Home has worked with the US affiliate suppliers to connect with all key suppliers to assess their existing risk mitigation strategies",0,0,0,0,0,0,0,1,0,0,0
SID_356,12150,The US affiliate has established that both import and domestic suppliers recognize the need for transparency in the supply chain and are willing to work on mitigation strategies in partnership with us to reduce any risks,0,0,0,0,0,0,0,0,0,0,0
SID_356,12151,"The internal assessment and assessment of suppliers, development of the Leaf Home Master Vendor Contracts and Vendor Relationship Guide, establishment of the partnership with Bureau Veritas, and the vetting process for new partners are steps we have taken to mitigate risks of forced labour or child labour",0,0,0,0,0,0,0,1,0,0,0
SID_356,12152,Remediation Measures LeafFilter has not identified any instances of forced labour or child labour in its activities or supply chains,0,0,0,0,0,0,1,0,0,0,0
SID_356,12153,"For that reason, remediation measures for instances of forced labour or child labour or for loss of income to the most vulnerable families have not arisen",0,0,0,0,0,0,0,0,1,0,0
SID_356,12154,{01992982; 2; 4770-3 }{01992982; 2; 2704-9 } {3334245; 3; 02704-016} We remain committed to take steps to respond and remediate in the event instances forced labour or child labour are discovered,0,0,0,0,0,0,0,0,0,0,0
SID_356,12155,Training Our employees are required to take a virtual training course on our Corporate Code of Business Conduct and Ethics on an annual basis,0,0,0,0,0,0,0,1,0,0,0
SID_356,12156,Employees are also required to acknowledge the Code annually,0,0,0,0,0,0,0,0,0,0,0
SID_356,12157,"However, this training does not specifically cover risks of forced or child labour",0,0,0,0,0,0,0,1,0,0,0
SID_356,12158,"Assessing Effectiveness We remain committed to further developing and continuously refining our policies, procedures, and programs as we learn more about the risks in our supply chain and ways to mitigate them",0,0,0,0,0,0,0,0,0,0,0
SID_356,12159,This Report is approved and attested pursuant to subsection 11(4)(a) and subsection 11(5) of the Fighting Against Forced Labour and Child Labour in Supply Chain Act,0,0,0,0,0,0,0,0,0,0,0
SID_356,12160,"I have the authority to bind the LeafFilter North of Canada, Inc",0,0,0,0,0,0,0,0,0,0,0
SID_356,12161,___________________________ Name: Joseph A,0,1,0,0,0,0,0,0,0,0,0
SID_356,12162,"Saldutti, Jr Title: Vice President & Secretary Date: May 31, 2024",0,1,0,0,0,0,0,0,0,0,0
SID_357,12163,1 Forced Labour and Child Labour in Canadian Supply Chains Report Summary,0,0,0,0,0,0,0,0,0,0,0
SID_357,12164,The Casinos are dedicated to adhering to high ethical standards in all facets of our operations,0,0,0,0,0,0,0,0,0,0,0
SID_357,12165,Our company practices and policies are designed to ensure we operate in an ethical and responsible manner,0,0,0,0,0,0,0,0,0,0,0
SID_357,12166,"Our core values of Winning Attitude, Wining Culture, and Winning Energy aim to build a place of belonging that promotes diversity, inclusion, transparency, and a team centered culture to draw on the differences of who we are, what weve experienced, and how we think",0,0,0,0,0,0,0,0,0,0,0
SID_357,12167,We require fair and responsible labour practices throughout our companies and from our vendors,0,0,0,0,0,0,0,0,0,0,0
SID_357,12168,"Reporting Requirements This report is prepared to comply with Bill S211, Fighting Against Forced Labour and Child Labour in Supply Chains Act",0,0,0,0,0,0,0,0,0,0,0
SID_357,12169,This report satisfies the reporting obligations outlined by Public Safety Canada and the Government of Canada,0,0,0,0,0,0,0,0,0,0,0
SID_357,12170,Reporting Year This report is prepared for the 2023 reporting year,0,0,0,0,0,0,0,0,0,0,0
SID_357,12171,Reporting Group This is a joint report and includes the following entities which are under common control and operate under common management,0,0,0,1,0,0,0,0,0,0,0
SID_357,12172,"Calgary Casino LP, Calgary Casino GP o/a Ace Casino Airport 2267166 Alberta Ltd o/a Ace Casino Blackfoot Cash Casinos LP, 477599 Alberta Ltd o/a Cash Casino",0,0,0,1,0,0,0,0,0,0,0
SID_357,12173,Collectively referred to in this report as the Entities,0,0,0,0,0,0,0,0,0,0,0
SID_357,12174,About the Entities,0,0,0,0,0,0,0,0,0,0,0
SID_357,12175,The Entities operate in the highly regulated gaming sector and offer food and beverage services as well as entertainment,0,0,0,0,1,0,0,0,0,0,0
SID_357,12176,"The Entities are Regulated by Alberta Gaming, Liquor and Cannabis",0,0,0,0,0,0,0,0,0,0,0
SID_357,12177,The Entities operate casinos located in Calgary and Red Deer Alberta,0,0,0,0,1,0,0,0,0,0,0
SID_357,12178,"This report was approved by the Board of Directors on April 19, 2024, attestation statement is included on page 4",1,0,0,0,0,0,0,0,0,0,0
SID_357,12179,"Structure, activities and supply chains",0,0,0,0,0,0,0,0,0,0,0
SID_357,12180,Child and forced labor are pervasive problems throughout the world,0,0,0,0,0,0,0,0,0,0,0
SID_357,12181,We recognize that we have the responsibility to ensure all stakeholders are treated with dignity and respect,0,0,0,0,0,0,0,0,0,0,0
SID_357,12182,We structure our procurement processes to ensure the following standards,0,0,0,0,0,0,0,1,0,0,0
SID_357,12183,The Entities will not tolerate the use of child or forced labor in any of its suppliers,0,0,0,0,0,0,0,1,0,0,0
SID_357,12184,"The Entities will not tolerate the exploitation of children, their engagement in unacceptably hazardous work, and the physical punishment, abuse, or involuntary servitude of any worker",0,0,0,0,0,0,0,1,0,0,0
SID_357,12185,We expect the suppliers and contractors with whom we do business to uphold the same standards,0,0,0,0,0,0,0,0,0,0,0
SID_357,12186,"Should we become aware of a violation of these standards, we will terminate the relationship and",0,0,0,0,0,0,0,0,1,0,0
SID_357,12187,"For this purpose, a child is anyone who is less than 15 years of age",0,0,0,0,0,0,0,0,0,0,0
SID_357,12188,It is our responsibility to ensure compliance with these principles in our businesses and from our suppliers,0,0,0,0,0,0,0,0,0,0,0
SID_357,12189,Supply Chain Structure,0,0,0,0,0,0,0,0,0,0,0
SID_357,12190,The Entities are located in Canada and source the majority of their goods and supplies from within Canada,0,0,0,0,1,1,0,0,0,0,0
SID_357,12191,The majority of regular and recurring purchases are related to goods and supplies purchased for Food and Beverage Operations and over 99% are purchased from within Canada,0,0,0,0,0,1,0,0,0,0,0
SID_357,12192,Imported goods and supplies have the following characteristics,0,0,0,0,0,0,0,0,0,0,0
SID_357,12193,"Goods are imported on an infrequent and irregular basis; Goods imported tend to be ordered more than once tend to be from a limited number of approved vendors; Good imported are sold by a number different of vendors that could be evaluated, if needed; Goods imported are not business critical in nature",0,0,0,0,0,1,0,0,0,0,0
SID_357,12194,Policies and due diligence,0,0,0,0,0,0,0,0,0,0,0
SID_357,12195,The Entities have written policies and conduct requirements that our employees must review annually and acknowledge compliance,0,0,0,0,0,0,0,0,0,0,0
SID_357,12196,These requirements are included in our Employee Handbook and include,0,0,0,0,0,0,0,0,0,0,0
SID_357,12197,Core values Ethics Conflict of interest Fair dealing Corruption,0,0,0,0,0,0,0,0,0,0,0
SID_357,12198,Whistleblower,0,0,0,0,0,0,0,0,0,0,0
SID_357,12199,Procurement,0,0,0,0,0,0,0,0,0,0,0
SID_357,12200,Any non-compliance is addressed immediately in accordance with company policy,0,0,0,0,0,0,0,0,0,0,0
SID_357,12201,Risk assessment,0,0,0,0,0,0,0,0,0,0,0
SID_357,12202,"Due to the highly regulated gaming sector in which we operate and to comply with our internal policies and processes, prior to entering a contract or agreement with any new supplier or business, we undergo an evaluation process",0,0,0,0,0,0,0,1,0,0,0
SID_357,12203,We follow a strict vetting and approval process before contracting with new vendors,0,0,0,0,0,0,0,1,0,0,0
SID_357,12204,"This includes supplier investigation via website review, internet search and risk assessment",0,0,0,0,0,0,0,1,0,0,0
SID_357,12205,High risk imported items are considered as follows,0,0,0,0,0,0,1,0,0,0,0
SID_357,12206,High risk factors,0,0,0,0,0,0,1,0,0,0,0
SID_357,12207,Labour intensive services,0,0,0,0,0,0,1,0,0,0,0
SID_357,12208,Outsourced labour hire,0,0,0,0,0,0,1,0,0,0,0
SID_357,12209,Raw material sourcing,0,0,0,0,0,0,1,0,0,0,0
SID_357,12210,Migrant workers High risk sectors,0,0,0,0,0,0,1,0,0,0,0
SID_357,12211,Cleaning and maintenance,0,0,0,0,0,0,1,0,0,0,0
SID_357,12212,Electronics,0,0,0,0,0,0,1,0,0,0,0
SID_357,12213,Manufacturing,0,0,0,0,0,0,1,0,0,0,0
SID_357,12214,Information technology,0,0,0,0,0,0,0,0,0,0,0
SID_357,12215,The Entities conduct their business solely in Canada where there is a low risk of forced and child labour,0,0,0,0,1,0,0,0,0,0,0
SID_357,12216,"All goods imported to Canada by the Entities are ancillary goods purchased to support our business; because they are not business critical in nature, the Entities have the ability to search for suppliers and execute diligence to ensure that they meet our business values in advance of placing an order",0,0,0,0,0,1,0,0,0,0,0
SID_357,12217,This allows for careful compliance with our responsibilities and reduces overall risk as the Entities dont have execution or urgency pressures when evaluating vendors from outside of Canada,0,0,0,0,0,0,0,0,0,0,0
SID_357,12218,We have the ability to source goods from several vendors and are not reliant on one vendor for the supply of most goods,0,0,0,0,0,0,0,0,0,0,0
SID_357,12219,Imported items are from a small number of approved vendors which have been vetted prior to ordering,0,0,0,0,0,1,0,0,0,0,0
SID_357,12220,Imported goods over the last two years by the entities include items such as,0,0,0,0,0,1,0,0,0,0,0
SID_357,12221,Lighting and fixtures,0,0,0,0,0,1,0,0,0,0,0
SID_357,12222,Dice,0,0,0,0,0,1,0,0,0,0,0
SID_357,12223,Carpet and,0,0,0,0,0,1,0,0,0,0,0
SID_357,12224,Radios,0,0,0,0,0,1,0,0,0,0,0
SID_357,12225,"Remediation measures The Entities have not become aware of any vendor, either vetted or contracted with, to have breached our policies, conduct or known to have forced or child labour in their operations",0,0,0,0,0,0,1,0,0,0,0
SID_357,12226,"As such, no specific remedial action has occurred during the reporting period",0,0,0,0,0,0,0,0,1,0,0
SID_357,12227,"If we become aware of a breach in our Policies by a vendor in the future, the relationship would be discontinued immediately and additional actions taken depending on the circumstances",0,0,0,0,0,0,0,0,1,0,0
SID_357,12228,Assessing effectiveness We continue to take risk-based steps to enhance our systems and processes to mitigating forced labour risks,0,0,0,0,0,0,0,0,0,1,0
SID_357,12229,Effectiveness indicators include,0,0,0,0,0,0,0,0,0,1,0
SID_357,12230,Updating and reviewing our processes and policies at least annually,0,0,0,0,0,0,0,0,0,1,0
SID_357,12231,Enhancing internal awareness and training,0,0,0,0,0,0,0,0,0,1,0
SID_357,12232,"Remediation loss of income As noted above, there have been no instances of a vendor in non-compliance with fair labour practices",0,0,0,0,0,0,1,0,0,0,0
SID_357,12233,"As such, there have been no cases where loss of income has arose from cutting ties from a vendor",0,0,0,0,0,0,0,0,0,0,0
SID_357,12234,"As noted above, the risk of forced and child labour is lower in Canada than in many other countries",0,0,0,0,0,0,0,0,0,0,0
SID_357,12235,"Given that the Entities do not presently anticipate taking any remedial action for its operations, no loss of income to vulnerable families as a result of such actions is anticipated",0,0,0,0,0,0,0,0,0,0,0
SID_357,12236,Training We have a small team of procurement personnel that are employed by the Entities and they are the only authorized individuals permitted to contract or engage with vendors,0,0,0,0,0,0,0,0,0,0,0
SID_357,12237,All procurement personnel are familiar with our process and policies and required to adhere,0,0,0,0,0,0,0,0,0,0,0
SID_357,12238,"Our Employee Handbook is updated annually and must be reviewed and formal written acknowledgement completed by all employees, including the procurement personnel",0,0,0,0,0,0,0,1,0,0,0
SID_357,12239,"In order to limit risk, the Entities only allow for their procurement personal to contract or engage with vendors",0,0,0,0,0,0,0,0,0,0,0
SID_357,12240,Attestation,0,0,0,0,0,0,0,0,0,0,0
SID_357,12241,"In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for the entity or entities listed above",0,0,0,0,0,0,0,0,0,0,0
SID_357,12242,"Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the 2023 reporting year",0,0,0,0,0,0,0,0,0,0,0
SID_357,12243,John W,0,1,0,0,0,0,0,0,0,0,0
SID_357,12244,"Mather Director April 19, 2024",0,1,0,0,0,0,0,0,0,0,0
SID_357,12245,I have the authority to bind the Entities,0,0,0,0,0,0,0,0,0,0,0
SID_361,12556,(418) 624-4565 BILL S-211: REPORT FROM METAL 7 INC,0,0,0,0,0,0,0,0,0,0,0
SID_361,12557,Legal Name of the Reporting Entity: Mtal 7 Inc,0,0,0,0,0,0,0,0,0,0,0
SID_361,12558,Financial Year Covered by the Report: 01/01/2023 31-12-2023,0,0,0,0,0,0,0,0,0,0,0
SID_361,12559,Business Number(s) (if applicable):1169977544,0,0,0,0,0,0,0,0,0,0,0
SID_361,12560,Identification of Reporting Obligations in Other Jurisdictions: None,0,0,0,0,0,0,0,0,0,0,0
SID_361,12561,"Categorization of Entities Under the Act: Canadian company doing business in Canada, with assets in Canada and meeting the following criteria: ""Has at least $20 million in assets for at least one of its last two financial years""; ""Has generated at least $40 million in revenue for at least one of its last two financial years",0,0,0,0,0,0,0,0,0,0,0
SID_361,12562,Sector/Industry: Manufacturing and Mining,0,0,0,0,1,0,0,0,0,0,0
SID_361,12563,"Location: Sept-les, QC, Canada",0,0,0,1,0,0,0,0,0,0,0
SID_361,12564,Section 1,0,0,0,0,0,0,0,0,0,0,0
SID_361,12565,"Structure, Activities, and Supply Chains (a) Structure Mtal 7 Inc is a joint-stock company owned by major Canadian investment funds (Fonds de Solidarit FTQ, Fondaction, BDC Capital, CSN Investment) and senior executives, all based in the province of Quebec, Canada",0,0,0,1,0,0,0,0,0,0,0
SID_361,12566,"Although Mtal 7 Inc includes a group of Canadian and foreign subsidiaries, designated as ""Groupe M7,"" it has been understood that entities are required to report only the activities of their subsidiaries that are entities with reporting obligations under the Act (CA$40M revenue, CA$20M assets, 250 employees)",0,0,0,1,0,0,0,0,0,0,0
SID_361,12567,"In this case, only Mtal 7 Inc meets the size criteria, namely : ""Has at least $20 million in assets for at least one of its last two financial years""; ""Has generated at least $40 million in revenue for at least one of its last two financial years."" However, throughout this report, a set of information, policies, and processes implemented by Mtal 7 Inc, within its own entity but also affecting its main subsidiaries, will be mentioned",0,0,0,1,0,0,0,0,0,0,0
SID_361,12568,"The mandate of the ""Groupe M7"" is to develop innovative solutions to optimize efficiency and reduce the environmental footprint of the primary industry",0,0,0,0,1,0,0,0,0,0,0
SID_361,12569,"For Mtal 7 Inc, and more specifically, its mandate is to create high-performance solutions that meet the needs of solid particle screening and ultra-resistant surface coatings",0,0,0,0,1,0,0,0,0,0,0
SID_361,12570,"With world-class expertise in surface engineering and mastery of complex industrial processes, Mtal 7 Inc has built a solid reputation with major mining and metallurgical companies worldwide, as well as companies specializing in the processing of hard particles, such as fertilizers and aggregates",0,0,0,0,1,0,0,0,0,0,0
SID_361,12571,(418) 624-4565 Presentation of Mtal 7 Inc and its Subsidiaries,0,0,0,1,0,0,0,0,0,0,0
SID_361,12572,Presentation of the Organizational Structure of Mtal 7 Inc,0,0,0,1,0,0,0,0,0,0,0
SID_361,12573,"(418) 624-4565 Mtal 7 Inc employs 211 people, distributed as follows: 112 employees for Mtal 7 Inc and Groupe M7 Inc, including 5 abroad 51 employees for Cast 7 LCC",0,0,0,1,0,0,0,0,0,0,0
SID_361,12574,in the United States 34 employees for Enduride Canada / USA Inc in Canada 14 employees for Les quipements Mgatraction Inc,0,0,0,1,0,0,0,0,0,0,0
SID_361,12575,"(b) Activities Mtal 7 Inc imports, manufactures, and processes a range of products in its sole plant, located in Sept-les, Quebec, Canada",0,0,0,0,0,1,0,0,0,0,0
SID_361,12576,"In 2023, Mtal 7 Inc imported approximately 6,000 tubes and other goods from the United States, China, India, Brazil, and Europe, representing 45% of its product purchases",0,0,0,0,0,1,0,0,0,0,0
SID_361,12577,"Mtal 7 Inc proudly exports 80% of its solid particle screening equipment and ultra-resistant surface coatings outside of Canada, deploying them in over 20 countries",0,0,0,0,1,0,0,0,0,0,0
SID_361,12578,"(c) Supply chains Mtal 7 Inc is proud to work daily with Quebec and Canadian companies, representing more than 95% of its supplier base for both products and services",0,0,0,0,0,1,0,0,0,0,0
SID_361,12579,"Generally, and for products, Mtal 7 Inc manages its own purchases and imports but also relies on specialized suppliers for importing specific raw materials such as tubes, steel, or coating components",0,0,0,0,0,1,0,0,0,0,0
SID_361,12580,"Origin Type of Merchandise Type of Service (eg, direct import by Mtal 7 Inc, indirect by our suppliers) USA Tubes Direct and indirect import USA Steel and other raw materials Indirect import China Tubes Direct and indirect import China Small components Indirect import India Tubes Direct import Europe Motors and other components Indirect import Europe Small components Direct and indirect import Brazil Tubes Direct import Canada Steel and other raw materials Direct purchase Canada Small components (eg, fasteners) Direct purchase Canada All services combined Direct purchase",0,0,0,0,0,1,0,0,0,0,0
SID_361,12581,(418) 624-4565 Section 2,0,0,0,0,0,0,0,0,0,0,0
SID_361,12582,"Policies and Due Diligence Processes Related to Forced Labor and Child Labor Mtal 7 Inc proudly upholds its values related to the objectives of this report and its actions in favor of these principles: collaboration, respect, and excellence",0,0,0,0,0,0,0,0,0,0,0
SID_361,12583,"All stakeholders are involved: employees, executives, partners, and suppliers; we all work together to adhere to these principles daily",0,0,0,0,0,0,0,0,0,0,0
SID_361,12584,"EXCELLENCE // Striving to exceed, being rigorous, professional, and responsible",0,0,0,0,0,0,0,0,0,0,0
SID_361,12585,"COLLABORATION // Working together with our people, our partners, and our clients",0,0,0,0,0,0,0,0,0,0,0
SID_361,12586,"RESPECT // Being honest and transparent, acting in the best mutual interest",0,0,0,0,0,0,0,0,0,0,0
SID_361,12587,"In line with these values, several activities have been implemented with Mtal 7 Inc employees and subsidiaries, as well as external partners: (a) Activities with employees: A code of ethics has been drafted and is presented to all new employees, who must sign to acknowledge acceptance",0,0,0,0,0,0,0,1,0,0,0
SID_361,12588,"This same code of ethics is also presented annually to all employees as a reminder, with proof of acceptance",0,0,0,0,0,0,0,1,0,0,0
SID_361,12589,"Specifically, within the framework of Bill S-211, the code refers to fundamental human and worker rights, stating: ""Mtal 7 Inc is equally concerned about respecting the fundamental rights of individuals, workers, and laborers, and commits not to knowingly be complicit in operations involving forced displacement of individuals, groups, or communities",0,0,0,0,0,0,0,0,0,0,0
SID_361,12590,"Mtal 7 Inc also commits not to use child labor as defined by labor organizations."" (b) Activities with External Partners: A supplier code of conduct has been established and distributed to Mtal 7 Inc.'s main suppliers",0,0,0,0,0,0,0,1,0,0,0
SID_361,12591,"Beyond mere communication, suppliers were also instructed to complete a questionnaire accompanying the supplier code of conduct, committing to values important to Mtal 7 Inc such as",0,0,0,0,0,0,0,1,0,0,0
SID_361,12592,"Acting with integrity, loyalty, and diligence",0,0,0,0,0,0,0,0,0,0,0
SID_361,12593,Respecting people and the work environment,0,0,0,0,0,0,0,0,0,0,0
SID_361,12594,Environmental sustainability and development,0,0,0,0,0,0,0,0,0,0,0
SID_361,12595,"Avoiding forced labor and child labor Suppliers were also encouraged to share processes or best practices implemented within their own entities, potentially providing valuable insights for Mtal 7 Inc",0,0,0,0,0,0,0,1,0,0,0
SID_361,12596,The distribution of this supplier code of conduct and specifically the questionnaire offers an opportunity to learn more about the practices and activities of Mtal 7 Inc.'s and its subsidiaries' main suppliers regarding the use of forced labor and child labor,0,0,0,0,0,0,0,1,0,0,0
SID_361,12597,(418) 624-4565 It should be noted that only the primary product suppliers were invited to respond to the initial questionnaire distribution,0,0,0,0,0,0,0,1,0,0,0
SID_361,12598,The suppliers who responded to the questionnaire and have annual purchases exceeding $50K account for 42% of the purchase value in 2023,0,0,0,0,0,0,0,0,0,1,0
SID_361,12599,"This initial risk analysis initiative regarding forced labor and child labor, the first distribution, and these initial results cover 27% of Mtal 7 Inc.'s supply chain activities, including all products and services",0,0,0,0,0,0,0,0,0,1,0
SID_361,12600,This exercise has been extended to the supply chain activities of the entity Les quipements Mgatraction Inc,0,0,0,0,0,0,0,1,0,0,0
SID_361,12601,The product suppliers who responded to the questionnaire represent nearly 80% of the purchase value in 2023 for Les quipements Mgatraction Inc,0,0,0,0,0,0,0,0,0,1,0
SID_361,12602,"This initial risk analysis initiative regarding forced labor and child labor, the first distribution, and these initial results cover almost half of the supply chain activities of Les quipements Mgatraction Inc, including products and services",0,0,0,0,0,0,0,0,0,1,0
SID_361,12603,Section 3,0,0,0,0,0,0,0,0,0,0,0
SID_361,12604,"Parts of Its Business Chains or Supply Chains That Involve a Risk of Forced Labor or Child Labor and the Measures Taken to Assess and Manage This Risk With the implementation of Bill S-211, Mtal 7 Inc sought to learn more about the practices of its suppliers, initially focusing on foreign suppliers or those importing products from abroad regarding the risks of forced labor and child labor",0,0,0,0,0,0,0,0,0,0,0
SID_361,12605,"Following the distribution of the supplier code of conduct and its accompanying questionnaire, the analysis of the initial responses confirmed that there was no risk of forced labor or child labor within Mtal 7 Inc.'s supply chain activities",0,0,0,0,0,0,1,0,0,0,0
SID_361,12606,"However, Mtal 7 Inc remains vigilant and will continue its efforts to prevent any future risks, notably by",0,0,0,0,0,0,0,0,0,0,0
SID_361,12607,"Continuing to distribute its supplier code of conduct to all suppliers, both for products and services, to promote an environment free from forced labor or child labor",0,0,0,0,0,0,0,1,0,0,0
SID_361,12608,"Continuing to collect results to analyze the activities of suppliers from all entities within the ""Groupe M7,"" aiming to monitor 80% of the group's product purchases by value",0,0,0,0,0,0,0,1,0,1,0
SID_361,12609,Organizing regular audits of main suppliers that could develop a risk of forced labor and child labor,0,0,0,0,0,0,0,1,0,0,0
SID_361,12610,Section 4,0,0,0,0,0,0,0,0,0,0,0
SID_361,12611,"Measures Taken to Remedy Any Use of Forced Labor or Child Labor Since no risk of forced labor or child labor was identified within Mtal 7 Inc.'s activities and supply chains, no remedial measures have been implemented",0,0,0,0,0,0,1,0,1,0,0
SID_361,12612,"However, Mtal 7 Inc regularly raises awareness among its employees, partners, suppliers, and other stakeholders about these practices and will continue to do so to prevent the need for any remedial actions",0,0,0,0,0,0,0,1,0,0,0
SID_361,12613,Section 5,0,0,0,0,0,0,0,0,0,0,0
SID_361,12614,"Measures Taken to Remedy Income Losses of the Most Vulnerable Families Resulting from Measures to Eliminate Forced Labor or Child Labor in Activities and Supply Chains Since no risk of forced labor or child labor was identified within Mtal 7 Inc.'s activities and supply chains, no measures have been implemented to address income losses of the most vulnerable families resulting from measures to eliminate forced labor or child labor",0,0,0,0,0,0,1,0,0,0,0
SID_361,12615,(418) 624-4565 Section 6,0,0,0,0,0,0,0,0,0,0,0
SID_361,12616,"Training Provided to Employees on Forced Labor and Child Labor Since no risk of forced labor or child labor was identified within Mtal 7 Inc.'s activities and supply chains, no training has been provided to Mtal 7 Inc employees on forced labor and child labor",0,0,0,0,0,0,1,1,0,0,0
SID_361,12617,"However, this has been noted for future action",0,0,0,0,0,0,0,0,0,0,0
SID_361,12618,Section 7,0,0,0,0,0,0,0,0,0,0,0
SID_361,12619,"How the Effectiveness of Efforts is Evaluated to Prevent Forced Labor or Child Labor in Commercial Chains and Supply Chains Since no risk of forced labor or child labor was identified within Mtal 7 Inc.'s activities and supply chains, there is currently no method to measure the effectiveness of efforts to prevent forced labor or child labor in commercial and supply chains",0,0,0,0,0,0,1,0,0,1,0
SID_361,12620,"However, an audit will be conducted with Mtal 7 Inc.'s main suppliers to verify the accuracy of declarations in the latest questionnaire attached to the supplier code of conduct distribution",0,0,0,0,0,0,0,1,0,0,0
SID_361,12621,"This audit will lead to the implementation of tools to monitor supplier declarations, audits performed and planned, and reports from each visit",0,0,0,0,0,0,0,1,0,0,0
SID_361,12622,"This report was prepared in Quebec by Mlanie Bouleau, Strategic Buyer, (mbouleau@metal7.com)",0,0,0,0,0,0,0,0,0,0,0
SID_361,12623,We solemnly attest to the accuracy of the information provided,0,0,0,0,0,0,0,0,0,0,0
SID_361,12624,This report has been read and approved by: Name Position Date and Signature Eric Martin,0,1,0,0,0,0,0,0,0,0,0
SID_361,12625,Franois Chevarie,0,1,0,0,0,0,0,0,0,0,0
SID_361,12626,Guillaume Vincent,0,1,0,0,0,0,0,0,0,0,0
SID_361,12627,Erik Levesque,0,1,0,0,0,0,0,0,0,0,0
SID_361,12628,DocuSign Envelope ID: 67C498F0-1628-4627-85D6-34A9B5DBF6A7 CEO 23/05/2024 23/05/2024 Value Chain Director 27 mai 2024 | 9:58 AM PDT VP Oprations VP Finance 23/05/2024,0,0,0,0,0,0,0,0,0,0,0
SID_365,12776,"Arkema Inc 900 1st Avenue, King of Prussia, PA 19406 Tel.: (610) 205-7000 - Fax: (610) 205-7075 www.arkema.com PURPOSE The purpose of this Annual Report is to report on the steps the Reporting Entities described below have taken during their previous financial year to prevent and reduce the risk that forced labour and child labour is used at any step of the production of goods in Canada or elsewhere by the named Reporting Entity, or of goods imported into Canada by the Reporting Entity, if any",0,0,0,0,0,0,0,0,0,0,0
SID_365,12777,"REPORTING ENTITIES This report pertains to the activities of the Arkema entities listed below, who are parties filing this report jointly in accordance with subsection 11(2) of the FCLA, and any reference to Reporting Entities in this report shall be taken to be a reference to each of them",0,0,0,1,0,0,0,0,0,0,0
SID_365,12778,Arkema Inc,0,0,0,1,0,0,0,0,0,0,0
SID_365,12779,Arkema Canada Inc,0,0,0,1,0,0,0,0,0,0,0
SID_365,12780,Bostik Canada Ltd,0,0,0,1,0,0,0,0,0,0,0
SID_365,12781,"(hereafter, the Reporting Entities)",0,0,0,0,0,0,0,0,0,0,0
SID_365,12782,"REPORTING PERIOD The reporting period relevant for purposes of this report is the previous financial year of the Reporting Entities, which is common to each of the Reporting Entities, and which is the year ended December 31, 2023 (the Reporting Period)",0,0,0,1,0,0,0,0,0,0,0
SID_365,12783,REPORTABLE ACTIVITIES,0,0,0,0,0,0,0,0,0,0,0
SID_365,12784,"Structure, Activities & Supply Chains The Reporting Entities are each controlled subsidiaries of Arkema (France) as societe anonyme (Arkema France) and fall within the umbrella of what will be referred to in this Annual Report as the Arkema Group.i The Arkema Group has over 21,100 employees worldwide and 148 industrial sites in 55 countries",0,0,0,1,1,0,0,0,0,0,0
SID_365,12785,"In the U.S., Arkema Affiliates operate 43 sites, including 37 manufacturing facilities and employ over 3600 people.ii In Canada, Arkema has over 60 employees and two",0,0,0,1,1,0,0,0,0,0,0
SID_365,12786,"facilities.iii Between the US and Canada, the Arkema Group produces and markets a wide range of chemical products, including acrylic monomers, adhesives, emulsion systems, fluorochemicals, fluoropolymers, functional additives, hydrogen peroxide, specialty polyamides and thiochemicals",0,0,0,1,1,0,0,0,0,0,0
SID_365,12787,"The three Reporting Entities have established a global network of suppliers, which consists of over 570 suppliers across many countries, including Canada, the United States, Mexico, and France",0,0,0,0,0,1,0,0,0,0,0
SID_365,12788,"Through that network, the Reporting Entities procure a wide range of materials essential for their operations, including propylene, butanol, methanol, and methacrylic acid",0,0,0,0,0,1,0,0,0,0,0
SID_365,12789,"Policies & Due Diligence Processes in relation to Forced Labour & Child Labour The Arkema Group has established comprehensive policies and due diligence processes aimed at addressing the issue of forced labour and child labour, and which apply to not only all Arkema Affiliates and their employees, including the Reporting Entities, but also to all third-party suppliers",0,0,0,0,0,0,0,1,0,0,0
SID_365,12790,Some of these policies and processes are discussed below,0,0,0,0,0,0,0,0,0,0,0
SID_365,12791,Internal Policies & Standards,0,0,0,0,0,0,0,0,0,0,0
SID_365,12792,"Code of Conduct & Ethics / Compliance Program The Arkema Group and each of the Reporting Entities is fully committed to integrity in their respective supply chains, and otherwise",0,0,0,0,0,0,0,0,0,0,0
SID_365,12793,"More specifically, all Arkema Affiliates strive to continuously strengthen our ethics and compliance culture, using the guiding principles and prescriptions laid out in the Arkema Groups Code of Conduct",0,0,0,0,0,0,0,0,0,0,0
SID_365,12794,"The Code of Conduct is the cornerstone of the Arkema Groups Ethics & Compliance Program, which sets out the general requirements that every Arkema Affiliate must meet with respect to its stakeholders and describes the principles and rules of conduct that each Arkema Group employee must comply with",0,0,0,0,0,0,0,0,0,0,0
SID_365,12795,"Our values are both specific, as they have been chosen by us, and universal, as they are inspired by principles derived from fundamental rights treaties including the Universal Declaration of Human Rights of 1948, the Principles of the International Labour Organization, the Guidelines for Multinational Enterprises of the Organization for Economic Cooperation and Development (OECD) and the Principles of the United Nations Global Compact",0,0,0,0,0,0,0,0,0,0,0
SID_365,12796,"Within the Code of Conduct, we also explicitly express our commitment to respect human rights and fundamental freedoms as defined in the United Nations Universal Declaration of Human Rights",0,0,0,0,0,0,0,0,0,0,0
SID_365,12797,"The Arkema Group is therefore fully committed to preventing human rights violations, including forced labour and/or child labour, that could be caused to or by our employees and others, including any participants in our various supply chains",0,0,0,0,0,0,0,0,0,0,0
SID_365,12798,"Specifically, we oppose any forms of human trafficking, forced labour and child labour, regardless of the country in which we operate",0,0,0,0,0,0,0,1,0,0,0
SID_365,12799,"We also oppose all forms of exploitation, abuse, violence and sexual or moral harassment, as defined by the legislation of each country where Arkema operates",0,0,0,0,0,0,0,1,0,0,0
SID_365,12800,"We strive to ensure that no employee feels threatened or intimidated by any inappropriate conduct, and no form of violation or sexual or moral harassment in the workplace is tolerated",0,0,0,0,0,0,0,1,0,0,0
SID_365,12801,These commitments are also underpinned by our Human Rights Policy and our Social Commitment Charter,0,0,0,0,0,0,0,0,0,0,0
SID_365,12802,"Human Rights Policy The Arkema Group is also committed to the respect of human rights and fundamental freedoms as set out in the United Nations Universal Declaration of Human Rights, and places them at the heart of our business activity",0,0,0,0,0,0,0,0,0,0,0
SID_365,12803,"The Arkema Group thus strives, within the framework of its business activities, to prevent and, if necessary, to remedy human rights violations that could be experienced by its employees, those of its suppliers, subcontractors or other stakeholders",0,0,0,0,0,0,0,0,0,0,0
SID_365,12804,"In 2006, Arkema signed the Responsible Care Global Charter, a voluntary commitment by the chemical industry to improve the protection of people in terms of safety, health and environment across the entire value chain",0,0,0,0,0,0,0,1,0,0,0
SID_365,12805,"Similarly, in 2014, Arkema undertook to respect the Ten Principles of the UN Global Compact, a commitment that it renews every year through its Communication on Progress",0,0,0,0,0,0,0,1,0,0,0
SID_365,12806,Arkema Groups commitment is also reflected in,0,0,0,0,0,0,0,0,0,0,0
SID_365,12807,"Our compliance with relevant international regulations, national laws and standards in force in the countries in which we operate",0,0,0,0,0,0,0,0,0,0,0
SID_365,12808,The regular assessment of the risks in this area that may be generated by our business activity,0,0,0,0,0,0,0,1,0,0,0
SID_365,12809,The access to a whistleblowing system for both internal and external stakeholders,0,0,0,0,0,0,0,1,0,0,0
SID_365,12810,The implementation of corrective actions when necessary,0,0,0,0,0,0,0,0,0,0,0
SID_365,12811,A policy for continuous improvement of the companys practices through training initiatives and processes,0,0,0,0,0,0,0,1,0,0,0
SID_365,12812,An assessment and dialogue program with our suppliers and subcontractors aimed at promoting the respect of Human Rights,0,0,0,0,0,0,0,1,0,0,0
SID_365,12813,Transparent communication on our efforts in this area,0,0,0,0,0,0,0,0,0,0,0
SID_365,12814,More information on the Arkema Groups approach to human rights can be found in our Human Rights Policy,0,0,0,0,0,0,0,0,0,0,0
SID_365,12815,"Social Commitment Charter In a world facing multiple economic, environmental and social challenges, Arkema Group strives to offer its customers sustainable and innovative solutions contributing to the Sustainable Development Goals (SDGs) of the United Nations",0,0,0,0,0,0,0,0,0,0,0
SID_365,12816,"The Social Commitment Charter underscores our dedication to responsible business practices, prioritizing safety, health, and human rights",0,0,0,0,0,0,0,0,0,0,0
SID_365,12817,We aim to reduce environmental impacts through sustainable practices and innovations,0,0,0,0,0,0,0,0,0,0,0
SID_365,12818,"We advocate for diversity, equity, and inclusion, promoting fair treatment and opportunities for employees",0,0,0,0,0,0,0,0,0,0,0
SID_365,12819,"Transparency and dialogue with customers, suppliers and other partners are valued, with a goal to build a responsible value chain that creates shared value",0,0,0,0,0,0,0,0,0,0,0
SID_365,12820,"We support communities through philanthropy and volunteering efforts, aiming to create positive social impacts globally",0,0,0,0,0,0,0,0,0,0,0
SID_365,12821,Due Diligence Processes The Arkema Group has undertaken the following due diligence processes over the Reporting Period,0,0,0,0,0,0,0,0,0,0,0
SID_365,12822,"Supplier Code of Conduct Arkema promotes the responsible conduct of our suppliers through a Code of Conduct for Arkema Suppliers, which, among other things, outlines the minimum standards of conduct expected from suppliers and sub-contractors working with the Arkema Affiliates, including the Reporting Entities",0,0,0,0,0,0,0,0,0,0,0
SID_365,12823,"Suppliers are required to (i) respect and ensure that their own suppliers and sub- contractors respect the principles outlined in the Code of Conduct, and (ii) accept being assessed and/or audited in the scope of the Together for Sustainability program",0,0,0,0,0,0,0,1,0,0,0
SID_365,12824,"With respect to Human Rights and Labour Standards, Arkema requires suppliers to comply with the labour laws of the countries in which they operate",0,0,0,0,0,0,0,1,0,0,0
SID_365,12825,"Suppliers specifically undertake not to use child, forced, bonded or involuntary prison labour, as well as not to withhold their employees personal documents",0,0,0,0,0,0,0,1,0,0,0
SID_365,12826,"Suppliers must certify that the products supplied have not been mined, produced or manufactured, in whole or in part, using any form of forced labour or child labour",0,0,0,0,0,0,0,1,0,0,0
SID_365,12827,"Supply Chain Risk Assessment & Due Diligence Processes As part of the Arkema Groups commitment to upholding human rights and combatting forced labour and child labour, and as part of our due diligence activities with regard to",0,0,0,0,0,0,0,1,0,0,0
SID_365,12828,"forced labour and child labour, all Arkema Affiliates conduct risk assessments throughout our supply chains",0,0,0,0,0,0,0,1,0,0,0
SID_365,12829,"These assessments involve examination of various factors, including supplier practices and geographical considerations",0,0,0,0,0,0,0,1,0,0,0
SID_365,12830,"Through continuous monitoring and evaluation, we strive to ensure that our supply chain is aligned with our core values of ethical conduct and respect for human rights",0,0,0,0,0,0,0,0,0,0,0
SID_365,12831,"For Arkemas Affiliates in the US and Canada, including the Reporting Entities, we conduct risk assessments based on four categories of suppliers, and these due diligence processes were specifically undertaken during the Reporting Period",0,0,0,0,0,0,0,1,0,0,0
SID_365,12832,"Direct Suppliers from China: For direct suppliers from China and in cases where an Arkema Affiliate acts as the Importer of Record to Canada or to the US, the suppliers must undergo a thorough review process before they are approved to conduct business with us, to ensure compliance with applicable forced labour laws and regulations",0,0,0,0,0,1,0,1,0,0,0
SID_365,12833,"Direct Suppliers Outside of the US, other than from China: For direct suppliers not from the US or China, and in cases where an Arkema Affiliate acts as the Importer of Record to Canada or the US, the suppliers must undergo a thorough review process before they are approved to conduct business with us to ensure compliance with applicable forced labour laws and regulations",0,0,0,0,0,1,0,1,0,0,0
SID_365,12834,This applies even if the suppliers supply materials/products not directly from China (but were manufactured in China in whole or in part),0,0,0,0,0,1,0,1,0,0,0
SID_365,12835,"Indirect suppliers of Chinese goods (suppliers outside of China, Chinese domestic suppliers, distributors suppliers of Chinese products): When dealing with materials/products manufactured in China, where an Arkema Affiliate does not act as the Importer of Record, we will conduct a review to ensure that the supplier complies with relevant forced labour and child labour laws either upon a customer request or when the supplier serves as a sole source to the Arkema Group",0,0,0,0,0,1,0,1,0,0,0
SID_365,12836,"US or Canadian Domestic Suppliers: US or Canadian domestic suppliers who supply materials/products manufactured in the US or Canada, and which are acquired within the US or Canada are considered low risk for use of forced labour or child labour",0,0,0,0,0,1,1,0,0,0,0
SID_365,12837,"Accordingly, Arkema Affiliates sourcing these types of domestic goods will typically send the US or Canadian domestic suppliers a notification letter with our Code of Conduct, Supplier Code of Conduct, Terms and Conditions of Purchase and Uyghur Forced Labour Prevention Act (UFLPA) training slides",0,0,0,0,0,0,0,1,0,0,0
SID_365,12838,"At the same time, the Arkema Affiliate will typically request certificates of origin and a letter of assurance regarding compliance with forced labour and child labour laws",0,0,0,0,0,0,0,1,0,0,0
SID_365,12839,We will conduct a review to ensure that the supplier complies with relevant forced labour and child labour laws either upon a customer request or when the supplier serves as a sole source to the Arkema Group,0,0,0,0,0,0,0,1,0,0,0
SID_365,12840,"Terms and Conditions of Purchase The Arkema Group recently updated its Terms and Conditions of Purchase (which are standard and used by each of the Reporting Entities) with a provision addressing forced labour and child labour, which stimulates, among other things, that vendors warrant that no materials incorporated into the supplied goods have been manufactured by forced labour or child labour",0,0,0,0,0,0,0,1,0,0,0
SID_365,12841,Vendors found in violation of this provision risk contract termination without penalty,0,0,0,0,0,0,0,0,1,0,0
SID_365,12842,"On top of that, when we identify a vendor with forced labour, we block it on our internal systems",0,0,0,0,0,0,0,0,1,0,0
SID_365,12843,"Once blocked on the systems, no individual at any Arkema Affiliate is able to purchase any material from that specific vendor",0,0,0,0,0,0,0,0,1,0,0
SID_365,12844,We also block all vendors that have not done any business with the Arkema Group within 24 months,0,0,0,0,0,0,0,1,0,0,0
SID_365,12845,This ensures that they will need to restart our process as if they were a new supplier and go through our vetting process again,0,0,0,0,0,0,0,1,0,0,0
SID_365,12846,"Forced Labour and Child Labour Committee In June 2022, the Arkema Group created a Forced Labour Committee to support the overall efforts to combat forced and child labour",0,0,0,0,0,0,0,1,0,0,0
SID_365,12847,"The Committee includes participants from different businesses and countries, including Supply Chain, Supply Chain Procurement, Legal, Trade Compliance, Product Safety & Regulatory Affairs, Security and Data Management",0,0,0,0,0,0,0,1,0,0,0
SID_365,12848,"Specific Risks This portion of this Annual Report addresses parts of the Arkema Group and its supply chains that could carry a risk of forced labour or child labour, and the steps the Arkema Group (including the Reporting Entities) has taken to assess and manage that risk",0,0,0,0,0,0,0,0,0,0,0
SID_365,12849,"The Arkema Group has identified and acknowledged the supply risks associated with materials/products from China, and specifically the Uyghur region of China",0,0,0,0,0,0,1,0,0,0,0
SID_365,12850,"Consequently, the Arkema Group is taking comprehensive measures to address these risks, including conducting thorough assessments and implementing due diligence processes as described above",0,0,0,0,0,0,0,1,0,0,0
SID_365,12851,"The continued aim is to ensure that all Arkema Groups supply chain remains free from any human rights abuses, including any possible forced labour or child labour practices",0,0,0,0,0,0,0,0,0,0,0
SID_365,12852,"Transparency, accountability, and collaboration with suppliers are central themes in this approach",0,0,0,0,0,0,0,0,0,0,0
SID_365,12853,"In 2022, Arkema engaged a leading supply chain risk mapping and analysis service to support the mapping and tracing of our suppliers and materials, and this work continued through the Reporting Period",0,0,0,0,0,0,0,1,0,0,0
SID_365,12854,This service enables the mapping of businesses based on records of movement of products and associated trade data within their ecosystem,0,0,0,0,0,0,0,0,0,0,0
SID_365,12855,Supply chain risk mapping and analysis was also part of the Arkema Groups day-to-day activities during the Reporting Period,0,0,0,0,0,0,0,0,0,0,0
SID_365,12856,"Among other things, this greatly supports identifying potential inputs from China, and specifically the Xinjiang Uyghur Autonomous Region (XUAR) across various tiers of the supply chain",0,0,0,0,0,0,0,1,0,0,0
SID_365,12857,"Through this process, the Arkema Group, and the Reporting Entities, have mapped all possible business partners in China, revealing direct or indirect connections to entities and facilities involved in the trade of goods produced with forced labour in XUAR, or exhibiting other selected risk characteristics",0,0,0,0,0,1,0,1,0,0,0
SID_365,12858,This process has resulted in the Arkema Group refusing to do business with a small number of companies,0,0,0,0,0,0,0,0,1,0,0
SID_365,12859,New suppliers with materials made in China and existing suppliers who are providing new materials that are sourced from China must be reviewed to identify any Uyghur forced labour risks,0,0,0,0,0,1,0,1,0,0,0
SID_365,12860,"Remediation Measures re Forced or Child Labour Findings When the Arkema Group becomes aware of instances of forced labour or child labour within its supply chains, we make that information available, upon request, to our U.S",0,0,0,0,0,0,0,0,1,0,0
SID_365,12861,"Customs and Border Protection (CBP) National Account Manager or any other CBP party, or to Public Safety Canada (PSC) when that supply chain involves the Reporting Entities or Canadian destined goods or goods imported to Canada",0,0,0,0,0,0,0,0,1,0,0
SID_365,12862,"Additionally, Arkema Affiliates will internally block any affected supplier in our system and our Master Data platform, effectively halting any further purchases from that supplier",0,0,0,0,0,0,0,0,1,0,0
SID_365,12863,"In the event that a shipment is detained, Arkema will conduct a review of our internal processes, utilizing our forced labour and child labour software tools and EcoVadis, and will also question the supplier whose goods are being detained",0,0,0,0,0,0,0,0,1,0,0
SID_365,12864,"In any circumstance, we will provide information to our CBP National Account Manager, the Canada Border Services Agency (CBSA) or PSC upon request",0,0,0,0,0,0,0,0,1,0,0
SID_365,12865,"During the Reporting Period, a small number of suppliers were identified as having either unacceptable forced labour and child labour risks, or as using forced labour or child labour in the production of their goods or in their supply chains, and were consequently removed as suppliers within the Arkema Groups supply chains",0,0,0,0,0,0,1,0,1,0,0
SID_365,12866,Remediation Measures re Vulnerable Families & Lost Income This section of the Annual Report reports on measures taken by the Reporting Entities during the Reporting Period to remediate the loss of income to the most vulnerable families that resulted from any measure taken to eliminate the use of forced labour or child labour in their activities and supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_365,12867,"During the Reporting Period, we have not identified any loss of income to vulnerable families resulting from measures taken to eliminate the use of forced labour or child labour in our supply chains and consequently, no measures have been taken in this area",0,0,0,0,0,0,0,0,0,0,0
SID_365,12868,Training Provided to Employees on Forced Labour and Child Labour The Arkema Group and the Reporting Entities recognize the importance of training in combating forced labour and child labour within our collective operations and supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_365,12869,"Through training programs, we aim to equip our employees with the knowledge necessary to identify, prevent, and address instances of forced labour and child labour effectively",0,0,0,0,0,0,0,1,0,0,0
SID_365,12870,"In 2022 and during the Reporting Period, the Arkema Groups Trade Compliance team provided employees of the Reporting Entities with training on forced labour and child labour",0,0,0,0,0,0,0,1,0,0,0
SID_365,12871,"The training was provided on a virtual platform for many employees involved with import and export, purchasing, R&D and logistics and transportation",0,0,0,0,0,0,0,1,0,0,0
SID_365,12872,"The training contained eleven (11) forced labour indicators that can lead to the belief that there is forced labour in the workforce or in the supply chain, which are as follows",0,0,0,0,0,0,0,1,0,0,0
SID_365,12873,"Abuse of vulnerability When an employer takes advantage of a workers vulnerable position, such as lack of knowledge or local language or laws",0,0,0,0,0,0,0,1,0,0,0
SID_365,12874,Deception Failure of an employer to deliver what has been promised to a worker,0,0,0,0,0,0,0,1,0,0,0
SID_365,12875,Restriction of movement Workers are locked up or guarded to prevent escape,0,0,0,0,0,0,0,1,0,0,0
SID_365,12876,"Isolation Workers are isolated in remote locations, unable to contact anyone outside the area",0,0,0,0,0,0,0,1,0,0,0
SID_365,12877,Physical and sexual violence Includes forcing workers to take drugs or alcohol or perform tasks not part of the initial agreement,0,0,0,0,0,0,0,1,0,0,0
SID_365,12878,"Intimidation and threats Employers may make threats or use psychological coercion techniques to increase a sense of vulnerability; Retention of identity documents Employers keep identity documents such as passports, drivers licences or other valuable personal possessions",0,0,0,0,0,0,0,1,0,0,0
SID_365,12879,Withholding of wages Workers may remain with abusive employers while waiting for owed wages,0,0,0,0,0,0,0,1,0,0,0
SID_365,12880,"Debt bondage Workers may be working to pay off a debt, possibly from advances or loans",0,0,0,0,0,0,0,1,0,0,0
SID_365,12881,Abusive working and living conditions Abuse and coercion that prevents workers from leaving the job,0,0,0,0,0,0,0,1,0,0,0
SID_365,12882,"Excessive overtime - Obligation (or under threat of dismissal) to work excessive hours or days beyond what is allowed by law, denial of breaks or days off, forced to work shifts for absent colleagues or requirement for being on call 24/7; This training is also done on an annual basis, and forced labour training for all employes in North America is upcoming for the current financial year",0,0,0,0,0,0,0,1,0,0,0
SID_365,12883,"G Self-Assessment Processes The Arkema Group acknowledges and understands that self-assessment plays an important role in ensuring the effectiveness of measures implemented to combat forced labour and child labour, providing a framework for evaluating the impact and effectiveness of policies and strategies, and allowing us to identify areas of improvement and make informed decisions",0,0,0,0,0,0,0,0,0,0,0
SID_365,12884,"The Arkema Group employs a Corporate Social Responsibility (CSR) approach and that is regularly assessed by extra-financial rating agencies and our clients on Environmental, Social, and Governance (ESG) criteria basis",0,0,0,0,0,0,0,1,0,0,0
SID_365,12885,We discuss some of our sustainability initiatives and ratings below,0,0,0,0,0,0,0,0,0,0,0
SID_365,12886,"Together for Sustainability The Arkema Group uses the Together for Sustainability (TfS) tool as a member-driven initiative, raising corporate social responsibility standards throughout the chemical industry",0,0,0,0,0,0,0,0,0,0,0
SID_365,12887,"Arkema, as a member company since 2014, is responsible for implementing TfS and has actively reached out to suppliers and conducted a defined number of assessments, audits, and consequent improvements, per year",0,0,0,0,0,0,0,1,0,0,0
SID_365,12888,TfS performed audits on our suppliers,0,0,0,0,0,0,0,1,0,0,0
SID_365,12889,Audits are usually conducted on-site,0,0,0,0,0,0,0,1,0,0,0
SID_365,12890,"Sustainability performance is verified against a defined set of audit criteria on Management, Environment, Health & Safety, Labour & Human Rights, and Governance issues",0,0,0,0,0,0,0,1,0,0,0
SID_365,12891,The results are shared with the supplier company and all TfS members,0,0,0,0,0,0,0,0,0,0,0
SID_365,12892,"EcoVadis The Arkema Group also partners with EcoVadis, the worlds largest and most trusted provider of business sustainability ratings",0,0,0,0,0,0,0,0,0,0,0
SID_365,12893,"EcoVadis rating is based on the evaluation of the quality of a company's CSR management system through its policies, actions and results",0,0,0,0,0,0,0,0,0,0,0
SID_365,12894,The following four themes are covered,0,0,0,0,0,0,0,0,0,0,0
SID_365,12895,Environment,0,0,0,0,0,0,0,0,0,0,0
SID_365,12896,Labour and human rights,0,0,0,0,0,0,0,1,0,0,0
SID_365,12897,Business ethics,0,0,0,0,0,0,0,0,0,0,0
SID_365,12898,Sustainable procurement,0,0,0,0,0,0,0,0,0,0,0
SID_365,12899,EcoVadis also allows us to assess the CSR performance of our suppliers and thus encourage a responsible approach throughout our supply chain,0,0,0,0,0,0,0,0,0,0,0
SID_365,12900,"The Arkema Group has ranked among the 4% top performing companies in its sector since 2014, and in the Reporting Period, Arkema continued to rank among the top 4% in its sector",0,0,0,0,0,0,0,0,0,0,0
SID_365,12901,"Other Extra-financial Ratings In addition to our partnerships with TfS and EcoVadis, the Arkema Group works with other sustainability indices and assessments, such as the Standard & Poor's Corporate Sustainability Assessment and the Dow Jones Sustainability Indices, and consistently ranks among the best performing companies in the sector",0,0,0,0,0,0,0,1,0,0,0
SID_365,12902,More details of our extra financial ratings can be found here,0,0,0,0,0,0,0,0,0,0,0
SID_365,12903,"ATTESTATION In accordance with the requirements of the FCLA, and in particular section 11 thereof, I attest that I have reviewed the information contained in this report for the entities listed below",0,0,0,0,0,0,0,0,0,0,0
SID_365,12904,"Based on my knowledge, and having exercised reasonable diligence, I attest that the information in this report is true, accurate and complete in all material respects for the purposes of the FCLA, for the reporting year ended on December 31, 2023",0,0,0,0,0,0,0,0,0,0,0
SID_365,12905,"I have the authority to bind Arkema Canada, Arkema Inc, and Bostik Canada Ltd Anthony ODonovan President and Chief Executive Officer Arkema Canada Inc./ Arkema Inc",0,1,0,0,0,0,0,0,0,0,0
SID_365,12906,"May 28, 2024",0,0,0,0,0,0,0,0,0,0,0
SID_365,12907,ENDNOTES,0,0,0,0,0,0,0,0,0,0,0
SID_365,12908,"i More specifically, references herein to the Arkema Group or to Arkema Affiliates shall include each of the Reporting Entities, Arkema France, and all affiliated and/or related entities",0,0,0,0,0,0,0,0,0,0,0
SID_365,12909,ii https://www.arkema.com/usa/en/arkema-united-states/at-a-glance/ iii https://www.arkema.com/canada/en/,0,0,0,0,0,0,0,0,0,0,0
SID_366,12910,Magna International Inc Report on Fighting Against Forced Labour and Child Labour in Supply Chains May 2024,0,0,0,0,0,0,0,0,0,0,0
SID_366,12911,About Magna International Inc,0,0,0,0,0,0,0,0,0,0,0
SID_366,12912,"Our Structure & Activities Magna International Inc is a company incorporated under the laws of the Province of Ontario, Canada",0,0,0,1,0,0,0,0,0,0,0
SID_366,12913,"Our registered and head office is located at 337 Magna Drive, Aurora, Ontario, Canada L4G 7K1",0,0,0,1,0,0,0,0,0,0,0
SID_366,12914,"Our Common Shares trade on the Toronto Stock Exchange under the trading symbol MG, and the New York Stock Exchange under the trading symbol MGA",0,0,0,0,0,0,0,0,0,0,0
SID_366,12915,We are a mobility technology company and one of the worlds largest suppliers in the automotive space,0,0,0,0,1,0,0,0,0,0,0
SID_366,12916,"As of the date of this Report, our global network includes 343 manufacturing and assembly operations and 105 product development, engineering, and sales (PDE&S) centres in 28 countries.1 We have a global, entrepreneurial-minded team of over 179,000 employees.2",0,0,0,1,1,0,0,0,0,0,0
SID_366,12917,"We have complete vehicle engineering and contract manufacturing expertise, as well as product capabilities which include body, chassis, exterior, seating, powertrain, active driver assistance, electronics, mechatronics, mirrors, lighting, and roof systems",0,0,0,0,1,0,0,0,0,0,0
SID_366,12918,Magna also has electronic and software capabilities across many of these areas,0,0,0,0,1,0,0,0,0,0,0
SID_366,12919,"Our business is managed under four operating segments which have been determined on the basis of technological opportunities, product similarities, as well as market and operating factors, as follows",0,0,0,0,1,0,0,0,0,0,0
SID_366,12920,Body Exteriors & Structures,0,0,0,0,1,0,0,0,0,0,0
SID_366,12921,Seating Systems,0,0,0,0,1,0,0,0,0,0,0
SID_366,12922,Power & Vision,0,0,0,0,1,0,0,0,0,0,0
SID_366,12923,Complete Vehicles,0,0,0,0,1,0,0,0,0,0,0
SID_366,12924,"A more detailed description of our company, products and activities can be found in our Annual Information Form, which is available on Magnas website www.magna.com",0,0,0,0,0,0,0,0,0,0,0
SID_366,12925,Manufacturing operations and PDES centres include certain operations accounted for under the equity method,0,0,0,0,1,0,0,0,0,0,0
SID_366,12926,"Number of employees includes over 168,000 employees at our wholly owned or controlled entities and over 11,000 employees at certain operations accounted for under the equity method",0,0,0,1,0,0,0,0,0,0,0
SID_366,12927,"About this Report This joint report (the Report) is made pursuant to subsection 11(2) of the Fighting Against Forced Labour and Child Labour Supply Chains Act, S.C",0,0,0,0,0,0,0,0,0,0,0
SID_366,12928,"2023 c.9 (the Act) and has been prepared by Magna International Inc for itself and the subsidiaries listed in Appendix A (collectively, Magna)",0,0,0,1,0,0,0,0,0,0,0
SID_366,12929,"This Report summarizes the steps that Magna has taken in the financial year ended December 31, 2023 to prevent and reduce the risk of forced labour or child labour within our operations and supply chain",0,0,0,0,0,0,0,0,0,0,0
SID_366,12930,"The terms we, our, us, Company, and Magna used in this Report refer collectively to Magna International Inc and the applicable controlled entities, unless otherwise noted",0,0,0,0,0,0,0,0,0,0,0
SID_366,12931,"Contact Us: If you have any inquiries concerning this Report, please contact sustainability@magna.com",0,0,0,0,0,0,0,0,0,0,0
SID_366,12932,"Our Supply Chain Magna designs, engineers and manufacture components, assemblies, systems, subsystems, and modules for original equipment manufacturers (OEMs or automobile manufacturers) of vehicles and light trucks",0,0,0,0,1,0,0,0,0,0,0
SID_366,12933,"As a Tier 1 supplier, we source subcomponents from Tier 2 and other sub-suppliers, which are integrated into the products sold by us directly to OEMs Due to the number and complexity of the products we manufacture, Magnas supply chains consists of a substantial number of suppliers globally, the composition of which changes within each calendar year and from year to year",0,0,0,0,0,1,0,0,0,0,0
SID_366,12934,"In 2023, we had approximately 10,000 direct materials/goods suppliers (representing approximately 7,000 supplier parent entities), with approximately 1,300 such suppliers providing goods/commodities directly to Canada",0,0,0,0,1,0,0,0,0,0,0
SID_366,12935,Our top categories of materials/goods purchased in Canada for the fiscal year ended 2023 were: steel (approximately 22%); stampings (approximately 22%); electronics (approximately 10%); resins/plastics (approximately 11%); and aluminum (approximately 5%),0,0,0,0,1,0,0,0,0,0,0
SID_366,12936,Our Policies and Processes to Combat,0,0,0,0,0,0,0,0,0,0,0
SID_366,12937,Forced/Child Labour,0,0,0,0,0,0,0,0,0,0,0
SID_366,12938,Magnas Values and Commitment to Respecting Human Rights Respect for human rights is a part of our core company values and we recognize our responsibility with respect to preventing forced/child labour and promoting socially responsible business practices,0,0,0,0,0,0,0,0,0,0,0
SID_366,12939,We are committed to conducting business in a legal and ethical manner globally and we seek to fully comply with all applicable labor and other laws in all jurisdictions in which we operate,0,0,0,0,0,0,0,0,0,0,0
SID_366,12940,"We hold our own employees to high ethical standards and expect the same commitment of our suppliers, vendors, consultants, independent contractors, agents, or any third party engaged on our behalf (collectively, suppliers)",0,0,0,0,0,0,0,0,0,0,0
SID_366,12941,"We expect that Magna personnel and suppliers will always act with integrity by obeying the letter and spirit of laws, regulations, standards and Magna policies that apply to them, wherever they do business",0,0,0,0,0,0,0,0,0,0,0
SID_366,12942,A failure by any of our suppliers to comply with its terms can result in the termination by Magna of the supply relationship,0,0,0,0,0,0,0,0,1,0,0
SID_366,12943,"Governance Several of Magnas Corporate functions centrally manage policies and, in some cases, implementation of activities aimed at social risks generally, and forced/child labour risk in particular",0,0,0,0,0,0,0,1,0,0,0
SID_366,12944,These include,0,0,0,0,0,0,0,0,0,0,0
SID_366,12945,"Magna's global Human Resources function (including Magnas Health, Safety and Environmental department), is responsible for ensuring respect for working conditions and employment standards compliance, human rights, safety and employee wellness, as well as environmental standards, within our own business, as well as managing various due diligence and audit processes",0,0,0,0,0,0,0,0,0,0,0
SID_366,12946,"Magnas global Purchasing function (including its Supplier Management function), is responsible for directing due diligence processes within the supplier base",0,0,0,0,0,0,0,0,0,0,0
SID_366,12947,"The Supplier Management team leads a cross-functional working group that includes representation from legal, ethics and compliance, human resources, sustainability and other functions that determines Magnas standards for its suppliers and oversees global implementation of key due diligence and other supply chain activities",0,0,0,0,0,0,0,0,0,0,0
SID_366,12948,"our Ethics and Compliance function oversees our ethics and compliance program, updates to key policies such as our Code of Conduct, and Supplier Code, and Ethics and Compliance training, as well as related investigations and remedial action",0,0,0,0,0,0,0,0,0,0,0
SID_366,12949,other specialist functions provide regular and ad-hoc reports to their function leadership; and,0,0,0,0,0,0,0,0,0,0,0
SID_366,12950,"overall support for ESG policy, practices and initiatives is also provided by our global Sustainability team",0,0,0,0,0,0,0,0,0,0,0
SID_366,12951,"Magnas Compliance Council (Compliance Council), a body that includes key corporate officers representing our finance, legal, human resources, operations, internal audit, sales and marketing, technology, information, research and development, and compliance functions, supervises our ethics and compliance program",0,0,0,0,0,0,0,0,0,0,0
SID_366,12952,The Compliance Council also ensures that the required elements of our Program are being carried out globally by our cross-functional Operating Group Compliance Committees,0,0,0,0,0,0,0,0,0,0,0
SID_366,12953,Day-to-day responsibility for effective implementation and execution of compliance activities relating to human rights are managed by each of Magna's Operating Groups and their respective business divisions and partners within our overall policy framework and with the support of the Magna Corporate functions referred to above,0,0,0,0,0,0,0,0,0,0,0
SID_366,12954,"Board-level oversight is provided by the Governance, Nominating and Sustainability Committee of Magnas Board of Directors (with respect to supply chain risks) and the Talent Oversight and Compensation Committee (with respect to health and safety risks and social risks related to our own workforce)",0,0,0,0,0,0,0,0,0,0,0
SID_366,12955,Our Audit Committee oversees our global compliance program,0,0,0,0,0,0,0,0,0,0,0
SID_366,12956,"Key Policies Supporting Our Commitment Magna maintains a policy framework that clearly and unequivocally prohibits forced/child labour, promotes socially responsible business practices, and is designed to protect and recognize the fundamental rights of workers as key stakeholders in our business",0,0,0,0,0,0,0,1,0,0,0
SID_366,12957,"While we operate in a number of jurisdictions with a range of different laws, Magnas policy framework applies equally to all our operations across the globe to establish a common and consistent baseline for the fair treatment of our own employees, as well as those in our supply chain",0,0,0,0,0,0,0,1,0,0,0
SID_366,12958,The key policies supporting our commitment to human rights are Magnas,0,0,0,0,0,0,0,0,0,0,0
SID_366,12959,"Employees Charter: Our Employees Charter sets out our philosophy of fairness and concern for people including through the following principles: Job Security; a Safe & Healthful Workplace; and Fair Treatment with equal opportunities based on an individuals qualifications and performance, free from discrimination or favouritism",0,0,0,0,0,0,0,1,0,0,0
SID_366,12960,Code of Conduct and Ethics (Code of Conduct),0,0,0,0,0,0,0,0,0,0,0
SID_366,12961,"Our Code of Conduct, which applies equally to all our directors, executive officers and employees, articulates our compliance-oriented values and expectations",0,0,0,0,0,0,0,0,0,0,0
SID_366,12962,"The Code addresses standards of conduct in a number of specific areas, including: conducting business with integrity; fairness and respect; complying with all laws and regulations; diversity and inclusion; and respect for human rights, including fair working conditions and prohibitions against slavery and forced/child labour",0,0,0,0,0,0,0,1,0,0,0
SID_366,12963,"It also addresses how to report suspected violations of the Code, and prohibits retaliation against persons who report such violations in good faith",0,0,0,0,0,0,0,1,0,0,0
SID_366,12964,Supplier Code of Conduct (Supplier Code): Our Supplier Code is a foundational document in our business relationships with suppliers,0,0,0,0,0,0,0,0,0,0,0
SID_366,12965,"It outlines the human rights, labour and other standards we require every entity that supplies goods or services to Magna to adhere to, even in jurisdictions where meeting such standards may not be considered part of the usual business culture",0,0,0,0,0,0,0,1,0,0,0
SID_366,12966,"Such standards include similar requirements as our internally applied Code of Conduct, including the prohibition against using forced/child labour",0,0,0,0,0,0,0,1,0,0,0
SID_366,12967,A failure to comply with our Supplier Code can result in the termination by Magna of the supply relationship,0,0,0,0,0,0,0,0,1,0,0
SID_366,12968,"Global Labour Standards: All Magna employees and suppliers are required to abide by our Global Labour Standards, which articulate our commitment to various internationally recognized frameworks that govern workers' rights, including the UN Universal Declaration of Human Rights, ILO Fundamental Conventions (which include conventions prohibiting forced and child labour-related practices), and ILO Declaration on Fundamental Principles and Rights at Work",0,0,0,0,0,0,0,1,0,0,0
SID_366,12969,The Global Labour Standards have been incorporated into our Supplier Code,0,0,0,0,0,0,0,1,0,0,0
SID_366,12970,"Global Company Statement Regarding Human Rights & Environmental Standards (Human Rights Statement): Our Human Rights Statement is a comprehensive summary of Magnas values and commitment regarding human rights and environmental standards, and internal and supply chain requirements",0,0,0,0,0,0,0,0,0,0,0
SID_366,12971,The Statement also outlines our risk assessment and risk management process with respect to human rights and environmental risks,0,0,0,0,0,0,0,0,0,0,0
SID_366,12972,"Global Policy regarding use of Temporary Staffing & Employment Agencies, Recruiting Firms and Labour Brokers (Staffing Agency Policy): The Staffing Agency Policy sets out requirements and best practices when doing business with third party vendors supplying labour-related services to Magna, including: due diligence requirements; prohibition on the use of all forms of debt bondage arrangements; transparency in employment terms; and verification processes related to contract workers employment conditions",0,0,0,0,0,0,0,1,0,0,0
SID_366,12973,We also maintain a number of other comprehensive human rights related policies that prohibit discrimination and harassment and country specific Employee Policy Manuals & Contract Terms that are aimed at compliance with applicable laws,0,0,0,0,0,0,0,0,0,0,0
SID_366,12974,"Local employee policy manuals consistently reflect local hiring policies and practices that prohibit both forced and child labour, and contain operational procedures that include robust worker identification requirements, minimum working age policies, policies on the legal and ethical employment of young workers in educational programs, and provide oversight for hours of work and overtime practices to ensure that employment is free and voluntary in nature",0,0,0,0,0,0,0,1,0,0,0
SID_366,12975,"Such manuals also have substantive human rights policies addressing the prohibition of harassment, discrimination and/or workplace violence/bullying, together with proactive complaint and investigation procedures, reinforced with guarantees of no retaliation against whistleblowers",0,0,0,0,0,0,0,1,0,0,0
SID_366,12976,Our key policies can be found at: https://www.magna.com/company/company- information/leadership-and-governance/corporate-governance-documents,0,0,0,0,0,0,0,0,0,0,0
SID_366,12977,"Risk of Forced/Child Labour Being Used and Steps Taken to Prevent and Reduce such Risk We believe that the risk of forced/child labour is generally lower in our own operations due to our: robust policy framework and practices; well-established Human Resources program, including HR due diligence/audit programs; and compliance-oriented values, including our long- standing philosophy of fairness and concern for our people and respect for the inherent rights of workers",0,0,0,0,0,0,1,0,0,0,0
SID_366,12978,"We have identified certain areas of our supply chain that carry the potential risk of forced/child labour, based on a range of sources, including",0,0,0,0,0,0,0,1,0,0,0
SID_366,12979,regulatory guidance or legislation (eg The Uyghur Forced Labor Prevention Act (UFLPA) in the United States),0,0,0,0,0,0,0,1,0,0,0
SID_366,12980,publicly available non-governmental external data sources,0,0,0,0,0,0,0,1,0,0,0
SID_366,12981,information learned through our participation in industry associations; and,0,0,0,0,0,0,0,1,0,0,0
SID_366,12982,third-party supplier risk assessment tools,0,0,0,0,0,0,0,1,0,0,0
SID_366,12983,"While we monitor all our suppliers using a third-party live-monitoring platform, our Supplier Management function has identified certain categories of goods requiring enhanced due diligence, including aluminum, electronics, polysilicon, and steel",0,0,0,0,0,0,1,1,0,0,0
SID_366,12984,We cross-check categories we have identified against the U.S,0,0,0,0,0,0,0,1,0,0,0
SID_366,12985,"Department of Labor List of Goods Produced by Child Labor or Forced Labor and its List of Products Produced by Forced or Indentured Child Labor, as well as the high-priority sectors identified by the U.S",0,0,0,0,0,0,0,1,0,0,0
SID_366,12986,Department of Homeland Securitys Forced Labor Enforcement Task Force,0,0,0,0,0,0,0,1,0,0,0
SID_366,12987,Knowledge gained from these risk assessment measures and through other sources such as our global whistleblower Hotline (described below) are continuously incorporated into our risk identification process to improve our due diligence processes,0,0,0,0,0,0,0,1,0,1,0
SID_366,12988,"Due Diligence Processes and Steps Taken to Prevent Forced/Child Labour Risk In 2023 and to date in 2024, Magna has taken the following steps to prevent and reduce the risk that forced labour or child labour is used at any step of the production of goods in Canada or elsewhere by Magna or of goods imported into Canada by Magna",0,0,0,0,0,0,0,1,0,0,0
SID_366,12989,Policy Enhancements,0,0,0,0,0,0,0,0,0,0,0
SID_366,12990,We reviewed key policies addressing human rights including our Supplier Code and implemented new policies including the Human Rights Statement and Staffing Agency Policy Employee Training,0,0,0,0,0,0,0,1,0,0,0
SID_366,12991,We conduct mandatory annual Code of Conduct training for our employees (described below),0,0,0,0,0,0,0,1,0,0,0
SID_366,12992,We have developed the mandatory human rights training modules (discussed below) HR-Related Audits/Due Diligence,0,0,0,0,0,0,0,1,0,0,0
SID_366,12993,"We have implemented a number of HR audit and/or due diligence programs aimed at the protection of the rights of workers and compliance with applicable laws, including",0,0,0,0,0,0,0,1,0,0,0
SID_366,12994,"Employee Opinion Surveys - designed to assess overall employee engagement and satisfaction, identify workplace complaints and issues, and assess employee opinions on a variety of workplace issues ranging from fair treatment, working conditions, diversity and inclusion, and health & well-being",0,0,0,0,0,0,0,1,0,0,0
SID_366,12995,"Wage & Benefits survey process - designed to benchmark industry competitive wage and benefit levels for all job classifications, help ensure that objective and non-discriminatory compensation structures are in place, and to implement remedial compensation adjustments where necessary to ensure both competitive and legally compliant compensation levels are maintained",0,0,0,0,0,0,0,1,0,0,0
SID_366,12996,"Health, Safety & Environmental Audits and Inspections - designed to help ensure the maintenance of legally compliant health, safety and environmental programs, using a coordinated systems of world class audits, inspections and remedial action plan processes",0,0,0,0,0,0,0,0,0,0,0
SID_366,12997,"Payroll & Compensation Audits - conducted through Magnas Internal Audit (IA) teams that review location specific payroll processes to verify that employee compensation meets applicable employment standards, while aligning to hours of work, overtime and payroll record keeping requirements",0,0,0,0,0,0,0,1,0,0,0
SID_366,12998,"Labour & Employment Audits - designed to assess HR compliance-related issues, policies, and practices at the local Divisional level and adherence to both Magna policy and local laws, in a variety of areas, including fair working conditions and prevention of forced and child labour",0,0,0,0,0,0,0,1,0,0,0
SID_366,12999,Magna Hotline which allows employees and other stakeholders to report concerns or suspected violations of Magnas policies or practices,0,0,0,0,0,0,0,1,0,0,0
SID_366,13000,Third Party Labour/Staffing Management,0,0,0,0,0,0,0,0,0,0,0
SID_366,13001,We maintain oversight and due diligence practices with respect to third party labour/staffing agencies including service agreement templates for use with third party labour suppliers to ensure that contingent workers are subject to the same ethical standards applicable to Magnas regular full-time employees,0,0,0,0,0,0,0,1,0,0,0
SID_366,13002,"The service agreement templates include, among other things, requirements to adhere to ethical labour standards, express prohibition on forced or child labour related practices, and robust audit and investigation provisions",0,0,0,0,0,0,0,1,0,0,0
SID_366,13003,We implemented a system for reporting non-compliant third-party labour suppliers which is designed to help ensure that we do not conduct business with prohibited suppliers,0,0,0,0,0,0,0,1,0,0,0
SID_366,13004,"As a result, we terminated business relationships with a number of temporary staffing/labour agencies that did not meet the requirements of our Staffing Agency Policy",0,0,0,0,0,0,0,0,1,0,0
SID_366,13005,"Globally, we conducted over 2600 manpower audits of labour related suppliers",0,0,0,0,0,0,0,0,0,1,0
SID_366,13006,We took the remediatory actions discussed under Remediation Measures below Supplier Engagement,0,0,0,0,0,0,0,0,0,0,0
SID_366,13007,"We routinely communicate and reinforce our expectations and requirements to suppliers through a variety of means, including: dedicated supplier ESG roundtables; direct buyer interactions; live all supplier communications; and information on our Corporate website and supplier information portal Supply Chain Management",0,0,0,0,0,0,0,0,0,0,0
SID_366,13008,"Our Supplier Management function uses a third-party supply chain risk monitoring and mapping tool, which monitors and provides real- time alerts regarding a number of ESG-related categories, including forced/child labour and poor working conditions",0,0,0,0,0,0,0,1,0,0,0
SID_366,13009,We monitor updates to the UFLPA entity list of entities suspected of using Uyghur forced labor and integrate such updates into our third- party monitoring tool,0,0,0,0,0,0,0,1,0,0,0
SID_366,13010,"We require selected suppliers to complete ESG self-assessment questionnaires (SAQs) that cover, among other things: working conditions, human rights and health and safety",0,0,0,0,0,0,0,1,0,0,0
SID_366,13011,In certain circumstances we require suppliers to undergo more comprehensive on-site audits,0,0,0,0,0,0,0,1,0,0,0
SID_366,13012,The SAQs and audits generate corrective action plans for suppliers to complete,0,0,0,0,0,0,0,0,1,0,0
SID_366,13013,We use a scorecard process to provide ongoing monitoring and assessment of suppliers and have developed an ESG component to this process which includes forced/child labour as a critical flag,0,0,0,0,0,0,0,1,0,0,0
SID_366,13014,No production suppliers needed to be terminated in 2023 as a result of a violation of working conditions or human rights,0,0,0,0,0,0,0,0,0,1,0
SID_366,13015,The Supplier Management function maintains an investigation and case management system to gather information and execute control and oversight of any necessary mitigating activities,0,0,0,0,0,0,0,0,0,0,0
SID_366,13016,Reporting Mechanism,0,0,0,0,0,0,0,0,0,0,0
SID_366,13017,We enhanced our Hotline to create a dedicated reporting tier for suppliers,0,0,0,0,0,0,0,1,0,0,0
SID_366,13018,Continuously monitored reports received by our Hotline for matters relating to social/human rights risks,0,0,0,0,0,0,0,0,0,1,0
SID_366,13019,None of the reports submitted to our Hotline have involved forced or child labour related allegations Transparency & Reporting,0,0,0,0,0,0,0,0,0,1,0
SID_366,13020,"We publicly report on our efforts to combat forced/child labour in our annual Sustainability Report and a number of regulatory reports, including this Report which increases transparency and further amplifies the importance of our activities to stakeholders",0,0,0,0,0,0,0,0,0,0,0
SID_366,13021,Mechanisms for Reporting Concerns We have established a robust and comprehensive complaints management process as an integral part of our due diligence procedures,0,0,0,0,0,0,0,1,0,0,0
SID_366,13022,"Our own employees can take advantage of several reporting/resolution mechanisms, including our Open-Door Process whereby employees are empowered to bring issues and concerns forward to leadership at all levels of the organization, without fear of retaliation",0,0,0,0,0,0,0,1,0,0,0
SID_366,13023,Our Open Door Process includes Fairness Committees and an Employee Advocates program in certain of our operations,0,0,0,0,0,0,0,0,0,0,0
SID_366,13024,"In addition to these internal mechanisms, if any stakeholder experiences prohibited treatment or becomes aware of violations of Magna requirements or expectations outlined in our policy framework, they are able to use our whistleblower line, the Magna Hotline; which provides an additional avenue for employees and third parties (including our suppliers) to report suspected violations of Magna's Employees Charter, the Code of Conduct and Ethics, and the Supplier Code",0,0,0,0,0,0,0,1,0,0,0
SID_366,13025,"In a number of our operations globally, our facilities have third party employee representative bodies such as unions and/or works councils, together with formal concern resolution and grievance procedures designed to address workplace related issues",0,0,0,0,0,0,0,1,0,0,0
SID_366,13026,"Where third party representation exists, we work constructively with employee representatives and are jointly committed to the protection and enhancement of workplace rights",0,0,0,0,0,0,0,0,0,0,0
SID_366,13027,"Magna strictly prohibits any form of retaliation against individuals who report legal and ethical concerns in a truthful and good-faith manner, as outlined in our Policy on Anti-Retaliation",0,0,0,0,0,0,0,1,0,0,0
SID_366,13028,"All communications made through the complaints management process are treated confidentially, in accordance with relevant local data protection laws",0,0,0,0,0,0,0,1,0,0,0
SID_366,13029,Anonymity is possible when reporting through the Magna Hotline (if local law permits),0,0,0,0,0,0,0,1,0,0,0
SID_366,13030,"Should an individual voluntarily choose to reveal their identity, Magna will make diligent attempts to preserve confidentiality throughout the investigative procedures",0,0,0,0,0,0,0,0,0,0,0
SID_366,13031,We conduct comprehensive investigations into all reports and reasonable suspicions that are brought to our attention,0,0,0,0,0,0,0,0,1,0,0
SID_366,13032,"Employee Awareness and Training In order to help our employees understand the values, standards and principles underlying our Code, we have implemented a global compliance program overseen by the Audit Committee, which includes training of employees through different modalities (e-learning live in-person, and virtual instructor-led) on various topics relating to compliance and ethics",0,0,0,0,0,0,0,1,0,0,0
SID_366,13033,"Office-based employees complete annual Code of Conduct training, as well as specific training covering subtopics addressed by the Code",0,0,0,0,0,0,0,1,0,0,0
SID_366,13034,"In addition, we have developed and will be rolling out during the first half of 2024, mandatory enhanced compliance training for employees on responsible sourcing and global supply chain laws, covering such issues such as child labour, human trafficking, forced labour, and the responsible use of third party labour brokers",0,0,0,0,0,0,0,1,0,0,0
SID_366,13035,"The training will be mandatory for employees across various functional areas with responsibility for hiring and supplier/vendor selection and oversight, such as Human Resources, Purchasing, Legal, and Quality, as well as other functional leadership",0,0,0,0,0,0,0,1,0,0,0
SID_366,13036,These modules are expected to be rolled out in the first half of 2024,0,0,0,0,0,0,0,0,0,0,0
SID_366,13037,Assessing the Effectiveness of Our Actions We are committed to continuously improving our approach to human rights and continue to assess ways to refine our program and enhance the operationalization of our commitment,0,0,0,0,0,0,0,0,0,0,0
SID_366,13038,"We regularly evaluate our activities to confirm that they remain current and aligned with regulations, industry standards and best practices",0,0,0,0,0,0,0,0,0,0,0
SID_366,13039,"We assess the effectiveness of our activities with respect to forced/child labour in a number of ways, including",0,0,0,0,0,0,0,0,0,1,0
SID_366,13040,Effectiveness assessments conducted at least annually by a cross-functional internal working group,0,0,0,0,0,0,0,0,0,1,0
SID_366,13041,Participation in a number of industry associations that allows us to benchmark best practices regarding activities to prevent forced/labour and identify opportunities for continuous improvement,0,0,0,0,0,0,0,0,0,1,0
SID_366,13042,"For example, we are a founding member of the Responsible Supply Chain Initiative (RSCI), an association of automotive OEMs, Tier 1 Suppliers and industry associations, which has established an assessment program for due diligence in the automotive supply chain relating to social compliance, occupational safety and environmental protection",0,0,0,0,0,0,0,0,0,1,0
SID_366,13043,"Engagement with key stakeholders, such as investors and customers, as well as suppliers through mechanisms such as our Supplier Roundtables",0,0,0,0,0,0,0,0,0,1,0
SID_366,13044,"Feedback from our risk-based audits described in this Report, such as our Employee Opinion Surveys and other HR audit programs",0,0,0,0,0,0,0,0,0,1,0
SID_366,13045,Feedback received from our Board of Directors and its standing committees,0,0,0,0,0,0,0,0,0,1,0
SID_366,13046,Interactive tests included in our employee training modules which give us indicative feedback on the effectiveness of our training activities,0,0,0,0,0,0,0,0,0,1,0
SID_366,13047,Monitoring and analysis of existing and emerging regulatory requirements globally,0,0,0,0,0,0,0,0,0,1,0
SID_366,13048,Monitoring of non-governmental and other public reports related to forced/child labour,0,0,0,0,0,0,0,0,0,1,0
SID_366,13049,Assessments of Magna and/or its Divisions from third-party ESG rankings and customer- required self-assessments or audits,0,0,0,0,0,0,0,0,0,1,0
SID_366,13050,Assessments of the extent to which our suppliers are improving in self-assessment questionnaires or on-site audits or implementing corrective actions; and,0,0,0,0,0,0,0,0,0,1,0
SID_366,13051,"Ongoing monitoring of reports received through the reporting mechanisms described in this Report, including the Magna Hotline",0,0,0,0,0,0,0,0,0,1,0
SID_366,13052,Remediation Measures We identified one reportable matter in the reporting year,0,0,0,0,0,0,0,0,0,0,0
SID_366,13053,A description of the matter and our remediation activities is as follows,0,0,0,0,0,0,0,0,0,0,0
SID_366,13054,"During 2023, an Ontario Ministry of Labour (MOL) inspection at a division of one of our Ontario subsidiaries alerted Magna to potential concerns related to abusive and/or illegal practices by temporary staffing agencies operating in Simcoe County area",0,0,0,0,0,0,1,0,0,0,0
SID_366,13055,"We determined that the Magna Division had no relationship with either of the staffing agencies, and as a result the MOL inspection triggered no findings of concern",0,0,0,0,0,0,1,0,0,0,0
SID_366,13056,"Nonetheless, we proactively launched our own internal investigation centered on a third-party staffing agency that was occasionally contracted by the same Magna Division to help provide temporary worker placements",0,0,0,0,0,0,0,1,0,0,0
SID_366,13057,"Through the internal investigation Magna learned of the possibility that workers ineligible to be in Canada, and potentially vulnerable to exploitation, were illegally presented for temporary placements, in clear violation of the agencys contractual obligations to the Magna Division",0,0,0,0,0,0,1,0,0,0,0
SID_366,13058,"As a result, Magna took a number of remediatory steps, including",0,0,0,0,0,0,0,0,1,0,0
SID_366,13059,proactively contacting Ontario Victims Services to offer our support for the temporary workers involved,0,0,0,0,0,0,0,0,1,0,0
SID_366,13060,self-reported immediately to the MOL to ensure the Ministry was fully aware of the facts uncovered by Magnas investigation,0,0,0,0,0,0,0,0,1,0,0
SID_366,13061,self-reported and provided investigative material of assistance to both the York Regional Police (YRP) and the Canada Border Services Agency (CBSA) to help support their criminal investigation of those parties seeking to take advantage of vulnerable workers,0,0,0,0,0,0,0,0,1,0,0
SID_366,13062,terminated our services agreement with third party agency in question,0,0,0,0,0,0,0,0,1,0,0
SID_366,13063,"took steps to confirm this was an isolated incident and that no other examples of such non- compliance existed in any of our operations elsewhere, particularly where staffing agencies might have been used",0,0,0,0,0,0,0,1,0,0,0
SID_366,13064,"introduced additional compliance measures to strengthen our existing internal controls and oversight, particularly concerning protocols for contracted staffing agencies; and",0,0,0,0,0,0,0,1,0,0,0
SID_366,13065,made proactive contact with YRP and the CBSA to share the results of our internal investigation with a view to ensuring that anyone acting wrongly might be held to account,0,0,0,0,0,0,0,0,1,0,0
SID_366,13066,This information helped to alert the YRP and CBSA to possible bad actors apart from those they had already identified,0,0,0,0,0,0,0,0,1,0,0
SID_366,13067,"We also maintain the oversight and due diligence practices with respect to third-party staffing/temporary labour agencies, discussed in this elsewhere in this Report",0,0,0,0,0,0,0,1,0,0,0
SID_366,13068,"At all times, the Magna division in question paid the temporary agency involved fees that met or exceeded all requirements under the Ontarios Employment Standards legislation for purposes of properly compensating the temporary workers placed at the Magna Division those wages required to be compliance with local laws",0,0,0,0,0,0,0,1,0,0,0
SID_366,13069,Any shortfall in wages suffered by the affected workers at the hands of the non-compliant agency was unknown to Magna or its division,0,0,0,0,0,0,0,0,0,0,0
SID_366,13070,"Nonetheless, Magna, on a good faith and compassionate basis, proceeded to fully compensate those workers confirmed to have been temporarily placed at the division, who had been taken advantage of as a result of unethical employment practices of their hiring agency",0,0,0,0,0,0,0,0,1,0,0
SID_366,13071,"Approval and Attestation This Report was approved by Magnas Board of Directors on May 2, 2024",1,0,0,0,0,0,0,0,0,0,0
SID_366,13072,"In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for the entity or entities listed above",0,0,0,0,0,0,0,0,0,0,0
SID_366,13073,"Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above",0,0,0,0,0,0,0,0,0,0,0
SID_366,13074,"Seetarama (Swamy) Kotagiri Chief Executive Officer and Board Member Magna International Inc On behalf of the Board of Directors of Magna International Inc May 2, 2024",0,1,0,0,0,0,0,0,0,0,0
SID_366,13075,Appendix A Reporting Entities Covered By this Joint Report,0,0,0,1,0,0,0,0,0,0,0
SID_366,13076,Parent Company,0,0,0,1,0,0,0,0,0,0,0
SID_366,13077,Magna International Inc Controlled Subsidiaries,0,0,0,1,0,0,0,0,0,0,0
SID_366,13078,Magna Closures Inc,0,0,0,1,0,0,0,0,0,0,0
SID_366,13079,Magna Exteriors Inc,0,0,0,1,0,0,0,0,0,0,0
SID_366,13080,Magna Powertrain Inc,0,0,0,1,0,0,0,0,0,0,0
SID_366,13081,Magna Seating Inc,0,0,0,1,0,0,0,0,0,0,0
SID_366,13082,"Magna Seating of America, Inc",0,0,0,1,0,0,0,0,0,0,0
SID_368,13083,MODERN SLAVERY REPORT (2024) This modern slavery report (Report) is made by MEG Energy Corp (MEG or the Corporation) pursuant to the Fighting Against Forced Labour and Child Labour in Supply Chains Act (Act),0,0,0,0,0,0,0,0,0,0,0
SID_368,13084,"This Report outlines the approach and actions MEG has taken to identify, assess and address modern slavery risks across our operations and supply chains for the financial year ending December 31, 2023 (Reporting Period)",0,0,0,0,0,0,0,0,0,0,0
SID_368,13085,It sets out our progress to date and future commitments,0,0,0,0,0,0,0,0,0,0,0
SID_368,13086,"Commitment Against Modern Slavery MEG is committed to high ethical conduct and values, including a firm prohibition against any form of exploitation including slavery, servitude, forced labour, child labour and human trafficking (together Modern Slavery) in its business operations and supply chains",0,0,0,0,0,0,0,0,0,0,0
SID_368,13087,"MEG promotes a culture of sustainable, responsible development and respect for human dignity in the conduct of its business",0,0,0,0,0,0,0,0,0,0,0
SID_368,13088,"In addition, MEG expects that its affiliates, directors, officers, employees, contractors, suppliers and service providers conduct their business practices in accordance with MEGs values and requires that suppliers and service providers agree, in their contractual arrangements with MEG, to abide by the principles set out in MEGs policies, including MEGs Business Conduct Charter and Human Rights Policy Statement which prohibit Modern Slavery",0,0,0,0,0,0,0,1,0,0,0
SID_368,13089,"Steps Taken in 2023 to Prevent and Reduce Risks of Forced Labour and Child Labour In general terms, MEG took the following steps during the Reporting Period to prevent and reduce the risk of forced labour or child labour in its business and supply chains",0,0,0,0,0,0,0,1,0,0,0
SID_368,13090,"formed a working group comprised of management representatives from Legal and Supply Chain Management (SCM) to review the impact of the Act on MEG and assess the effectiveness of the governance structure, policies, and procedures of MEG to address the risks of forced labour or child labour",0,0,0,0,0,0,0,1,0,0,0
SID_368,13091,mapped our tier 1 suppliers and self-assessed those posing the most risk based on jurisdiction; and,0,0,0,0,0,0,0,1,0,0,0
SID_368,13092,provided first-time training to front line SCM employees to raise awareness of Modern Slavery indicators via the Supply Chain Canada training webinar,0,0,0,0,0,0,0,1,0,0,0
SID_368,13093,Details of the above actions are set out in this report,0,0,0,0,0,0,0,0,0,0,0
SID_368,13094,"MEGs Structure, Activities & Supply Chains MEG is an energy company focused on sustainable in situ thermal oil production in the southern Athabasca oil region of Alberta, Canada",0,0,0,0,1,0,0,0,0,0,0
SID_368,13095,MEG is actively developing innovative enhanced oil recovery projects that utilize steam-assisted gravity drainage (SAGD) extraction methods to improve the responsible economic recovery of oil as well as lower carbon emissions,0,0,0,0,1,0,0,0,0,0,0
SID_368,13096,MEG transports and sells thermal oil known as Access Western Blend or AWB to customers throughout North America and internationally,0,0,0,0,1,0,0,0,0,0,0
SID_368,13097,"Located in the southern Athabasca region, MEGs Christina Lake Project is a multi-phased project, located 150 kilometres south of Fort McMurray in northeast Alberta",0,0,0,0,1,0,0,0,0,0,0
SID_368,13098,Comprised of approximately 200 square,0,0,0,0,0,0,0,0,0,0,0
SID_368,13099,"MODERN SLAVERY REPORT kilometres of leases, this SAGD operation currently has regulatory approvals in place to produce approximately 210,000 bpd",0,0,0,0,1,0,0,0,0,0,0
SID_368,13100,"MEG was incorporated on March 9, 1999, under the Business Corporations Act (Alberta)",0,0,0,1,0,0,0,0,0,0,0
SID_368,13101,"MEG's head office is located at 25th Floor, 600 3rd Avenue S.W., Calgary, Alberta, Canada T2P 0G5",0,0,0,1,0,0,0,0,0,0,0
SID_368,13102,"As of December 31, 2023, MEG employed 449 full time permanent employees and 2 part-time permanent employees",0,0,0,1,0,0,0,0,0,0,0
SID_368,13103,MEG also engaged approximately 830 contractors and service providers directly for services and materials in the Reporting Period,0,0,0,0,0,1,0,0,0,0,0
SID_368,13104,"MEG Energy (U.S.) Inc (MEG US), a wholly-owned subsidiary of the Corporation, was incorporated on June 26, 2012, under the Delaware General Corporation Law",0,0,0,1,0,0,0,0,0,0,0
SID_368,13105,MEG US is the corporate vehicle used for the Corporation's hydrocarbon marketing-related activities in the United States,0,0,0,1,0,0,0,0,0,0,0
SID_368,13106,MEG US does not have employees or supply chains separate from MEG,0,0,0,1,0,0,0,0,0,0,0
SID_368,13107,The following organizational chart illustrates the current intercorporate relationship of the Corporation and MEG US,0,0,0,0,0,0,0,0,0,0,0
SID_368,13108,Further information about MEGs operations is available at www.megenergy.com,0,0,0,0,0,0,0,0,0,0,0
SID_368,13109,"Our supply chain includes the purchase of natural gas, chemicals, and diluent used in our production processes, and the purchase of equipment and other capital-intensive assets, including pipe, valves pumps, generators, turbines and other equipment common to in situ SAGD producers",0,0,0,0,0,1,0,0,0,0,0
SID_368,13110,"The vast majority of MEGs direct suppliers are located in North America, with only approximately 17 direct suppliers located outside of North America",0,0,0,0,0,1,0,0,0,0,0
SID_368,13111,MEGs international suppliers are located primarily in Europe and Asia,0,0,0,0,0,1,0,0,0,0,0
SID_368,13112,MEG engaged approximately 830 contractors and service providers directly for services and materials in the Reporting Period,0,0,0,0,0,1,0,0,0,0,0
SID_368,13113,"To the best of our knowledge, MEG does not source goods and/or services from the following ten countries, which are identified as having highest prevalence of modern slavery according to the 2023 Global Slavery Index (as applicable)",0,0,0,0,0,0,0,0,0,0,0
SID_368,13114,North Korea,0,0,0,0,0,0,0,0,0,0,0
SID_368,13115,Eritrea,0,0,0,0,0,0,0,0,0,0,0
SID_368,13116,Mauritania,0,0,0,0,0,0,0,0,0,0,0
SID_368,13117,Saudi Arabia,0,0,0,0,0,0,0,0,0,0,0
SID_368,13118,Turkey,0,0,0,0,0,0,0,0,0,0,0
SID_368,13119,Tajikistan,0,0,0,0,0,0,0,0,0,0,0
SID_368,13120,United Arab Emirates,0,0,0,0,0,0,0,0,0,0,0
SID_368,13121,Russia,0,0,0,0,0,0,0,0,0,0,0
SID_368,13122,Afghanistan,0,0,0,0,0,0,0,0,0,0,0
SID_368,13123,Kuwait,0,0,0,0,0,0,0,0,0,0,0
SID_368,13124,MODERN SLAVERY REPORT Potential Modern Slavery Risks in Our Operations and Supply Chains,0,0,0,0,0,0,0,0,0,0,0
SID_368,13125,"Operations MEGs operations require a wide variety of goods and services to operate, the vast majority of which are produced with higher-skilled and trained labour forces, including engineering, finance, and geoscientific services as well as specialized equipment and services for in situ SAGD oil production and transportation",0,0,0,0,1,0,0,0,0,0,0
SID_368,13126,"In our operations, we do not use forced or compulsory workers and such practices are illegal in the jurisdictions in which we operate",0,0,0,0,0,0,0,0,0,0,0
SID_368,13127,"Our employees are above the legal employment age in Canada and are recruited and provided with working conditions, wages and benefits that comply with Canadian laws and regulations, including those laws and regulations related to employment, labour and occupational health and safety",0,0,0,0,0,0,0,1,0,0,0
SID_368,13128,Canada is considered a low-risk jurisdiction for Modern Slavery risks according to the Global Slavery Index,0,0,0,0,0,0,0,0,0,0,0
SID_368,13129,"Our operations are complex and sophisticated and as a result, the majority of our employees and contractors are highly skilled professionals and technical labour",0,0,0,0,1,0,0,0,0,0,0
SID_368,13130,We consider the risk of Modern Slavery in our workforce to be low,0,0,0,0,0,0,0,0,0,0,0
SID_368,13131,ii,0,0,0,0,0,0,0,0,0,0,0
SID_368,13132,"Supply Chains To support our operations, our technical business units and supply chain management functions steward the acquisition of goods and services from third parties, including engineering, procurement, and construction services, general maintenance and support services, chemicals, drilling services and equipment, transportation and logistics services, operations support services, electrical and electronic equipment, and staffing agencies",0,0,0,0,0,1,0,0,0,0,0
SID_368,13133,"In our supply chains, a risk of Modern Slavery may exist where contractors and subcontractors conduct operations in countries with weak governance and regulatory oversight, a poor human rights track record and/or require the employment of low-skilled, physical labour",0,0,0,0,0,0,1,0,0,0,0
SID_368,13134,"We identify and assess the risk of Modern Slavery through our supply chain management processes by conducting a risk-based review, which identifies suppliers in higher risk geographic jurisdictions",0,0,0,0,0,0,0,1,0,0,0
SID_368,13135,"Based on our review, and to the best of MEGs knowledge, we have not identified suppliers and goods in our supply chain that present a high-risk potential of engaging in practices associated with Modern Slavery",0,0,0,0,0,0,1,0,0,0,0
SID_368,13136,"MEG acknowledges that it lacks visibility in respect to some of its suppliers located internationally, including indirect suppliers (ie the suppliers of MEGs direct suppliers)",0,0,0,0,0,0,0,0,0,0,0
SID_368,13137,"MEG will continue to work to further identify, understand and ultimately mitigate the risks of modern slavery in its supply chains",0,0,0,0,0,0,0,0,0,0,0
SID_368,13138,"Policies in Relation to Modern Slavery MEGs Business Conduct Charter and MEGs Human Rights Policy Statement prohibit Modern Slavery and set out MEGs commitment to ensuring human rights are respected in the conduct of all its activities, including",0,0,0,0,0,0,0,1,0,0,0
SID_368,13139,MODERN SLAVERY REPORT,0,0,0,0,0,0,0,0,0,0,0
SID_368,13140,"prohibiting all types of discrimination and harassment of minorities, including on the basis of gender identity or expression, race, or other minority status",0,0,0,0,0,0,0,0,0,0,0
SID_368,13141,prohibiting Modern Slavery in MEGs business operations and supply chains,0,0,0,0,0,0,0,1,0,0,0
SID_368,13142,"respecting the fundamental freedoms of all individuals, including the freedom of thought, belief, opinion and expression, the freedom of peaceful assembly, the freedom of association and collective bargaining, and other rights and freedoms enshrined in the UN Universal Declaration of Human Rights and the Canadian Charter of Rights and Freedoms",0,0,0,0,0,0,0,0,0,0,0
SID_368,13143,"ensuring safe, secure and healthy working conditions for all employees, contractors, and direct suppliers in accordance with applicable laws and best industry practices; and",0,0,0,0,0,0,0,1,0,0,0
SID_368,13144,ensuring security policies and guidelines are consistent with applicable laws and best industry practices,0,0,0,0,0,0,0,1,0,0,0
SID_368,13145,"Measures Taken to Assess and Manage Risks of Modern Slavery MEG uses several strategies and processes to assess and mitigate Modern Slavery risks, including",0,0,0,0,0,0,0,1,0,0,0
SID_368,13146,providing access to MEGs Business Conduct Charter and Human Rights Policy Statement to all new and existing employees and contractors,0,0,0,0,0,0,0,1,0,0,0
SID_368,13147,MEG also intends to provide a copy of this Report to all of our employees and contractors,0,0,0,0,0,0,0,0,0,0,0
SID_368,13148,monitoring compliance by annually requiring employees and contractors to: (i) acknowledge their own compliance with all policies; and (ii) affirm they are not aware of non-compliance by others,0,0,0,0,0,0,0,1,0,0,0
SID_368,13149,"providing ready access for employees, contractors, suppliers, and other stakeholders to anonymous and secure communication and reporting channels that allow them to safely notify MEG of actual or potential breaches of MEGs Business Conduct Charter and Human Rights Policy, including via MEGs confidential and anonymous Business Conduct Helpline",0,0,0,0,0,0,0,1,0,0,0
SID_368,13150,"reviewing and assessing MEGs policies, practices and procedures regarding Modern Slavery and human rights generally to ensure their ongoing relevance and alignment with MEGs overall business strategies",0,0,0,0,0,0,0,0,0,1,0
SID_368,13151,"requiring suppliers to adhere to Canadian safety standards, including compliance with the Labour Code and WHMIS when working in our operations, emphasizing employee safety and environmental protection",0,0,0,0,0,0,0,1,0,0,0
SID_368,13152,"assessing select supplier safety and quality assurance, quality control processes, and product testing for continuous improvement",0,0,0,0,0,0,0,0,0,0,0
SID_368,13153,"on a risk-based approach, evaluating suppliers' capacity, production capabilities, and logistical processes to meet our demand, incorporating contingency planning to ensure flexibility and robust operations; and",0,0,0,0,0,0,0,0,0,0,0
SID_368,13154,commencing the development of a program to provide training and increase awareness of Modern Slavery risks to employees on an annual basis,0,0,0,0,0,0,0,1,0,0,0
SID_368,13155,"Remediation During the Reporting Period, MEG did not have to take any measures to remediate any forced labour or child labour or remediate any loss of income incurred by vulnerable families as we did not identify any Modern Slavery in our operations or in our direct supply chains",0,0,0,0,0,0,1,0,1,0,0
SID_368,13156,"MODERN SLAVERY REPORT Should MEG identify that a loss of income has occurred to victim(s) as a result of any measures taken to eliminate Modern Slavery risks in its activities and supply chains, it will seek to take appropriate actions to remediate the loss to the victims",0,0,0,0,0,0,0,0,0,0,0
SID_368,13157,"Training During the Reporting Period, MEG provided first-time training to front line SCM employees to raise awareness of Modern Slavery indicators via the Supply Chain Canada training webinar, which discussed steps that organizations can take to identify, manage and prevent Modern Slavery and also explored how organizations can effectively operationalize and incorporate supply chain due diligence into their ESG programs and strategies",0,0,0,0,0,0,0,1,0,0,0
SID_368,13158,This training is anticipated to be incorporated into MEGs annual training program,0,0,0,0,0,0,0,1,0,0,0
SID_368,13159,Assessment of Effectiveness MEG is committed to assessing the effectiveness of its practices and policies and will seek to continually strengthen and improve upon its Modern Slavery response,0,0,0,0,0,0,0,0,0,0,0
SID_368,13160,The Board of Directors is responsible for overseeing the execution and implementation of MEGs modern slavery-related programs and policies,0,0,0,0,0,0,0,0,0,0,0
SID_368,13161,The Board will receive a regular annual report from MEGs SCM and legal team identifying areas of potential risk and actions taken to remediate such risks,0,0,0,0,0,0,0,1,0,0,0
SID_368,13162,"MEG will review the effectiveness of steps taken to identify, assess and mitigate Modern Slavery risks by",0,0,0,0,0,0,0,0,0,1,0
SID_368,13163,investigating any complaints and grievances received through our reporting mechanisms described herein,0,0,0,0,0,0,0,0,1,0,0
SID_368,13164,evaluating our supply chain processes on an ongoing basis,0,0,0,0,0,0,0,1,0,0,0
SID_368,13165,conducting increased due diligence on the top three suppliers we have identified as being at a higher risk of Modern Slavery practices,0,0,0,0,0,0,0,1,0,0,0
SID_368,13166,reviewing MEGs policies related to Modern-Slavery against our peers policies and against international benchmarking frameworks for best practice; and,0,0,0,0,0,0,0,0,0,1,0
SID_368,13167,reviewing our approach to Modern Slavery risks against international benchmarking frameworks and considering new processes to implement in future reporting periods,0,0,0,0,0,0,0,0,0,1,0
SID_368,13168,Feedback MEG welcomes all feedback as part of its commitment to foster communication with its stakeholders,0,0,0,0,0,0,0,0,0,0,0
SID_368,13169,"Please direct any comments or question you may have on this Report to MEGs Manager, SCM",0,0,0,0,0,0,0,0,0,0,0
SID_368,13170,"MODERN SLAVERY REPORT Approval & Attestation This Report was approved pursuant to paragraph 11(4)(a) of the Act by MEGs Board of Directors effective May 7, 2024",1,0,0,0,0,0,0,0,0,0,0
SID_368,13171,"In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for the entity or entities listed above",0,0,0,0,0,0,0,0,0,0,0
SID_368,13172,"Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above",0,0,0,0,0,0,0,0,0,0,0
SID_368,13173,I have the authority to bind MEG Energy Corp Full name: Darlene M,0,1,0,0,0,0,0,0,0,0,0
SID_368,13174,"Gates Title: President & CEO Date: May 30, 2024 Signature",0,1,0,0,0,0,0,0,0,0,0
SID_369,13175,Page 1 of 3,0,0,0,0,0,0,0,0,0,0,0
SID_369,13176,Lamb Ford Sales Ltd - Forced Labour Report,0,0,0,0,0,0,0,0,0,0,0
SID_369,13177,"Report on Forced Labour and Child Labour in Supply Chains, 2023",0,0,0,0,0,0,0,0,0,0,0
SID_369,13178,"The Fighting Against Forced Labour and Child Labour in Supply Chains Act (Canadas Modern Slavery Act, the Act) came into force on January 1, 2024",0,0,0,0,0,0,0,0,0,0,0
SID_369,13179,"In accordance with the Act, this report outlines the policies and procedures that Lamb Ford Sales Ltd (Lamb Ford) has implemented to prevent and reduce the risk that neither forced labour nor child labour occurs in its supply chains or operations",0,0,0,0,0,0,0,0,0,0,0
SID_369,13180,"Structure and Activities Lamb Ford Sales Ltd is a large central Alberta retailer of vehicles including cars, sports utility vehicles (SUVs), vans and trucks and employs approximately 70 full and part-time staff",0,0,0,1,1,0,0,0,0,0,0
SID_369,13181,The family-owned business started in Camrose in 1981 and carries a comprehensive line of new Ford vehicles and high- quality used vehicles,0,0,0,0,1,0,0,0,0,0,0
SID_369,13182,Resale of used vehicles includes a small number of exports to states in the U.S.A,0,0,0,0,1,0,0,0,0,0,0
SID_369,13183,"Lamb Ford services all makes and models of vehicles through its Quick Lane (lubrication and tires), Service, and Fix Auto Camrose (collision repair) departments",0,0,0,0,1,0,0,0,0,0,0
SID_369,13184,Its Finance department provides customers with a range of options to help purchase and maintain their vehicles,0,0,0,0,1,0,0,0,0,0,0
SID_369,13185,"The Parts department supports other businesses and individuals in repairing, upgrading and personalizing vehicles",0,0,0,0,1,0,0,0,0,0,0
SID_369,13186,"Supply Chains All new vehicles sold by Lamb Ford are purchased from Ford Motor Company of Canada, Limited, which through Ford Motor Company has its own statement on Global Modern Slavery and Human Trafficking Transparency",0,0,0,0,0,1,0,0,0,0,0
SID_369,13187,Used vehicles are sourced from individual (mostly local) owners and provincial dealer- only auctions,0,0,0,0,0,1,0,0,0,0,0
SID_369,13188,"A very high percentage of parts sold are sourced through Canadian original equipment manufacturers (O.E.M.s), with the remainder coming from trusted local parts suppliers and occasionally North American suppliers when necessary",0,0,0,0,0,1,0,0,0,0,0
SID_369,13189,The services of trusted local companies and contractors are retained on occasion,0,0,0,0,0,1,0,0,0,0,0
SID_369,13190,Steps Taken to Prevent and Reduce the Risk of Supply Chain Forced Labour and Child Labour Lamb Ford stands resolutely against the practices of forced labour and child labour,0,0,0,0,0,0,0,0,0,0,0
SID_369,13191,"To help prevent those practices in its supply chain, management has conducted an internal assessment of risks in the organizations activities and supply chains",0,0,0,0,0,0,0,1,0,0,0
SID_369,13192,"The risks are mitigated by using local, Canadian, and in a few cases, U.S.A sources",0,0,0,0,0,1,0,0,0,0,0
SID_369,13193,Suppliers of goods and services are monitored to ensure continued compliance,0,0,0,0,0,0,0,0,0,0,0
SID_369,13194,The hiring practices of Lamb Ford include gathering information directly and indirectly on potential employees,0,0,0,0,0,0,0,0,0,0,0
SID_369,13195,"Conversations with the potential employee, reference checks and discussions with past employers are made",0,0,0,0,0,0,0,0,0,0,0
SID_369,13196,"Original documentation to prove identity, such as drivers licences, passports, and",0,0,0,0,0,0,0,0,0,0,0
SID_369,13197,Page 2 of 3,0,0,0,0,0,0,0,0,0,0,0
SID_369,13198,social insurance cards/letters are required of all new hires,0,0,0,0,0,0,0,0,0,0,0
SID_369,13199,No underage person is ever hired by Lamb Ford,0,0,0,0,0,0,0,0,0,0,0
SID_369,13200,"Risk Of Forced Labour or Child Labour Being Used in Lamb Fords Business and Supply Chain, and Steps Taken to Assess and Manage That Risk Parts supply chains carry risks related to forced labour and child labour",0,0,0,0,0,0,0,0,0,0,0
SID_369,13201,The likelihood that Lamb Ford directly employs forced or child labour is extremely low,0,0,0,0,0,0,1,0,0,0,0
SID_369,13202,"By sourcing parts mainly from Ford of Canada and local distributors, the risks of supporting forced labour and/or child labour are further reduced",0,0,0,0,0,1,0,0,0,0,0
SID_369,13203,Measures Taken to Remediate Any Forced Labour or Child Labour Lamb Ford has not identified or been informed of any forced labour or child labour in its supply chains,0,0,0,0,0,0,1,0,0,0,0
SID_369,13204,Measures Taken to Remediate the Loss of Income to the Most Vulnerable Families That Results from Any Measure Taken to Eliminate the Use of Forced Labour or Child Labour in Its Activities and Supply Chains Lamb Ford recognizes that elimination of forced labour and child labour could result in financial hardship for less privileged families,0,0,0,0,0,0,0,0,0,0,0
SID_369,13205,"If forced labour or child labour in its supply chains is discovered, Lamb Ford commits to taking action by reporting the information to appropriate authorities",0,0,0,0,0,0,0,0,1,0,0
SID_369,13206,"Also, Lamb Ford will, as much as possible, communicate with affected individuals and appropriate authorities to determine what kinds of support and compensation can be provided",0,0,0,0,0,0,0,0,1,0,0
SID_369,13207,Training Provided to Employees on Forced Labour and Child Labour The management team at Lamb Ford takes very seriously the harm caused by forced labour and child labour,0,0,0,0,0,0,0,0,0,0,0
SID_369,13208,"Management utilizes Canadian government resources, such as those provided by Public Safety Canada, to train and improve the management team in its ability to prevent supporting forced labour and child labour",0,0,0,0,0,0,0,1,0,0,0
SID_369,13209,"Assessment Of Lamb Fords Effectiveness in Ensuring That Forced Labour and Child Labour Are Not Being Used in Its Business and Supply Chains Ensuring the effectiveness of Lamb Fords adherence to its principles, including working to prevent forced labour and child labour in its activities and supply chains, is a daily process",0,0,0,0,0,0,0,0,0,0,0
SID_369,13210,"Through annual reviews and discussions with managers, Lamb Ford plans to keep this issue current and relevant in the minds of staff",0,0,0,0,0,0,0,0,0,1,0
SID_369,13211,"Lamb Ford acknowledges that the entities making use of forced labour and child labour are unlikely to make such practices obvious and visible, and that there is always the potential for such problems to find their way into a supply chain",0,0,0,0,0,0,0,0,0,0,0
SID_369,13212,As of the date of this report Lamb Ford is proud to state that no instances of forced labour or child labour were found in its operations or supply chains,0,0,0,0,0,0,1,0,0,0,0
SID_370,13213,"2023 Report Introduction This report has been prepared jointly by Material Handling Systems, Inc and Fortna Canada Corp, both of which are subsidiaries of Fortna Group, Inc (collectively, FORTNA) in response to the reporting requirements under Canadas Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Act) for the financial year ending December 31, 2023",0,0,0,1,0,0,0,0,0,0,0
SID_370,13214,FORTNA is committed to respecting the human rights of people impacted by our operations and supply chain,0,0,0,0,0,0,0,0,0,0,0
SID_370,13215,"Organizational Structure FORTNA is comprised of a global group of companies and operates in the following countries United States, Canada, Mexico, Austria, China, Czech Republic, Germany, Italy, Netherlands, Poland, South Africa, United Kingdom, and Vietnam",0,0,0,1,1,0,0,0,0,0,0
SID_370,13216,"FORTNA designs, develops, and delivers intelligent software and automated material handling systems for parcel, distribution and fulfillment operations",0,0,0,0,1,0,0,0,0,0,0
SID_370,13217,FORTNA manufactures certain components of the material handling systems it designs and delivers,0,0,0,0,1,0,0,0,0,0,0
SID_370,13218,"FORTNA has approximately 2,500 employees and its headquarters is in Atlanta, Georgia",0,0,0,1,0,0,0,0,0,0,0
SID_370,13219,FORTNA is a privately held company,0,0,0,1,0,0,0,0,0,0,0
SID_370,13220,"Organizational Activities FORTNA designs, develops, installs, and provides ongoing service and maintenance support for material handling systems for parcel, distribution and fulfillment operations",0,0,0,0,1,0,0,0,0,0,0
SID_370,13221,"Some FORTNA companies manufacture or assemble certain components of the material handling systems, including conveyors, sorters, and/or certain parts at its facilities in Louisville, Kentucky.1 Material Handling Systems, Inc imports some of these products into Canada to support FORTNA projects operated by Fortna Canada Corp and to sell to third-party purchasers located in Canada",0,0,0,0,1,0,0,0,0,0,0
SID_370,13222,"Supply Chain FORTNA procures a range of goods and services that support the design, development, installation, and servicing of material handling systems",0,0,0,0,0,1,0,0,0,0,0
SID_370,13223,"The primary goods FORTNA purchases are products that are part of material handling systems, such as automated guided vehicles (AGVs) and racks",0,0,0,0,0,1,0,0,0,0,0
SID_370,13224,"The primary services FORTNA purchases are services related to the installation of material handling systems, such as mechanical and electrical engineering services",0,0,0,0,0,1,0,0,0,0,0
SID_370,13225,"Efforts to Prevent and Reduce Risk of Forced Labour and Child Labour In our financial year ending December 31, 2023, FORTNA has taken the following steps to prevent and reduce the risks of forced labour and child labour in our operations and supply chain: Developing and implementing anti-forced labour and anti-child labour standards via its Global Code of Ethics and Business Conduct (Code) and its Supplier Code of Conduct (Supplier Code)",0,0,0,0,0,0,0,1,0,0,0
SID_370,13226,"FORTNA is in the process of moving its manufacturing operations in Norton Shores/Walker, Michigan to Louisville, Kentucky",0,0,0,0,1,0,0,0,0,0,0
SID_370,13227,DocuSign Envelope ID: 6386CD33-3680-4967-ADCA-DA3DEF13A48D,0,0,0,0,0,0,0,0,0,0,0
SID_370,13228,"Developing and implementing anti-forced labour and anti-child labour contractual clauses for our direct suppliers; Developing and implementing mechanisms for reporting and investigating complaints or concerns about forced labour and child labour, including FORTNAs Compliance & Ethics Hotline (Hotline)",0,0,0,0,0,0,0,1,0,0,0
SID_370,13229,"Policies and Due Diligence FORTNA embeds responsible business conduct into our governance structure, policies, and risk management processes",0,0,0,0,0,0,0,0,0,0,0
SID_370,13230,"Governance FORTNA is committed to strong corporate governance and has established roles that are responsible for overseeing compliance with applicable laws and regulations, including compliance with forced labour and child labour laws and regulations",0,0,0,0,0,0,0,1,0,0,0
SID_370,13231,"FORTNAs Legal & Compliance group is responsible for identifying and managing the risks associated with FORTNAs business, including the risks associated with forced labour and child labour",0,0,0,0,0,0,0,1,0,0,0
SID_370,13232,"FORTNAs Legal & Compliance group also oversees and administers the Hotline, which also serves as the companys whistleblower hotline",0,0,0,0,0,0,0,1,0,0,0
SID_370,13233,Policies FORTNAs Code and Supplier Code affirm FORTNAs commitment to uphold high moral and ethical principles and specify the basic norms of behaviour for those conducting business on FORTNAs behalf,0,0,0,0,0,0,0,0,0,0,0
SID_370,13234,"Specifically, both expressly prohibit forced labour and exploitation of child labour",0,0,0,0,0,0,0,1,0,0,0
SID_370,13235,All employees are required to review and acknowledge the Code upon hire and annually and/or as the Code is updated,0,0,0,0,0,0,0,1,0,0,0
SID_370,13236,Compliance with the Supplier Code is a standard term in all contracts with suppliers and contracts with suppliers require compliance with all applicable laws,0,0,0,0,0,0,0,1,0,0,0
SID_370,13237,Due Diligence FORTNA is in the process of integrating the operations of two businesses that merged in 2022 to form FORTNA,0,0,0,1,0,0,0,0,0,0,0
SID_370,13238,"As part of this integration, we are combining the procurement functions from each of the business to form a centralized procurement function that will utilize a vendor qualification process to evaluate suppliers and confirm that they meet FORTNA standards, including compliance with anti-slavery, forced labour and child labour laws",0,0,0,0,0,0,0,1,0,0,0
SID_370,13239,We expect this centralization to be completed within the next twelve months,0,0,0,0,0,0,0,0,0,0,0
SID_370,13240,"Forced Labour and Child Labour Risk FORTNAs operations are located in primarily low-risk jurisdictions, based on assessment using a Conflict-Affected and High-Risk Area (CAHRA) tool that uses country-level data indicators spanning multiple topics, including forced labour and child labour",0,0,0,0,0,0,1,1,0,0,0
SID_370,13241,"To date, our approach to identifying the risks of forced labour and child labour has focused on the locations we operate in, which is primarily where our suppliers are located",0,0,0,0,0,0,0,1,0,0,0
SID_370,13242,Remediation Measures/Remediation of Loss of Income DocuSign Envelope ID: 6386CD33-3680-4967-ADCA-DA3DEF13A48D,0,0,0,0,0,0,0,0,0,0,0
SID_370,13243,"In addition to FORTNAs Code and Supplier Code, which set expectations regarding forced labour and child labour, FORTNA has a Compliance & Ethics Hotline and Speak Up Policy (Hotline Policy)",0,0,0,0,0,0,0,1,0,0,0
SID_370,13244,"The Hotline Policy encourages employees to raise concerns about potential Code and other violations and provides employees with information on how to report concerns, including via the Hotline",0,0,0,0,0,0,0,1,0,0,0
SID_370,13245,The Hotline is operated by a third party and all reports to the Hotline go directly to FORTNAs Legal & Compliance group for review and investigation,0,0,0,0,0,0,0,1,1,0,0
SID_370,13246,"To date, FORTNA has not received any complaints relating to forced labour or child labour in our operations or supply chain, and as such has not had to take any remediation measures or remediation of loss of income to families as a result of forced labour or child labour",0,0,0,0,0,0,0,0,0,1,0
SID_370,13247,Employee Training FORTNA requires employees to review and acknowledge the Code and the Hotline Policy annually and/or as it is updated,0,0,0,0,0,0,0,1,0,0,0
SID_370,13248,FORTNA also requires employees to do training from time to time on topics covered in the Code and plans to roll out training on forced labour and child labour to all employees globally in Q4 2024,0,0,0,0,0,0,0,1,0,0,0
SID_370,13249,"The training will provide an overview of anti- slavery/forced labour/child labour, common indicators of risk, how to identify forced labour and child labour, and what to do if they suspect an issue or violation",0,0,0,0,0,0,0,1,0,0,0
SID_370,13250,The training will be delivered through FORTNAs Learning Management System and FORTNA will track completion and follow up with employees and their supervisors if the training is not completed within the allocated time frame (ie by year-end),0,0,0,0,0,0,0,0,0,1,0
SID_370,13251,"Approval In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for Material Handling Systems, Inc and Fortna Canada Corp Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above",0,0,0,0,0,0,0,0,0,0,0
SID_370,13252,"I have the authority to bind Material Handling Systems, Inc and Fortna Canada Corp",0,0,0,0,0,0,0,0,0,0,0
SID_370,13253,______________________________________ Rob McKeel Director,0,1,0,0,0,0,0,0,0,0,0
SID_370,13254,_______________________________________ Kathleen Phelps Director DocuSign Envelope ID: 6386CD33-3680-4967-ADCA-DA3DEF13A48D,0,1,0,0,0,0,0,0,0,0,0
SID_372,13438,"Fighng Against Forced Labour and Child Labour in Supply Chains 2023 REPORT About this Report CanadaOne Auto is commied to ensuring transparency and responsibility throughout our supply chain in accordance with Canada's Forced Labour and Child Labour in Supply Chains Act (the Act) which came into eect on January 1, 2024",0,0,0,0,0,0,0,0,0,0,0
SID_372,13439,"This report has been prepared to outline the measures and policies we have implemented, or plan to implement, to idenfy, prevent, and migate any instances of forced or child labour within our operaons and those of our suppliers",0,0,0,0,0,0,0,0,0,0,0
SID_372,13440,"This iniave aligns with our core values and ethical standards, reinforcing our dedicaon to human rights and corporate responsibility",0,0,0,0,0,0,0,0,0,0,0
SID_372,13441,"In this report, we will provide an overview of our supply chain pracces, discuss our compliance mechanisms, and present the outcomes of our monitoring and auding processes",0,0,0,0,0,0,0,0,0,0,0
SID_372,13442,"This report covers the nancial reporng period of January 1, 2023 to December 31, 2023 (the Reporng Period) and includes ongoing acvies of CanadaOne Auto, including all of its related dealerships and subsidiary enes up to the date of this report",0,0,0,0,0,0,0,0,0,0,0
SID_372,13443,"Structure, Acvies and Supply Chains",0,0,0,0,0,0,0,0,0,0,0
SID_372,13444,Structure CanadaOne Auto operates as a signicant organizaon in the Canadian automove retail sector,0,0,0,0,1,0,0,0,0,0,0
SID_372,13445,"The company's structure is notably expansive, with a broad network encompassing 41 automove dealerships at the date of this report across mulple provinces including Brish Columbia, Alberta, Saskatchewan, Manitoba, and Ontario",0,0,0,1,1,0,0,0,0,0,0
SID_372,13446,"This network enables CanadaOne Auto to oer a diverse range of automove brands and services, enhancing its market reach and service capabilies",0,0,0,0,1,0,0,0,0,0,0
SID_372,13447,"Supported from its corporate headquarters in Edmonton, Alberta, CanadaOne Auto is a private organizaon owned and controlled by Patrick Priestner under a family trust structure with a number of subsidiary enes, each of which undertakes a range of funcons and acvies in support of the business including the operaon of its automove dealerships, and the management of property and investments",0,0,0,1,1,0,0,0,0,0,0
SID_372,13448,The leadership team at CanadaOne Auto is comprised of an experienced and dedicated team commied to ensuring consistent service quality and operaonal eciency throughout its organizaon,0,0,0,0,0,0,0,0,0,0,0
SID_372,13449,"With over 3,000 employees employed by its various subsidiaries CanadaOne Auto thrives on teamwork and collaboraon",0,0,0,1,0,0,0,0,0,0,0
SID_372,13450,"Each dealership under CanadaOne Auto is individually managed by engaged general managers commied to upholding the companys standards, contribung to its reputaon for high customer sasfacon and community involvement",0,0,0,0,0,0,0,0,0,0,0
SID_372,13451,CanadaOne Autos dealerships collecvely parcipate and support over 200 charies and local community organizaons,0,0,0,0,0,0,0,0,0,0,0
SID_372,13452,"Acvies CanadaOne Auto engages in a mulfaceted range of acvies within the retail automove industry, designed to ensure comprehensive service delivery and operaonal excellence",0,0,0,0,1,0,0,0,0,0,0
SID_372,13453,"These acvies primarily encompass: Vehicle Sales: Central to operaons is the retail sale of new and used vehicles, which serves a broad customer base with varying preferences and needs",0,0,0,0,1,0,0,0,0,0,0
SID_372,13454,This includes providing a wide selecon,0,0,0,0,1,0,0,0,0,0,0
SID_372,13455,Fighng Against Forced Labour and Child Labour in Supply Chains 2023 REPORT of automove brands ensuring that customers have access to both luxury and standard vehicle opons,0,0,0,0,1,0,0,0,0,0,0
SID_372,13456,"Parts, Maintenance and Repair Services: CanadaOne Auto provides extensive parts and service oerings, which are crucial for maintaining customer sasfacon post-purchase",0,0,0,0,1,0,0,0,0,0,0
SID_372,13457,"This service includes regular maintenance, compleng repairs, and the sale of auto parts and accessories, essenal for the longevity and opmal performance of the vehicles sold",0,0,0,0,1,0,0,0,0,0,0
SID_372,13458,"Finance and Insurance (F&I) Services: CanadaOne Autos F&I services facilitate the vehicle purchasing process for customers, oering tailored soluons with its lender partnerships that enhance the buying experience and protect customers investments",0,0,0,0,1,0,0,0,0,0,0
SID_372,13459,Supply Chains CanadaOne Autos supply chain includes a variety of suppliers who provide goods and services that contribute directly and indirectly to our operaons,0,0,0,0,0,0,0,0,0,0,0
SID_372,13460,"This ranges from global automobile manufacturers (OEMs) who supply the new vehicles we sell, to domesc vendors that supply parts for maintenance and repair services",0,0,0,0,0,1,0,0,0,0,0
SID_372,13461,"Automobile Manufacturers: Leading global automobile manufacturers including Ford, Toyota, General Motors, Honda, Kia, Subaru, Mitsubishi, BMW, Mini, Hyundai and Stellans supply new vehicles and vehicle parts to our dealerships",0,0,0,0,0,1,0,0,0,0,0
SID_372,13462,"Parts Suppliers: To support vehicle maintenance and repair services, CanadaOne Auto works with numerous other domesc parts suppliers that provide quality automove parts and accessories",0,0,0,0,0,1,0,0,0,0,0
SID_372,13463,"This includes everything from basic maintenance items like oil and lters, to res, to more complex components such as transmissions and electrical systems",0,0,0,0,0,1,0,0,0,0,0
SID_372,13464,"Technology Providers: We ulize advanced technology systems from various tech suppliers to manage our inventory, logiscs and operaons",0,0,0,0,0,1,0,0,0,0,0
SID_372,13465,"These systems help us maintain eciency and transparency across our supply chain, from tracking shipments to managing inventory levels at each dealership",0,0,0,0,0,1,0,0,0,0,0
SID_372,13466,Logiscs Partners: Our network is supported by several logiscs partners who handle the transportaon and delivery of vehicles and parts to and from our dealerships,0,0,0,0,0,1,0,0,0,0,0
SID_372,13467,"This includes both naonal and regional carriers, ensuring mely and safe delivery of inventory",0,0,0,0,0,1,0,0,0,0,0
SID_372,13468,"General Supplier Relaonships and Domesc Vendors: CanadaOne Auto ulizes many locally based vendors to supply oce and other ancillary business supplies, maintain and renovate our facilies, and provide various other services to our dealerships such as cleaning and security",0,0,0,0,0,1,0,0,0,0,0
SID_372,13469,Many of our manufacturers and suppliers operate on a global scale with a network that spans numerous countries and regions,0,0,0,0,0,1,0,0,0,0,0
SID_372,13470,"This complexity involves mulple ers of suppliers, each responsible for various components and services essenal to the nal products and services CanadaOne Auto retails to consumers",0,0,0,0,0,0,0,0,0,0,0
SID_372,13471,Fighng Against Forced Labour and Child Labour in Supply Chains 2023 REPORT Policies and Due Diligence Processes Relang to Forced Labour and Child Labour,0,0,0,0,0,0,0,0,0,0,0
SID_372,13472,Policies CanadaOne Auto is commied to the highest standards of corporate governance which ensures the integrity and ethical management of our operaons,0,0,0,0,0,0,0,0,0,0,0
SID_372,13473,Our leadership team plays a pivotal role in reviewing and adapng our corporate governance policies to adhere to human rights and labour laws and ensure these policies are communicated across our organizaon,0,0,0,0,0,0,0,1,0,0,0
SID_372,13474,"The policy that most specically relates to our commitment against the use of any forms of forced or child labour in our business acvies and supply chains includes CanadaOne Autos Code of Business Conduct which mandates that all personnel, including directors, ocers, employees, and consultants, adhere to the highest ethical standards and comply with all applicable laws",0,0,0,0,0,0,0,1,0,0,0
SID_372,13475,This Code emphasizes the importance of legality and integrity in all business decisions and acons,0,0,0,0,0,0,0,0,0,0,0
SID_372,13476,"It also encourages personnel to report any illegal, fraudulent, dishonest, unsafe, negligent, or otherwise unethical acons they observe",0,0,0,0,0,0,0,1,0,0,0
SID_372,13477,"Due Diligence Processes To address and migate the risks associated with forced and child labor in our operaons and supply chains, we have begun to implement several proacve measures and due diligence processes: Risk Assessment: Conduct high level assessments of our key supply chain partners (OEMs) acvies including annual review of their published human rights and supply chain policies and modern slavery reports and statements to idenfy potenal risks of forced or child labor within our supply chains",0,0,0,0,0,0,0,1,0,0,0
SID_372,13478,Review Supplier Pracces: Review any signicant potenal suppliers' and service providers' governance pracces and policies concerning modern slavery before nalizing any signicant new agreements,0,0,0,0,0,0,0,1,0,0,0
SID_372,13479,This review process will help assess their compliance with the Act and conrm their operaons are free from forced or child labour,0,0,0,0,0,0,0,1,0,0,0
SID_372,13480,"Depending on the risk associated with a supplier, their business relaonship length, and their human rights policies, we may require specic provisions in our contracts requiring adherence to all applicable laws expressly conrming the absence of modern slavery in their operaons and supply chains",0,0,0,0,0,0,0,1,0,0,0
SID_372,13481,"Risks of Modern Slavery in Operaons and Supply Chain Recognizing the inherent risks that come with the automove manufacturing sector, CanadaOne Auto takes a cauous approach to supply chain management",0,0,0,0,0,0,0,0,0,0,0
SID_372,13482,"Our operaons span across Canada, where the risk of modern slavery is generally low due to strong human rights laws and enforcement",0,0,0,0,1,0,0,0,0,0,0
SID_372,13483,"However, the complexity of our supply chains, which involve a heavy reliance on procurement from our global original equipment manufacturers, necessitates a vigilant approach",0,0,0,0,0,1,0,0,0,0,0
SID_372,13484,"Geographical Risks: While our immediate operaonal region (Canada) present lower risks, the global span of our OEMs' and supplier acvies means some components may be sourced from or manufactured in higher-risk areas",0,0,0,0,0,1,1,0,0,0,0
SID_372,13485,"These regions might not have stringent labor protecons, which increases the risk of modern slavery pracces",0,0,0,0,0,0,1,0,0,0,0
SID_372,13486,"Material Sourcing Risks: The procurement of raw materials needed in the automove industry oen occurs beyond our direct er one suppliers, which can obscure visibility and control over the",0,0,0,0,0,1,1,0,0,0,0
SID_372,13487,Fighng Against Forced Labour and Child Labour in Supply Chains 2023 REPORT condions under which these materials are gathered and processed,0,0,0,0,0,0,1,0,0,0,0
SID_372,13488,This lack of direct oversight or control can potenally expose our supply chain to modern slavery risks,0,0,0,0,0,0,1,0,0,0,0
SID_372,13489,Conducng regular assessment and following the due diligence processes and pracces established by CanadaOne Auto will migate risk of its acvies and supply chains involving the use of forced or child labour,0,0,0,0,0,0,0,0,0,1,0
SID_372,13490,Remediaon To date CanadaOne Auto has not idened any specic instances of forced or child labor within our retail supply chain and as such has not implemented any remediaon measures to this point,0,0,0,0,0,0,1,0,1,0,0
SID_372,13491,CanadaOne Auto has not idened any loss of income to vulnerable families resulng from measures taken to eliminate the use of forced labour or child labour in its acvies and supply chains therefore no remediave acons have been taken,0,0,0,0,0,0,0,0,0,0,0
SID_372,13492,Assessing Eecveness and Looking Forward CanadaOne Auto is commied to connuously enhancing the measures in place to prevent and reduce the risks of forced and child labour within our operaons and supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_372,13493,"The following outlines the framework and steps we have adopted, or are considering adopng as the case may be, to assess the eecveness of these measures: Policy Evaluaon and Updates: CanadaOne Auto has undertaken to regularly review exisng policies, such as the Code of Business Conduct, to ensure our policies reect the most current legal standards and best pracces related to human rights and labor laws",0,0,0,0,0,0,0,0,0,1,0
SID_372,13494,Updates will be made to incorporate new insights and address any gaps that might contribute to risks within our supply chain,0,0,0,0,0,0,0,1,0,0,0
SID_372,13495,"Training and Awareness Programs: To deepen the understanding of modern slavery risks among our sta, parcularly those involved in procurement and supply chain management, CanadaOne Auto is evaluang the implementaon of targeted training programs to raise awareness about the indicators of forced and child labour and educate our team on the appropriate acons to migate these risks",0,0,0,0,0,0,0,1,0,0,0
SID_372,13496,"Stakeholder and Employee Engagement: Engaging with external stakeholders, including OEMs, suppliers, customers, other industry partners, associaons and government agencies, and infernally with our own employees will help us gain external perspecves on our pracces and idenfy any areas for improvement",0,0,0,0,0,0,0,0,0,1,0
SID_372,13497,This engagement will be a crucial component of our overall strategy to enhance transparency and accountability in our operaons,0,0,0,0,0,0,0,0,0,0,0
SID_372,13498,"Approve a Zero Tolerance Statement: CanadaOne Auto's leadership team is collaborang on the adopon of a Zero-Tolerance Statement on Forced and Child Labour in 2024, which it views as an integral part of our commitment to ethical business pracces",0,0,0,0,0,0,0,1,0,0,0
SID_372,13499,"This statement intends to uphold, among other things, that CanadaOne Auto is a people-driven company that values integrity and stands rmly against any form of modern slavery",0,0,0,0,0,0,0,0,0,0,0
SID_372,13500,"Fighng Against Forced Labour and Child Labour in Supply Chains 2023 REPORT As a leading dealership group in the automove industry, CanadaOne Auto understands the importance of seng precedents that encourage ethical business pracces not just within our immediate operaons but also across our enre supply network",0,0,0,0,0,0,0,0,0,0,0
SID_372,13501,"By adhering to the guidelines and requirements set forth by the Canadian government, we aim not only to comply with the legal mandates but also to foster a culture of integrity and transparency in every aspect of our business",0,0,0,0,0,0,0,0,0,0,0
SID_372,13502,Approval This joint report has received approval of the Family Trusts that govern the operaons of CanadaOne Autos reporng enes as outlined in the Act and the Boards of Directors of the included enes as of the date hereof,1,0,0,0,0,0,0,0,0,0,0
SID_372,13503,"In accordance with the requirements of the Act, and in parcular secon 11 thereof, I aest that I have reviewed the informaon contained in the report for the enty or enes listed above",0,0,0,0,0,0,0,0,0,0,0
SID_372,13504,"Based on my knowledge, and having exercised reasonable diligence, I aest that the informaon in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporng year listed above",0,0,0,0,0,0,0,0,0,0,0
SID_372,13505,"Full Name: Daniel Priestner Title: Trustee of the Family Trusts, and Director of the Boards of the subsidiary enes of CanadaOne Auto Date: May 30, 2024 Signature: ________________________ I have the authority to bind CanadaOne Auto",0,1,0,0,0,0,0,0,0,0,0
SID_375,13785,Forced Labour Act Identifying Information,0,0,0,0,0,0,0,0,0,0,0
SID_375,13786,This report is being completed for an entity,0,0,0,0,0,0,0,0,0,0,0
SID_375,13787,What is the legal name of the reporting entity? Viking Truck Sales Inc,0,0,0,0,0,0,0,0,0,0,0
SID_375,13788,Financial reporting year: 2023,0,0,0,0,0,0,0,0,0,0,0
SID_375,13789,Is this a revised version of a report already submitted this reporting year? No,0,0,0,0,0,0,0,0,0,0,0
SID_375,13790,Entity business number: BN 105535868,0,0,0,0,0,0,0,0,0,0,0
SID_375,13791,Is this a joint report? Yes,0,0,0,0,0,0,0,0,0,0,0
SID_375,13792,"If yes, identify the legal name of each entity covered by this report: Viking Truck Sales Inc o DBA Expressway Trucks Waterloo & o DBA Expressway Trucks London 905364 Ontario Limited o DBA Expressway Trucks Windsor While 905364 Ontario Limited does not meet the threshold requirements to be defined as an entity, we are including it in this report due to the fact that all of the businesses listed in this report work under the umbrella of the Expressway Group of companies and adhere to the same policies",0,0,0,1,0,0,0,0,0,0,0
SID_375,13793,"Addison Truck & Trailer Repair Inc While Addison Truck & Trailer Repair Inc does not meet the threshold requirements to be defined as an entity, we are including it in this report due to the fact that all of the businesses listed in this report work under the",0,0,0,1,0,0,0,0,0,0,0
SID_375,13794,umbrella of the Expressway Group of companies and adhere to the same policies,0,0,0,1,0,0,0,0,0,0,0
SID_375,13795,"Express Lease Inc While Express Lease Inc does not meet the threshold requirements to be defined as an entity, we are including it in this report due to the fact that all of the businesses listed in this report work under the umbrella of the Expressway Group of companies and adhere to the same policies",0,0,0,1,0,0,0,0,0,0,0
SID_375,13796,"Identify the business numbers of each entity covered in the report: Viking Truck Sales Inc BN 105535868 905364 Ontario Limited BN 123500704 o As mentioned in (6.1), 905364 Ontario Limited is not considered an entity, but is being included in this report as it operates under the Expressway Group of companies alongside the reporting entity, Viking Truck Sales Inc Addison Truck & Trailer Repair Inc BN 856991021 o As mentioned in (6.1), Addison Truck & Trailer Repair Inc is not considered an entity, but is being included in this report as it operates under the Expressway Group of companies alongside the reporting entity, Viking Truck Sales Inc Express Lease Inc BN 836658559 o As mentioned in (6.1), Express Lease Inc is not considered an entity, but is being included in this report as it operates under the Expressway Group of companies alongside the reporting entity, Viking Truck Sales Inc",0,0,0,1,0,0,0,0,0,0,0
SID_375,13797,Is the entity also subject to reporting requirements under supply chain legislation in another jurisdiction? No,0,0,0,0,0,0,0,0,0,0,0
SID_375,13798,Which categorizations apply to the entity? Canadian business presence o Has a place of business in Canada,0,0,0,0,0,0,0,0,0,0,0
SID_375,13799,o Does business in Canada,0,0,0,0,0,0,0,0,0,0,0
SID_375,13800,o Has assets in Canada,0,0,0,0,0,0,0,0,0,0,0
SID_375,13801,Meets size-related thresholds o Has at least $20 million in assets for at least one of its two most recent financial years,0,0,0,0,0,0,0,0,0,0,0
SID_375,13802,o Has generated at least $40 million in revenue for at least one of its two most recent financial years,0,0,0,0,0,0,0,0,0,0,0
SID_375,13803,"The reporting entity, Viking Truck Sales Inc (DBA Expressway Trucks Waterloo and Expressway Trucks London), meets the minimum $40 million threshold outlined",0,0,0,0,0,0,0,0,0,0,0
SID_375,13804,"The other businesses listed in this report do not meet this threshold, however they do operate under the Expressway Group of companies alongside Viking Truck Sales Inc",0,0,0,1,0,0,0,0,0,0,0
SID_375,13805,"Which sector/industry does the entity operate in? Wholesale Trade o NAICS Code: 415120 Truck, Truck Tractor and Bus Merchant Wholesalers 10",0,0,0,0,1,0,0,0,0,0,0
SID_375,13806,In which country is the entity headquartered or principally located? Canada 10.1 In which province or territory is the entity headquartered or principally located? Ontario Annual Report,0,0,0,1,0,0,0,0,0,0,0
SID_375,13807,What steps has the entity taken in the previous financial year to prevent and reduce the risk that forced labour or child labour is used at any step of the production of goods in Canada or elsewhere by the entity or of goods imported into Canada by the entity? All dealerships under the Expressway Group of companies trust in the due diligence of our OEMs to have in place policies and procedures for identifying and prohibiting the use of forced labour and/or child labour in their activities and supply chains,0,0,0,0,0,0,0,1,0,0,0
SID_375,13808,Please provide additional information describing the steps taken: Please see below for hyperlinks that lead to the most recent Modern Slavery statements made by our OEMs: Volvo Truck Corporations Modern Slavery Statement (2022) Hino Motor Sales Australia Pty Ltd.s Modern Slavery Statement (2020) Hino Motors Canada (another one of our OEMs) does not have any public Modern Slavery Statements available to reference,0,0,0,1,0,0,0,0,0,0,0
SID_375,13809,"Toyota, Hinos parent company, published a document titled Toyotas action taken for Forced Labour of Migrant Workers (Statement on the Modern Slavery Acts) on September 30th, 2023",0,0,0,1,0,0,0,0,0,0,0
SID_375,13810,"You can view this document at the following hyperlink: Toyotas action taken for Forced Labour of Migrant Workers (Statement on the Modern Slavery Acts) Vanguard National Trailer Corp (another one of our OEMs) and their parent company CIMC Vehicle Group, does not have any public Modern Slavery Statements available to reference",0,0,0,1,0,0,0,0,0,0,0
SID_375,13811,Please provide an accurate description of the entitys structure: Corporation,0,0,0,0,0,0,0,0,0,0,0
SID_375,13812,Please provide an accurate description of the entitys activities: Selling goods in Canada,0,0,0,0,0,0,0,0,0,0,0
SID_375,13813,Distributing goods in Canada,0,0,0,0,0,0,0,0,0,0,0
SID_375,13814,Importing into Canada goods that are produced outside of Canada,0,0,0,0,0,0,0,0,0,0,0
SID_375,13815,"Please provide additional information on the entitys structure, activities, and supply chains: There are 115 employees across all businesses outlined in the report",0,0,0,1,0,0,0,0,0,0,0
SID_375,13816,"We sell/distribute heavy duty trucks, and related parts and repair at a volume of $100,000,000",0,0,0,0,0,1,0,0,0,0,0
SID_375,13817,"We pay our customs brokers to import Vanguard parts and product from a variety of small miscellaneous vendors at a volume of approximately $175,000",0,0,0,0,0,1,0,0,0,0,0
SID_375,13818,"Does the entity currently have policies and due diligence processes in place related to forced labour and/or child labour? No As previously mentioned, the Expressway Group of companies trust in our OEMs to have in place policies and due diligence processes for identifying and prohibiting the use of forced labour and/or child labour in their activities and supply chains",0,0,0,0,0,0,0,1,0,0,0
SID_375,13819,"Has the entity identified parts of its activities and supply chains that carry a risk of forced labour or child labour being used? No, we have not started the process of identifying risks",0,0,0,0,0,0,1,0,0,0,0
SID_375,13820,The Expressway Group of companies trust in the due diligence of our OEMs to identify parts of its activities and supply chains that carry a risk of forced labour or child labour being used,0,0,0,0,0,0,0,0,0,0,0
SID_375,13821,Has the entity identified forced labour or child labour risks in its activities and supply chains related to any of their applicable sectors and industries? We have not identified any evidence of forced labour or child labour risks in our activities or in the supply chains related to our industry,0,0,0,0,0,0,1,0,0,0,0
SID_375,13822,The Expressway Group of companies trust in the due diligence of our OEMs to identify forced labour or child labour risks in its activities and supply chains related to any of their applicable sectors and insustries,0,0,0,0,0,0,0,0,0,0,0
SID_375,13823,"Has the entity taken any measures to remediate any forced labour or child labour in its activities and supply chains? Not applicable, we have not identified any forced labour or child labour in our activities and supply chains",0,0,0,0,0,0,1,0,0,0,0
SID_375,13824,"Has the entity taken any measures to remediate the loss of income to the most vulnerable families that results from any measure taken to eliminate the use of forced labour or child labour in its activities and supply chains? Not applicable, we have not identified any loss of income to vulnerable families resulting from measures taken to eliminate the use of forced labour or child labour in our activities and supply chains",0,0,0,0,0,0,0,0,0,0,0
SID_375,13825,Does the entity currently provide training to employees on forced labour and/or child labour? No 12,0,0,0,0,0,0,0,1,0,0,0
SID_375,13826,Does the entity currently have policies and procedures in place to assess its effectiveness in ensuring that forced labour and child labour are not being used in its activities and supply chains? No The Expressway Group of companies trust in our OEMs to have policies and procedures in place to assess their effectiveness in ensuring that forced labour and child labour are not being used in its activities and supply chains,0,0,0,0,0,0,0,0,0,1,0
SID_390,14973,"2023 MODERN SLAVERY ACT REPORT As of January 1, 2024, the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Act) in Canada requires disclosure statements to be made in a report on certain company details and efforts made to ensure slavery and human trafficking are not taking place in our supply chain or business",0,0,0,0,0,0,0,0,0,0,0
SID_390,14974,"This report is produced by SunOpta Inc (SunOpta) and covers SunOptas fiscal 2023, a 12-month period ending on December 30, 2023",0,0,0,0,0,0,0,0,0,0,0
SID_390,14975,The following report serves as a statement complying with the Act,0,0,0,0,0,0,0,0,0,0,0
SID_390,14976,ABOUT SUNOPTA SunOpta is an innovative and sustainable manufacturer fueling the future of food,0,0,0,0,1,0,0,0,0,0,0
SID_390,14977,"With roots tracing back over 50 years, SunOpta drives growth for todays leading brands by serving as a trusted innovation partner and value-added manufacturer, crafting organic, plant-based beverages, fruit snacks, nutritional beverages, broths and tea products sold through retail, club, foodservice and e-commerce channels",0,0,0,0,1,0,0,0,0,0,0
SID_390,14978,"Alongside the companys commitment to top brands, retailers and coffee shops, SunOpta also proudly produces its own brands, including SOWN, Dream, and West Life",0,0,0,1,0,0,0,0,0,0,0
SID_390,14979,We manufacture and sell the following,0,0,0,0,1,0,0,0,0,0,0
SID_390,14980,private label products to retail and foodservice customers,0,0,0,0,1,0,0,0,0,0,0
SID_390,14981,branded products under co-manufacturing agreements to other branded food companies for their distribution,0,0,0,0,1,0,0,0,0,0,0
SID_390,14982,branded products under our own proprietary brands to retail and foodservice customers; and,0,0,0,0,1,0,0,0,0,0,0
SID_390,14983,bulk ingredients for use by foodservice customers and other food manufacturers,0,0,0,0,1,0,0,0,0,0,0
SID_390,14984,Our employees and 7 manufacturing facilities are located in the US and Canada,0,0,0,1,1,0,0,0,0,0,0
SID_390,14985,"Our corporate headquarters is located in Eden Prairie, Minnesota, together with our innovation center and pilot plant",0,0,0,0,0,1,0,0,0,0,0
SID_390,14986,We work with a diverse value chain of 170 suppliers in more than 28 countries,0,0,0,0,0,1,0,0,0,0,0
SID_390,14987,"The principal raw materials we use are grains (oat, rice), fruits (apple, coconut), vegetables (soybean, hemp), nuts (almond), sugar, and meat (broth)",0,0,0,0,0,1,0,0,0,0,0
SID_390,14988,"We also use substantial quantities of carton board, corrugated, plastic, and aseptic packaging materials, operating supplies, and energy",0,0,0,0,0,1,0,0,0,0,0
SID_390,14989,Most of these inputs for our US and Canadian operations are purchased from suppliers in the United States and Canada,0,0,0,0,0,0,0,0,0,0,0
SID_390,14990,"If inputs are not locally available in adequate supply, they may be imported from other countries",0,0,0,0,0,0,0,0,0,0,0
SID_390,14991,We do not sell any SunOpta branded product in Canada,0,0,0,0,0,0,0,0,0,0,0
SID_390,14992,"STEPS TO PREVENT AND REDUCE FORCED OR CHILD LABOUR As part of SunOptas supplier approval process, SunOpta asks new direct ingredient suppliers and food contact packaging suppliers to answer a self-assessment of their compliance with the Supplier Partner Code of Conduct (the Supplier Code)",0,0,0,0,0,0,0,1,0,0,0
SID_390,14993,The self-assessment asks about the social policies adopted by the supplier and the working conditions provided for its employees,0,0,0,0,0,0,0,1,0,0,0
SID_390,14994,SunOpta reviews the answers on the self-assessment and decides whether that supplier is aligned with SunOptas standards before SunOpta does business with the supplier,0,0,0,0,0,0,0,1,0,0,0
SID_390,14995,"Included in the Supplier Code is the expectation that suppliers share in our commitment to the rule of law and to compliance with applicable laws, including those related to slavery and human trafficking",0,0,0,0,0,0,0,1,0,0,0
SID_390,14996,"In 2022, SunOpta joined Sedex (a platform connecting suppliers to customers and creating transparency into the social practices of the suppliers) and we began training and implementation of our suppliers into the platform in 2023",0,0,0,0,0,0,0,1,0,0,0
SID_390,14997,"In 2023, SunOpta also reviewed and updated the Supplier Code",0,0,0,0,0,0,0,1,0,1,0
SID_390,14998,"In addition, we translated the Supplier Code into Spanish to ensure supplier comprehension",0,0,0,0,0,0,0,0,0,0,0
SID_390,14999,We also include a checklist and signature attestation for suppliers to confirm their compliance with the Supplier Code,0,0,0,0,0,0,0,1,0,0,0
SID_390,15000,"POLICIES AND PROCESSES In 2023, SunOpta adopted a Human Rights Policy Statement aligning its commitment to the UN Guiding Principles on Business and Human Rights and the Universal Declaration of Human Rights",0,0,0,0,0,0,0,1,0,0,0
SID_390,15001,"SunOpta is committed to supporting and promoting human rights with regard to our employees, business partners, and suppliers",0,0,0,0,0,0,0,0,0,0,0
SID_390,15002,SunOptas commitment to Human Rights is addressed in detail in SunOptas Code of Conduct (Employee Code) and it Supplier Code,0,0,0,0,0,0,0,0,0,0,0
SID_390,15003,We conduct in-person visits with selected suppliers as part of our process of ensuring they meet SunOpta expectations,0,0,0,0,0,0,0,1,0,0,0
SID_390,15004,"Not only are we reviewing ingredient quality, we also are looking at plant and personnel hygiene practices, how our suppliers execute documented programs, and the broader economic and social environments in the areas from which we source our ingredients",0,0,0,0,0,0,0,0,0,0,0
SID_390,15005,Every year is different in a growing region,0,0,0,0,0,0,0,0,0,0,0
SID_390,15006,"We seek to understand what might be happening in a particular season, including environmental, social and political conditions",0,0,0,0,0,0,0,0,0,0,0
SID_390,15007,"There are many factors that can impact a crop: weather, availability and cost of inputs, farming practices, labour availability, pest pressure, etc Supplier visits allow us to better understand challenges the growers are facing and inform our expectations for crop performance",0,0,0,0,0,0,0,0,0,0,0
SID_390,15008,We strive to get our feet inside the facilities regularly with our suppliers to confirm that practices in person are satisfactory and safe,0,0,0,0,0,0,0,0,0,0,0
SID_390,15009,"We utilize third-party audits and certifications for some, but there is always something to learn and discover by physically walking through a facility and watching a suppliers programs and processes in action",0,0,0,0,0,0,0,1,0,0,0
SID_390,15010,"When we are visiting sourcing locations, we are mindful of the local culture and political environment",0,0,0,0,0,0,0,1,0,0,0
SID_390,15011,This is important to ensure we are sourcing ethically harvested products and also helps us to understand the dynamics of a region that can be factored into a risk assessment for proactive management,0,0,0,0,0,0,0,0,0,0,0
SID_390,15012,"The Audit and Corporate Governance committees of SunOptas Board of Directors oversee reported violations of the Employee Code, including violations relating to matters of human rights",0,0,0,0,0,0,0,1,0,0,0
SID_390,15013,"The Board of Directors, Senior Leadership Team, and Sustainability Steering Committee oversee SunOptas overall approach to Environmental, Social and Governance (ESG) matters",0,0,0,0,0,0,0,1,0,0,0
SID_390,15014,IDENTIFICATION OF SECTORS WITH INCREASED RISK No sector or industry involving the production or importation of goods are assumed to be entirely free of forced labour and child labour risks,0,0,0,0,0,0,0,0,0,0,0
SID_390,15015,"We have considered the ways in which our activities and supply chains could potentially cause, contribute to or be directly or indirectly linked to an actual or potential risk that forced labour or child labour is used in our supply chains",0,0,0,0,0,0,0,0,0,0,0
SID_390,15016,We understand the 2022 ILO report suggests that sectors where human trafficking and child labour are most prevalent include agriculture and manufacturing and we take this seriously,0,0,0,0,0,0,1,0,0,0,0
SID_390,15017,"MEASURES TAKEN TO REMEDIATE FORCED OR CHILD LABOUR AND ITS IMPACT ON THE MOST VULNERABLE Measures taken to remediate forced labour or child labour in our activities and supply chains include adopting a Human Rights Policy Statement, engaging with Sedex to onboard our suppliers which will allow us to assess the risk of forced or child labour in our supply chain, visiting select suppliers prior to adding them to our supply chain, updating and translating our Supplier Code into Spanish, and optional training offered to select employees on our Supplier Code",0,0,0,0,0,0,0,1,0,0,0
SID_390,15018,We have judged that vulnerable families have not experienced loss of income as a result of steps SunOpta has taken to eliminate forced labour or child labour risks,0,0,0,0,0,0,0,0,0,0,0
SID_390,15019,"TRAINING In 2023, we provided optional training of the Supplier Code to those employees that have the potential to interact with suppliers, including procurement, research & development, and quality",0,0,0,0,0,0,0,1,0,0,0
SID_390,15020,"As part of the training, we emphasized the concern of human trafficking and child labour in industries within our supply chain; the red flags to be on the lookout for when talking with or visiting suppliers; and how to report a concern about a potential violation",0,0,0,0,0,0,0,1,0,0,0
SID_390,15021,HOW WE ASSESS EFFECTIVENESS We are taking steps to be able to assess our effectiveness by working with Sedex,0,0,0,0,0,0,0,0,0,1,0
SID_390,15022,There are capabilities within the Sedex platform to conduct risk assessments of our supply chain,0,0,0,0,0,0,0,0,0,0,0
SID_390,15023,"Once we have onboarded the majority of our suppliers, we will assess the baseline social risk of our supplier base using the tools within Sedex and prioritize further action with those suppliers identified as high risk",0,0,0,0,0,0,0,1,0,0,0
SID_390,15024,"We will set KPIs for improvements in areas such as supplier participation, transparency, and risk reduction based on our analysis of the risk assessment",0,0,0,0,0,0,0,0,0,1,0
SID_390,15025,"SunOpta distributes its Employee Code to all employees, officers, and directors of the Company",0,0,0,0,0,0,0,0,0,0,0
SID_390,15026,All managers are responsible for communicating to their teams about SunOptas dedication to operating our business in accordance with the highest standards of ethical conduct and reinforcing this principle at every opportunity,0,0,0,0,0,0,0,0,0,0,0
SID_390,15027,Each department head or supervisor is responsible for monitoring compliance with the Employee Code by all employees within their department,0,0,0,0,0,0,0,1,0,0,0
SID_390,15028,"Officers, directors, and senior leaders will reaffirm compliance with the Employee Code and all related policies on an annual basis",0,0,0,0,0,0,0,1,0,0,0
SID_390,15029,All employees are obligated to follow the Employee Code,0,0,0,0,0,0,0,1,0,0,0
SID_390,15030,"Employees are also required to report any wrongdoing or violation of the Employee Code or related policies, violation of accounting or internal controls, or any incidents of fraud or alleged fraud in accordance with SunOptas Ethics Reporting Policy",0,0,0,0,0,0,0,1,0,0,0
SID_390,15031,The Audit and Corporate Governance committees of SunOptas Board of Directors oversee reported violations of the Employee Code,0,0,0,0,0,0,0,1,0,0,0
SID_392,15112,BROOKFIELD RENEWABLE PARTNERS L.P,0,0,0,0,0,0,0,0,0,0,0
SID_392,15113,BROOKFIELD BRP CANADA CORP,0,0,0,0,0,0,0,0,0,0,0
SID_392,15114,"May 31, 2024",0,0,0,0,0,0,0,0,0,0,0
SID_392,15115,Page 2,0,0,0,0,0,0,0,0,0,0,0
SID_392,15116,Report Pursuant to the Act to enact the Fighting Against Forced Labour and Child Labour in Supply Chains (Report) ABOUT THIS REPORT,0,0,0,0,0,0,0,0,0,0,0
SID_392,15117,This is a joint report by Brookfield Renewable Partners L.P,0,0,0,1,0,0,0,0,0,0,0
SID_392,15118,"(Brookfield Renewable or BEP)1 and Brookfield BRP Canada Corp (BRP Canada and together with BEP, the Reporting Entities) for the financial year ended December 31, 2023, pursuant to the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Act)",0,0,0,1,0,0,0,0,0,0,0
SID_392,15119,"In this Report, references to we, us or our refer to the Reporting Entities",0,0,0,0,0,0,0,0,0,0,0
SID_392,15120,This is the first report for the Reporting Entities under the Act,0,0,0,0,0,0,0,0,0,0,0
SID_392,15121,"This Report sets out our commitments, approach and substantive policies relating to forced labour and child labour with particular reference to potential issues in our supply chain, specifically with respect to the goods and services that we purchase in order to build, operate and maintain our renewable power generation assets in Canada",0,0,0,0,1,0,0,0,0,0,0
SID_392,15122,Our Commitment,0,0,0,0,0,0,0,0,0,0,0
SID_392,15123,"As a global owner and operator of renewable energy and transition assets, Brookfield Renewable is committed to conducting business in an ethical and responsible manner that respects human rights",0,0,0,0,1,0,0,0,0,0,0
SID_392,15124,"We are dedicated to treating stakeholders, including employees, customers, suppliers and the communities in which we operate, with dignity and respect",0,0,0,0,0,0,0,0,0,0,0
SID_392,15125,"Our commitment to human rights is consistent with our sustainability principles, which include implementing policies and procedures aimed at ensuring the well-being and safety of employees, mitigating the impact of our operations on the environment, upholding strong governance practice and being good corporate citizens in the communities in which we operate",0,0,0,0,0,0,0,0,0,0,0
SID_392,15126,"OUR STRUCTURE, ACTIVITIES AND SUPPLY CHAIN",0,0,0,0,0,0,0,0,0,0,0
SID_392,15127,Our Business,0,0,0,0,0,0,0,0,0,0,0
SID_392,15128,"Brookfield Renewable is one of the worlds largest investors, developers, owners and operators of clean power and decarbonization assets, with approximately 33,000 megawatts of generating capacity2 globally and nearly 2,000 megawatts of clean energy capacity in Canada, including hydroelectricity, wind, and solar",0,0,0,0,1,0,0,0,0,0,0
SID_392,15129,BRP Canada holds Brookfield Renewables Canadian operating assets,0,0,0,1,0,0,0,0,0,0,0
SID_392,15130,"For more information on Brookfield Renewables structure, activities and strategic direction, please refer to our Annual Report and our Sustainability Report on our website",0,0,0,0,0,0,0,0,0,0,0
SID_392,15131,BEP is an exempted limited partnership established under the Bermuda Exempted Partnerships Act 1992 (as amended) together with the Bermuda Limited Partnership Act 1883 (as amended),0,0,0,1,0,0,0,0,0,0,0
SID_392,15132,BEPs limited partnership units are listed on the Toronto Stock Exchange (BEP.UN),0,0,0,0,0,0,0,0,0,0,0
SID_392,15133,BRP Canada is incorporated under the Business Corporations Act (Ontario),0,0,0,1,0,0,0,0,0,0,0
SID_392,15134,"This represents total generating capacity on a 100% basis for our investments, and own and operating facilities regardless of proportionate ownership",0,0,0,0,1,0,0,0,0,0,0
SID_392,15135,It includes business transformation and cogeneration assets,0,0,0,0,0,0,0,0,0,0,0
SID_392,15136,Page 3,0,0,0,0,0,0,0,0,0,0,0
SID_392,15137,Our Supply Chain,0,0,0,0,0,0,0,0,0,0,0
SID_392,15138,"Brookfield Renewables core supply chain focuses on the development and construction of new renewable energy assets, and the operation and maintenance (O&M) of our existing operating assets",0,0,0,0,1,0,0,0,0,0,0
SID_392,15139,"Therefore, our core suppliers include major equipment, construction and O&M vendors, and their respective supply chains, which involve multi-tiered international streams with mined materials and manufacturing processes",0,0,0,0,0,1,0,0,0,0,0
SID_392,15140,GOVERNANCE AND POLICIES,0,0,0,0,0,0,0,0,0,0,0
SID_392,15141,"We recognize that strong governance is essential to sustainable business operations, and we aim to conduct our business according to the highest ethical and legal standards",0,0,0,0,0,0,0,0,0,0,0
SID_392,15142,"Our approach to addressing forced labour and child labour is designed to be commensurate with the risks we face, which vary based on several factors, including jurisdiction, industry and sector",0,0,0,0,0,0,1,0,0,0,0
SID_392,15143,"Our established policies and processes promote sound governance practices, high ethical standards and a culture where employees and other stakeholders can share any concerns",0,0,0,0,0,0,0,0,0,0,0
SID_392,15144,"All of our directors, officers, employees and temporary workers must comply with our Code of Conduct and Ethics (the Code) and our Human Rights Policy as well as all relevant policies and processes",0,0,0,0,0,0,0,1,0,0,0
SID_392,15145,Our Human Rights Policy sets out our approach to respecting fundamental human rights,0,0,0,0,0,0,0,0,0,0,0
SID_392,15146,It outlines our commitments with respect to the elimination of forced or compulsory labour and the abolition of child labour,0,0,0,0,0,0,0,1,0,0,0
SID_392,15147,"Our Human Rights Policy support the Code, which governs and reinforces the application of our commitments to human rights",0,0,0,0,0,0,0,0,0,0,0
SID_392,15148,"Brookfield Renewables board of directors (the Board) oversees our corporate sustainability policies, including our Human Rights Policy, which govern our programs and strategy",0,0,0,0,0,0,0,1,0,0,0
SID_392,15149,"Additionally, senior leadership of our operating businesses formally reviews and discusses our strategy related to human rights as part of our Sustainability Steering Committee, and we update the Board on our sustainability strategy and performance on a quarterly basis",0,0,0,0,0,0,0,0,0,0,0
SID_392,15150,"Our internal audit program is also regularly refreshed in line with the evolving sustainability landscape to ensure we have appropriate self-evaluations and verify conformance with our sustainability policies and principles, including those related to human rights, forced labour and child labour",0,0,0,0,0,0,0,1,0,0,0
SID_392,15151,"Our Vendor Code of Conduct (Vendor Code), which is regularly updated to reflect evolving best practices, outlines our expectations for vendors to comply with applicable laws and regulations, respect and support human rights, and maintain processes to identify and prevent adverse human rights impacts that could arise from their own or their supply chains operations",0,0,0,0,0,0,0,0,0,0,0
SID_392,15152,"We also work directly with our suppliers to encourage them to enhance their processes on managing forced labour and child labour risk, conduct assessments and audits, and drive traceability and diversification within the supply chain",0,0,0,0,0,0,0,1,0,0,0
SID_392,15153,"We monitor compliance with, and maintain the right to, periodically audit vendors against the Vendor Code and provide an ethics reporting hotline for anonymous reporting of any concerns or potential violations",0,0,0,0,0,0,0,0,0,0,0
SID_392,15154,Page 4,0,0,0,0,0,0,0,0,0,0,0
SID_392,15155,FORCED LABOUR AND CHILD LABOUR RISKS IDENTIFICATION AND MANAGEMENT,0,0,0,0,0,0,0,0,0,0,0
SID_392,15156,"As our business continues to grow, we are committed to respecting human rights along our value chain",0,0,0,0,0,0,0,0,0,0,0
SID_392,15157,"To assess and manage such risks, we set up systems and processes to support the identification and prevention of potential human rights risks and impacts throughout the lifecycle of our investments including at the earliest stages and within our supply chain",0,0,0,0,0,0,0,0,0,0,0
SID_392,15158,"We regularly enhance our approach, track and assess the effectiveness of our policies and procedures in relation to respecting human rights, and update them as required",0,0,0,0,0,0,0,0,0,0,0
SID_392,15159,"In 2022, in line with the UN Guiding Principles on Business and Human Rights, we conducted a human rights assessment of our global business activities in partnership with a third-party sustainability consultancy",0,0,0,0,0,0,0,1,0,0,0
SID_392,15160,The assessment reviewed our potential human rights risks and impacts across our business activities and supply chain,0,0,0,0,0,0,0,0,0,0,0
SID_392,15161,"It looked at our systems, policies and practices that serve to identify, prevent, mitigate and respond to these risks",0,0,0,0,0,0,0,0,0,0,0
SID_392,15162,"The assessment identified our salient human rights opportunities and risks within our supply chain, including occupational health and safety, labour rights and forced labour and security practices, especially in higher risk jurisdictions",0,0,0,0,0,0,0,1,0,0,0
SID_392,15163,"In particular, the assessment identified risks of forced labour within the solar power supply chain",0,0,0,0,0,0,1,0,0,0,0
SID_392,15164,"To mitigate theses potential risks, we have developed Supply Chain Sustainability Due Diligence Guidelines which help us to understand supplier-related sustainability strengths and risks, including incorporating forced labour and child labour considerations into our procurement processes",0,0,0,0,0,0,0,1,0,0,0
SID_392,15165,Due diligence is carried out on material contracts and includes assessing forced labour and child labour risks both with our direct suppliers as well as within the upstream supply chain,0,0,0,0,0,0,0,1,0,0,0
SID_392,15166,"We look to whether a vendor has a supply chain either directly or indirectly sourcing from high human rights risks countries according to the 2023 Global Slavery Index, as well as a particular focus and additional considerations for vendors within the solar panel supply chain",0,0,0,0,0,0,0,1,0,0,0
SID_392,15167,"We recognize that each of our suppliers has its own supply chain, and our vendor assessments consider this risk where appropriate and possible",0,0,0,0,0,0,0,0,0,0,0
SID_392,15168,"For our largest and most strategic suppliers, we elevate that assessment to our global head office, to ensure we have greater engagement at the corporate level from our vendors",0,0,0,0,0,0,0,0,0,0,0
SID_392,15169,"Our sustainable supply chain strategy focuses on improving environmental and social sustainability performance through policies and guidance, direct engagement, supplier partnerships, industry collaboration and encouraging improvement on supply chain transparency and traceability relating to the projects we build and operate",0,0,0,0,0,0,0,0,0,0,0
SID_392,15170,"Through our internal global sustainable supply chain working group, we share best practices, monitor performance against our goals, solicit regular feedback from our operating businesses and seek opportunities for improvement on sustainability topics related to the supply chain, including forced labour and child labour",0,0,0,0,0,0,0,1,0,0,0
SID_392,15171,"We also perform third-party risk corporate profile checks on all suppliers and conduct screenings on all new vendors, both during due diligence (ie when we acquire a new business) and on an ongoing basis thereafter, on a predetermined frequency driven by the risk category",0,0,0,0,0,0,0,1,0,0,0
SID_392,15172,Page 5,0,0,0,0,0,0,0,0,0,0,0
SID_392,15173,GRIEVANCE AND ACCESS TO REMEDY,0,0,0,0,0,0,0,0,0,0,0
SID_392,15174,We have not found any evidence of forced labour or child labour,0,0,0,0,0,0,1,0,0,0,0
SID_392,15175,"We have established an ethics reporting hotline (the Hotline) for employees, vendors, partners, community members and other interested stakeholders to anonymously report any concerns or raise any issues, including any that are related to human rights, free of discrimination, retaliation or harassment",0,0,0,0,0,0,0,1,0,0,0
SID_392,15176,Any investments or operating businesses that do not participate in our Hotline must operate an independent hotline for stakeholders,0,0,0,0,0,0,0,1,0,0,0
SID_392,15177,"Our Hotline, independently hosted and operated by a third party, is available 24/7 in multiple languages, and we regularly communicate with our employees to ensure they are aware of the Hotline",0,0,0,0,0,0,0,1,0,0,0
SID_392,15178,We investigate all reports in compliance with applicable laws as necessary,0,0,0,0,0,0,0,0,1,0,0
SID_392,15179,"All grievances reported through these channels are carefully reviewed and, where appropriate, responded to",0,0,0,0,0,0,0,0,1,0,0
SID_392,15180,"In the event that we identify that we have caused or contributed to an adverse human rights impact, we will take appropriate action to mitigate or remedy the impact",0,0,0,0,0,0,0,0,0,0,0
SID_392,15181,"When doing so we will consider all the relevant circumstances of the case including, but not limited to: (i) the extent to which Brookfield Renewable has directly caused or contributed to the impact, (ii) Brookfield Renewables ability to influence the mitigation or remedy of the impact, and (iii) any wider consequences which may flow from Brookfield Renewables action",0,0,0,0,0,0,0,0,0,0,0
SID_392,15182,We seek to promote remediation and will not impede lawful access to judicial process nor retaliate against those who have exercised their rights to raise grievances,0,0,0,0,0,0,0,1,0,0,0
SID_392,15183,Partnering for Change,0,0,0,0,0,0,0,0,0,0,0
SID_392,15184,We look to drive wider changes in the industry and within our supply chain,0,0,0,0,0,0,0,0,0,0,0
SID_392,15185,"We are a signatory to the Solar Industry Forced Labor Prevention Pledge, alongside many of our direct suppliers, to oppose the use of forced labour from within the solar supply chain and raise awareness within the industry on this important issue",0,0,0,0,0,0,0,1,0,0,0
SID_392,15186,"We also support various industry associations efforts to implement a solar supply chain traceability protocol, as a tool for identifying the source of primary raw materials and inputs and tracking their incorporation into finished solar products",0,0,0,0,0,0,0,1,0,0,0
SID_392,15187,"We participated in a cross-industry working group, including the automotive and electronics sectors, to facilitate learning from a geographically diverse group of businesses, identify and refine practices in the management of forced labour risks in high-risk geographies, and support innovation",0,0,0,0,0,0,0,1,0,0,0
SID_392,15188,"We are continuously enhancing our approach to addressing human rights in our supply chain and monitor and assess the effectiveness of our human rights program by regularly engaging with key stakeholders and refining the program, as necessary",0,0,0,0,0,0,0,0,0,1,0
SID_392,15189,EMPLOYEE TRAINING,0,0,0,0,0,0,0,0,0,0,0
SID_392,15190,"We provide regular training on our Code and wider training and communications to relevant employee groups in line with their roles and responsibilities, including Anti-Bribery Anti-",0,0,0,0,0,0,0,1,0,0,0
SID_392,15191,Page 6,0,0,0,0,0,0,0,0,0,0,0
SID_392,15192,"Corruption (ABC), Health, Safety, Security and Environmental (HSSE) training and Supply Chain Due Diligence training",0,0,0,0,0,0,0,1,0,0,0
SID_392,15193,"General human rights training has been developed for employees, which we expect to roll out over the course of 2024",0,0,0,0,0,0,0,1,0,0,0
SID_392,15194,"Required focused training on specific human rights issues is provided for select employees in certain disciplines, as required",0,0,0,0,0,0,0,0,0,0,0
SID_392,15195,MEASURE OF EFFECTIVENESS,0,0,0,0,0,0,0,0,0,0,0
SID_392,15196,"We acknowledge that there are potential forced labour and child labour risk within our supply chain, in particular within the solar panel supply chain",0,0,0,0,0,0,1,0,0,0,0
SID_392,15197,"As described in this Report we have established formal policies and process that govern our identification, assessment and mitigation of human rights risk and access to remedy",0,0,0,0,0,0,0,0,0,0,0
SID_392,15198,"We consistently review this process, utilizing our governance structure to review the effectiveness of our program and use the controls of our approval processes to ensure that these are caried forward",0,0,0,0,0,0,0,0,0,1,0
SID_392,15199,We also regularly engage with our internal and external stakeholders on this topic and have clear communication around our policies and access to grievance management mechanisms,0,0,0,0,0,0,0,1,0,0,0
SID_392,15200,We are also committed to transparency throughout our disclosure and within this Report,0,0,0,0,0,0,0,0,0,0,0
SID_392,15201,PROCESS OF CONSULTATION,0,0,0,0,0,0,0,0,0,0,0
SID_392,15202,Brookfield Renewable took a cross-functional approach to preparing and drafting this Report,0,0,0,0,0,0,0,0,0,0,0
SID_392,15203,A consultation process was undertaken,0,0,0,0,0,0,0,0,0,0,0
SID_392,15204,The Board and the board of directors of BRP Canada were given an opportunity to consider and provide comments on the Report,0,0,0,0,0,0,0,0,0,0,0
SID_392,15205,ATTESTATION,0,0,0,0,0,0,0,0,0,0,0
SID_392,15206,"Pursuant to section 11(4)(b)(i) of the Act, this Report was approved by the board of directors of Brookfield Renewables managing general partner and the board of directors of BRP Canada",1,0,0,0,0,0,0,0,0,0,0
SID_392,15207,"/s/ James Bodi Name: James Bodi Title: President May 31, 2024 I have the authority to bind Brookfield Renewable Partners Limited",0,1,0,0,0,0,0,0,0,0,0
SID_392,15208,"/s/ William Fyfe Name: William Fyfe Title: Senior Vice President, General Counsel & Secretary May 31, 2024 I have the authority to bind Brookfield BRP Canada Corp",0,1,0,0,0,0,0,0,0,0,0
SID_394,15209,2024 Report under the Fighting Against Forced Labour and Child Labour in Supply Chains Act Introduction,0,0,0,0,0,0,0,0,0,0,0
SID_394,15210,"This report has been prepared by Trinity Western University (TWU) in respect of Canadas Fighting Against Forced Labour and Child Labour in Supply Chains Act for our financial year ending April 30, 2024",0,0,0,0,0,0,0,0,0,0,0
SID_394,15211,"TWU recognizes the importance of promoting labour practices that protect the human rights of workers in Canadas supply chains, including preventing and mitigating the risks of forced labour and child labour",0,0,0,0,0,0,0,0,0,0,0
SID_394,15212,"As a Christian university, our core values are to pursue truth and excellence with grace and diligence, treat people and ideas with charity and respect, think critically and constructively about complex issues, and willingly respond to the worlds most profound needs and greatest opportunities",0,0,0,0,0,0,0,0,0,0,0
SID_394,15213,Structure,0,0,0,0,0,0,0,0,0,0,0
SID_394,15214,"Founded in 1962, TWU is a global Christian liberal arts university organized under the Societies Act and the Trinity Western University Act to offer liberal arts, sciences, and professional disciplines in business, nursing, education, human kinetics, graduate studies, and arts, media, and culture",0,0,0,1,1,0,0,0,0,0,0
SID_394,15215,"TWU is chartered by the province of British Columbia to grant baccalaureate, masters and doctoral degrees",0,0,0,1,0,0,0,0,0,0,0
SID_394,15216,We are a not-for- profit entity and a registered charity,0,0,0,1,0,0,0,0,0,0,0
SID_394,15217,"We are governed by a Board of Governors, the members of which are elected in accordance with our by-laws",0,0,0,1,0,0,0,0,0,0,0
SID_394,15218,TWUs main campus and headquarters is in Langley,0,0,0,1,0,0,0,0,0,0,0
SID_394,15219,"We also operate locations in Richmond-Lansdowne, and Richmond-Minoru, British Columbia, and Ottawa, Ontario",0,0,0,0,1,0,0,0,0,0,0
SID_394,15220,"Over 7,000 students enroll each year at TWU",0,0,0,0,0,0,0,0,0,0,0
SID_394,15221,"We have approximately 1,000 employees of which 470 are fulltime and part-time faculty",0,0,0,1,0,0,0,0,0,0,0
SID_394,15222,Our fulltime faculty are unionized,0,0,0,0,0,0,0,0,0,0,0
SID_394,15223,"We also employ approximately 500 students on short-term contracts per year to facilitate our operations of offices, libraries, labs, and other facilities, recognizing that on-campus employment can assist students in financial support, skills expansion, and experiences enrichment",0,0,0,0,0,1,0,0,0,0,0
SID_394,15224,"TWU is an active member of industry organizations and associations including BCNET, the Canadian Association of University Business Officers (CAUBO), Canadian Public Procurement Council (CPPC), and Campus Stores Canada (CPC)",0,0,0,0,0,0,0,1,0,0,0
SID_394,15225,Activities and supply chain,0,0,0,0,0,0,0,0,0,0,0
SID_394,15226,"To support our academic and operational activities and campus life, TWU procures a variety of goods and materials, including research materials, education textbooks, clothing, gifts, and other supplies",0,0,0,0,0,1,0,0,0,0,0
SID_394,15227,"Through our Campus Store, on the Langley campus and online, we sell textbooks, trade books, university- branded clothing, gifts and supplies to our students",0,0,0,1,0,0,0,0,0,0,0
SID_394,15228,"On our main Langley campus, we provide food service that is operated and sourced by a large, reputable Canadian food service and distribution company",0,0,0,0,0,1,0,0,0,0,0
SID_394,15229,"TWU is a member of BCNET, a not-for-profit, collaborative shared services organization that provides procurement services to 25 public post-secondary institutions, 16 research institutes and other higher education institutions",0,0,0,0,0,0,0,1,0,0,0
SID_394,15230,"Through BCNET, we have access to pre-screened product and service agreements that align with institutional procurement policies and confirm compliance with applicable laws",0,0,0,0,0,0,0,1,0,0,0
SID_394,15231,"In addition, our membership in CAUBO, CPPC and CPC enable us to participate in industry organizations that advocate for the development of best practices in procurement",0,0,0,0,0,0,0,1,0,0,0
SID_394,15232,TWU purchases goods from Canadian suppliers whenever possible,0,0,0,0,0,1,0,0,0,0,0
SID_394,15233,"In this reporting year, most of the goods sold on campus and used in our operations were procured from Canadian vendors",0,0,0,0,0,1,0,0,0,0,0
SID_394,15234,"Our imports are minimal in value and consist primarily of education materials, the majority of which are imported from the United States",0,0,0,0,0,1,0,0,0,0,0
SID_394,15235,"Steps taken to prevent and reduce risks of forced labour and child labour In the reporting year, TWUs approach to preventing and reducing the risks of forced labour and child labour in our academic activities and operations, and supply chain was to continue to take the following steps",0,0,0,0,0,0,0,1,0,0,0
SID_394,15236,"incorporate responsible and ethical business practices in our operations through our standards of conduct, our commitment to community, and our workplace policies",0,0,0,0,0,0,0,1,0,0,0
SID_394,15237,"address supply chain risks by applying our Contract Signing Policy and participating in industry organizations, including BCNET, CAUBO, CPPC and CPC",0,0,0,0,0,0,0,1,0,0,0
SID_394,15238,"conduct business with reputable Canadian suppliers, including a well-established food service and distribution company that has adopted a Supplier Code of Conduct in its operations, and",0,0,0,0,0,1,0,0,0,0,0
SID_394,15239,encourage reporting of conduct that contravenes applicable laws and our policies,0,0,0,0,0,0,0,1,0,0,0
SID_394,15240,Policies and due diligence,0,0,0,0,0,0,0,0,0,0,0
SID_394,15241,TWU has well-established policies and written commitments relating to ethical and value-based conduct and decision making,0,0,0,0,0,0,0,0,0,0,0
SID_394,15242,Our faculty and employees are at all times guided by our Statement of Faith and Community Covenant Agreement,0,0,0,0,0,0,0,0,0,0,0
SID_394,15243,"As well, our students sign a Student Code of Conduct as part of their commitment when studying at TWU",0,0,0,0,0,0,0,1,0,0,0
SID_394,15244,"Our mission, core values, curriculum and community life are formed by a firm commitment to the person and work of Jesus Christ as declared in the Bible",0,0,0,0,0,0,0,0,0,0,0
SID_394,15245,"The Community Covenant is a solemn pledge in which our employees place themselves under obligations to, inter alia, demonstrate concern for others, treat all persons with respect and dignity, and be responsible citizens both locally and globally who respect authorities, submit to the laws of our country, and contribute to the welfare of creation and society",0,0,0,0,0,0,0,0,0,0,0
SID_394,15246,"In our academic activities and operations, we comply with Canadian employment, labour, human rights, and safety laws and regulations",0,0,0,0,0,0,0,1,0,0,0
SID_394,15247,"Our relationship with approximately half of our faculty is governed by the terms of a collective agreement that expressly require us to provide a healthy and safe workplace, to consult the union to improve hiring procedure, and to engage compensation specialists to evaluate our compensation system",0,0,0,0,0,0,0,1,0,0,0
SID_394,15248,"We have adopted policies to protect the health and safety of our faculty, employees, and students, including",0,0,0,0,0,0,0,0,0,0,0
SID_394,15249,"a Health and Safety Policy that enables a consistent, efficient, and effective approach to risk identification, assessment and response to prevent, reduce and eliminate hazards in our campuses",0,0,0,0,0,0,0,0,0,0,0
SID_394,15250,We educate our new employees of our general and specific safety policy through orientations and onboarding trainings,0,0,0,0,0,0,0,1,0,0,0
SID_394,15251,a Student Employment Handbook that requires onboarding trainings for our student employees to ensure the labour rights protection and compliance with our Occupational Health and Safety requirements,0,0,0,0,0,0,0,1,0,0,0
SID_394,15252,"an independent office to provide both in-person and online education and training for our Bullying, Harassment and Sexualized Violences Policy on campus to faculty, staff and students",0,0,0,0,0,0,0,0,0,0,0
SID_394,15253,The Policy allows report of any incidents and provides supporting resources to our employees,0,0,0,0,0,0,0,0,0,0,0
SID_394,15254,"a Whistleblower Protection Policy that encourages our employees to report any incidents of misconducts, unlawful activities, or other accountability concerns and protects our employees, contractors, service providers and any other individuals from any form of retaliation for providing the disclosures",0,0,0,0,0,0,0,1,0,0,0
SID_394,15255,a Workplace Violence Policy to minimize and prevent violence and unacceptable behaviour in our workplace,0,0,0,0,0,0,0,0,0,0,0
SID_394,15256,We demonstrate zero tolerance to any forms of violence in our campuses,0,0,0,0,0,0,0,0,0,0,0
SID_394,15257,"In our supply chain, TWU has adopted a Contract Signing Policy that applies to the procurement of goods, equipment, and services in our operations and programs",0,0,0,0,0,0,0,1,0,0,0
SID_394,15258,"This Policy provides procedures for our officers to enter into business agreements with suppliers, ensuring our compliance with the regulation of use of funds and high standards of business ethics",0,0,0,0,0,0,0,1,0,0,0
SID_394,15259,"Given that TWU sells and imports only a small volume of goods each year, we have limited influence and leverage over the global supply chain",0,0,0,0,0,1,0,0,0,0,0
SID_394,15260,"However, our continued participation in BCNET and other industry organizations that advocate for the development of services and best practices in procurement enables TWU to support and promote responsible and ethical supply chain and procurement practices",0,0,0,0,0,0,0,0,0,0,0
SID_394,15261,Assessing risks of forced labour and child labour,0,0,0,0,0,0,0,0,0,0,0
SID_394,15262,"To date, TWU has not identified risks of forced labour or child labour in our academic and operational activities",0,0,0,0,0,0,1,0,0,0,0
SID_394,15263,"We operate in accordance with applicable laws and collective agreements that protect the rights of workers, including protection from unsafe working conditions, workplace violence, underage work, and other conditions that are indicators of forced labour and child labour",0,0,0,0,0,0,0,1,0,0,0
SID_394,15264,We have not identified risks of forced labour and child labour in our direct supply chain,0,0,0,0,0,0,1,0,0,0,0
SID_394,15265,"We procure goods for our operations and programs, primarily from Canadian suppliers who are also required to comply with laws protecting the rights of workers",0,0,0,0,0,1,1,0,0,0,0
SID_394,15266,We import a limited number of goods into Canada,0,0,0,0,0,0,0,0,0,0,0
SID_394,15267,"Through BCNET, we have access to pre-screened products that comply with relevant laws and regulations in respect of sustainability and human rights protection",0,0,0,0,0,0,0,1,0,0,0
SID_394,15268,"Our food service provider has adopted a Supplier Code of Conduct that establishes ethical standards over its supply chain, including a commitment to the human rights of workers",0,0,0,0,0,1,0,1,0,0,0
SID_394,15269,We rely on this reputable Canadian company to establish due diligence processes to ensure that this code of conduct is respected in its extended supply chain,0,0,0,0,0,0,0,0,0,0,0
SID_394,15270,Remediation measures and remediation of loss of income,0,0,0,0,0,0,0,0,0,0,0
SID_394,15271,TWU has established remediation processes that enable our employees to report conduct is in contravention of applicable laws and our policies,0,0,0,0,0,0,0,0,0,0,0
SID_394,15272,Our Whistleblower Protection Policy protects and encourages reporting by employees who have reason to believe that there has been a contravention of any law or that any wrongdoing has been (or is about to be) committed,0,0,0,0,0,0,0,1,0,0,0
SID_394,15273,Employees can report without fear of reprisal,0,0,0,0,0,0,0,1,0,0,0
SID_394,15274,"TWU is not aware of any incidents or reports of forced labour or child labour in respect to our operations or supply chain, and as such, has not taken any remediation measures or remediation of loss of income to families as a result of forced labour or child labour",0,0,0,0,0,0,1,0,0,0,0
SID_394,15275,Employee training,0,0,0,0,0,0,0,0,0,0,0
SID_394,15276,TWU provides training to our employees (including student employees) relating to health and safety and human rights on our campuses as required by applicable laws and our collective agreements,0,0,0,0,0,0,0,1,0,0,0
SID_394,15277,"To date, we have not developed training specifically related to forced labour and child labour in our supply chains",0,0,0,0,0,0,0,1,0,0,0
SID_394,15278,Assessing the effectiveness of our approach,0,0,0,0,0,0,0,0,0,0,0
SID_394,15279,"TWU has established measures to assess in our operations and monitor compliance of our workers, contractors and suppliers with the standards set out in our Health and Safety Policy",0,0,0,0,0,0,0,0,0,0,0
SID_394,15280,"Beyond our safety assessments, to date we have not adopted specific assessment mechanisms to assess measure and track the effectiveness of steps taken to prevent or reduce the risks of forced labour or child labour",0,0,0,0,0,0,0,0,0,1,0
SID_394,15281,Approval and attestation,0,0,0,0,0,0,0,0,0,0,0
SID_394,15282,"In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for the entity listed above",0,0,0,0,0,0,0,0,0,0,0
SID_394,15283,"Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above",0,0,0,0,0,0,0,0,0,0,0
SID_394,15284,"Dated in the Township of Langley, British Columbia, this ___ day of May, 2024",0,0,0,0,0,0,0,0,0,0,0
SID_394,15285,"____________________________________ Dr Mark Husbands, President & Vice-Chancellor I have the authority to bind Trinity Western University",0,1,0,0,0,0,0,0,0,0,0
SID_394,15286,th,0,0,0,0,0,0,0,0,0,0,0
SID_396,15402,Danaher Group Report on Forced Labor and Child Labor in Supply Chains,0,0,0,0,0,0,0,0,0,0,0
SID_396,15403,"This joint report is made pursuant to section 11 of the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the ""Act"") and constitutes our Group's report on forced labor and child labor for the financial year ended December 31, 2023",0,0,0,0,0,0,0,0,0,0,0
SID_396,15404,Danaher Corporation as a parent company issues this joint report on behalf of itself and each of its direct and indirect subsidiaries listed on Exhibit 21.1 of Danaher Corporations most recent Annual Report on Form 10-K (the Annual Report) filed with the United States Securities and Exchange Commission that are reporting entities under the Act,0,0,0,1,0,0,0,0,0,0,0
SID_396,15405,"For the purposes of this joint report, Danaher Corporation and each of its subsidiaries subject to the Act are collectively referred to as Danaher",0,0,0,0,0,0,0,0,0,0,0
SID_396,15406,"At Danaher, we remain committed to building our enterprise with integrity and this informs our approach to dealing with our investors, business partners, customers, associates, suppliers, and the numerous communities in which we operate around the world",0,0,0,0,0,0,0,0,0,0,0
SID_396,15407,Danaher is committed to protecting and advancing human rights and it seeks to protect against violations of human rights in its operations and its supply chains,0,0,0,0,0,0,0,0,0,0,0
SID_396,15408,We fully support both the Act and the equivalent anti-slavery and human trafficking legislation in force in the countries in which we operate,0,0,0,0,0,0,0,0,0,0,0
SID_396,15409,Danaher remains committed to managing and mitigating the risk of modern slavery and human trafficking in connection with its operations and supply chain and to acting ethically and with integrity in all our business dealings and relationships,0,0,0,0,0,0,0,0,0,0,0
SID_396,15410,We expect adherence to the same high standards from our suppliers and other business partners and we expect that our suppliers will hold their own suppliers to the same high standards,0,0,0,0,0,0,0,0,0,0,0
SID_396,15411,"Our Supplier Code of Conduct underscores our suppliers compliance obligations and the consequences for them of non-compliance, as well as spelling out our expectations with respect to their own supply chain",0,0,0,0,0,0,0,0,0,0,0
SID_396,15412,Our Business and Structure Danaher is a global science and technology innovator committed to helping our customers solve complex challenges and improving quality of life around the world,0,0,0,0,1,0,0,0,0,0,0
SID_396,15413,"Our business is organised into three segments: Biotechnology, Life Sciences, and Diagnostics",0,0,0,0,1,0,0,0,0,0,0
SID_396,15414,"Further details about these segments and the key brands that are included in them can be found in Danaher Corporations most recent Annual Report, which is posted on Danahers public website, www.danaher.com",0,0,0,1,1,0,0,0,0,0,0
SID_396,15415,"Our Supply Chains As a global science and technology innovator, Danaher has a complex supply chain that spans numerous jurisdictions",0,0,0,0,1,1,0,0,0,0,0
SID_396,15416,"As discussed in further detail below, we seek to work with our suppliers to understand areas of risks relevant to slavery, forced labor, child labor and human trafficking, and we seek to mitigate identified risks as applicable",0,0,0,0,0,0,0,0,0,0,0
SID_396,15417,Our Policies Relevant to Slavery and Human Trafficking Danahers Code of Conduct expresses the fundamental expectation that each Danaher employee acts with the highest level of integrity and in compliance with all applicable laws and Danaher policies,0,0,0,0,0,0,0,0,0,0,0
SID_396,15418,The Code of Conduct also provides specific guidance on how to answer common integrity and compliance questions that arise during the ordinary course of Danaher business,0,0,0,0,0,0,0,0,0,0,0
SID_396,15419,"Danahers Sustainability Mission Statement emphasizes that We drive and sustain sustainability improvements throughout our areas of impact, including with our customers (through our products, services and solutions) and in our commercial organization, supply chain, operations, workplace, communities and environment",0,0,0,0,0,0,0,0,0,0,0
SID_396,15420,"Danahers Supplier Code of Conduct (the Code) establishes our expectation that suppliers who do business with Danaher comply with all applicable laws, act with integrity, respect human and employment rights, promote the safety and health of employees, operate in an environmentally responsible manner, and implement management systems to drive compliance, risk mitigation and continuous improvement",0,0,0,0,0,0,0,0,0,0,0
SID_396,15421,Our policies relevant to slavery and human trafficking are,0,0,0,0,0,0,0,1,0,0,0
SID_396,15422,Danaher's Code of Conduct,0,0,0,0,0,0,0,1,0,0,0
SID_396,15423,Danahers Sustainable Supply Chain Policy,0,0,0,0,0,0,0,1,0,0,0
SID_396,15424,Danahers Supplier Code of Conduct,0,0,0,0,0,0,0,1,0,0,0
SID_396,15425,Danaher's Conflict Minerals Policy Statement,0,0,0,0,0,0,0,1,0,0,0
SID_396,15426,Grievance Mechanism Danaher maintains an Integrity and Compliance Helpline to enable our employees to speak up if they know of or suspect any conduct that may compromise our policies or violate applicable laws,0,0,0,0,0,0,0,1,0,0,0
SID_396,15427,"The helpline is available to all employees to raise all forms of concern they may have, anonymously if requested, including those relating to human rights issues",0,0,0,0,0,0,0,1,0,0,0
SID_396,15428,Reports to the Danaher Integrity and Compliance Helpline of violations of law or Danaher policies are rigorously investigated,0,0,0,0,0,0,0,0,1,0,0
SID_396,15429,Due Diligence and Risk Assessment Processes,0,0,0,0,0,0,0,0,0,0,0
SID_396,15430,EcoVadis Supplier Sustainability Assessments,0,0,0,0,0,0,0,0,0,0,0
SID_396,15431,"Danaher has partnered with EcoVadis to assess and monitor Danahers suppliers in the areas of: Environmental, Labor and Human Rights, Ethics and Supplier Sustainability, with the objective of aligning supplier performance with our sustainability values",0,0,0,0,0,0,0,1,0,0,0
SID_396,15432,EcoVadis describes itself as the worlds largest and most trusted provider of business sustainability ratings,0,0,0,0,0,0,0,0,0,0,0
SID_396,15433,Supplier Risk Assessment/Risk Management,0,0,0,0,0,0,0,0,0,0,0
SID_396,15434,Our supply chain risk assessment/risk management program incorporates supplier financial and risk data from external providers as well as Danaher internal data,0,0,0,0,0,0,0,1,0,0,0
SID_396,15435,Key elements of the program include the following,0,0,0,0,0,0,0,0,0,0,0
SID_396,15436,"Tier 1 direct material suppliers (as well as Tier 2+ direct material suppliers deemed significant and indirect suppliers deemed significant) are required to be scored based on their impact on Danahers revenues, the suppliers financial health and any Danaher source limitations with respect to the supplied product",0,0,0,0,0,0,0,1,0,0,0
SID_396,15437,"Danaher engages a third-party supply chain data monitoring and predictive analytics platform designed to enhance supply chain risk management, to continuously monitor media and other publicly available data sources to identify risks relating to its direct material suppliers",0,0,0,0,0,0,0,1,0,0,0
SID_396,15438,"The monitoring encompasses dozens of risk categories, including financial, weather-related, cyber, geopolitical and other risk types",0,0,0,0,0,0,0,0,0,0,0
SID_396,15439,We require any supplier who exceeds a specified risk assessment score to develop and implement a risk management plan (RMP),0,0,0,0,0,0,0,1,0,0,0
SID_396,15440,"The RMP may include financial monitoring, business continuity planning, supplier training/development, additional contractual provisions and tooling assessments",0,0,0,0,0,0,0,1,0,0,0
SID_396,15441,o We also require any supplier whose revenue impact and source limitation scores exceed a specified level to develop and implement a supplier emergency response plan,0,0,0,0,0,0,0,0,0,0,0
SID_396,15442,Danaher leaders and leaders of our operating companies are required to review the program status for their respective businesses on a regular basis,0,0,0,0,0,0,0,0,0,0,0
SID_396,15443,Danahers corporate trade compliance function also screens Danahers suppliers on a quarterly basis using a tool that aggregates publicly available data and government-provided information regarding suppliers who may be implicated in the use of forced labor,0,0,0,0,0,0,0,1,0,0,0
SID_396,15444,"While the screening tool is not necessarily comprehensive due to the fragmented nature of the available data, it is an important asset in Danahers efforts to mitigate the risk of forced labor in our supply chain",0,0,0,0,0,0,0,0,0,0,0
SID_396,15445,Risks in our Operations and Supply Chains We have assessed our risk profile based on applicable sector and industry risks as low,0,0,0,0,0,0,1,0,0,0,0
SID_396,15446,We believe we have fair and responsible employment practices in place to protect and promote workers rights,0,0,0,0,0,0,0,0,0,0,0
SID_396,15447,"We seek to continue improving our efforts to classify supplier risks and map our supply chain, to support improvement in our understanding of modern slavery risks",0,0,0,0,0,0,0,0,0,0,0
SID_396,15448,"Remediation Measures To date we have not discovered any instances of modern slavery or human trafficking in our business and supply chains, therefore, we have not been required to take and have not taken remedial measures",0,0,0,0,0,0,1,0,1,0,0
SID_396,15449,"Training our Employees To help ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we require procurement employees to participate in annual training on human rights and other key Danaher policies and values, including human trafficking, employee health and safety, responsible environmental practices, anti-corruption, business ethics and data and intellectual property protection",0,0,0,0,0,0,0,1,0,0,0
SID_396,15450,Supplier Adherence and Tracking Performance; Our Effectiveness in Combating Slavery and Human Trafficking With the objective of aligning supplier performance with our sustainability values and maintaining and continually improving supplier performance in this area,0,0,0,0,0,0,0,0,0,0,0
SID_396,15451,"We regularly review the policies described above, which establish guidelines for our suppliers with respect to key social and environmental issues such as child labor, slavery and human trafficking, freedom of association and environmental compliance",0,0,0,0,0,0,0,0,0,1,0
SID_396,15452,"Through our supply chain risk assessment/risk management program, we assess and manage risks relating to key suppliers (including risks relating to forced labor); and",0,0,0,0,0,0,0,1,0,0,0
SID_396,15453,"As described above, we have engaged EcoVadis to assess and monitor key suppliers in the areas of Environmental, Labor and Human Rights, Ethics and Supplier Sustainability to further drive the integration of our sustainability values across the supply chain",0,0,0,0,0,0,0,1,0,0,0
SID_396,15454,We expect to continue engaging with EcoVadis in an effort to ensure the effectiveness of our supply chain due diligence processes,0,0,0,0,0,0,0,0,0,0,0
SID_396,15455,"This report was approved on May 7, 2024 pursuant to delegation of authority granted by the Board of Directors of Danaher Corporation in accordance with Paragraph 11(4)(b)(ii) of the Fighting Against Forced Labour and Child Labour in Supply Chains Act",1,0,0,0,0,0,0,0,0,0,0
SID_396,15456,"In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for the entity or entities listed above",0,0,0,0,0,0,0,0,0,0,0
SID_396,15457,"Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above",0,0,0,0,0,0,0,0,0,0,0
SID_396,15458,Rainer M,0,1,0,0,0,0,0,0,0,0,0
SID_396,15459,"Blair President, Chief Executive Officer and Director",0,1,0,0,0,0,0,0,0,0,0
SID_396,15460,"May 7, 2024",0,0,0,0,0,0,0,0,0,0,0
SID_399,15636,"July 3, 2024",0,0,0,0,0,0,0,0,0,0,0
SID_399,15637,RE: MODERN SLAVERY REPORT FOR RENEWABLE ENERGY SYSTEMS CANADA INC,0,0,0,0,0,0,0,0,0,0,0
SID_399,15638,INTRODUCTION,0,0,0,0,0,0,0,0,0,0,0
SID_399,15639,"This Report is prepared on behalf of Renewable Energy Systems Canada Inc (RES Canada, or the Company) and describes the actions taken by RES Canada during the financial year ending October 31, 2023 (Reporting Period) to assess, prevent and reduce the risk that forced labour or child labour is used at any step in its operations and supply chains pursuant to the requirements of Canadas Fighting Against Forced Labour and Child Labour in Supply Chains Act (Act)",0,0,0,0,0,0,0,0,0,0,0
SID_399,15640,"In this Report, RES Canada uses the term Forced Labour to encompass both forced labour and child labour",0,0,0,0,0,0,0,0,0,0,0
SID_399,15641,This Report constitutes the first report prepared by RES Canada under the Act,0,0,0,0,0,0,0,0,0,0,0
SID_399,15642,"RES Canada and its parent group of companies, the RES Group (RES Group or, when used collectively with RES Canada, RES), supports the eradication and prevention of Forced Labour in all its forms including slavery, servitude and forced or compulsory labour, and human trafficking",0,0,0,0,0,0,0,0,0,0,0
SID_399,15643,"RES does not permit, under any circumstances, the use of forced labour in its business and expect full compliance with all applicable legislation in this area",0,0,0,0,0,0,0,0,0,0,0
SID_399,15644,"ORGANIZATIONAL STRUCTURE, ACTIVITIES, AND SUPPLY CHAINS RES GROUP",0,0,0,0,0,0,0,0,0,0,0
SID_399,15645,RES is a global business that develops and manages large scale renewable energy projects and related infrastructure,0,0,0,0,1,0,0,0,0,0,0
SID_399,15646,"Headquartered in the United Kingdom, RES is the worlds largest independent renewable energy company and has been at the forefront of the renewable energy industry for more than 40 years",0,0,0,1,1,0,0,0,0,0,0
SID_399,15647,"Over that period, RES has delivered more than 22 GW of renewable energy projects, and also currently supports a diverse global operational generation portfolio exceeding 9 GW",0,0,0,0,0,0,0,0,0,0,0
SID_399,15648,"RES employs more than 3,000 people globally and is has office in 20 countries, with each country being led by a country manager with input from RES Group senior management",0,0,0,1,1,0,0,0,0,0,0
SID_399,15649,"It has strong in-house engineering and technical capability and operates in 4 main technology areas: onshore and offshore wind, solar, storage and electricity transmission / distribution",0,0,0,0,1,0,0,0,0,0,0
SID_399,15650,RES CANADA,0,0,0,0,0,0,0,0,0,0,0
SID_399,15651,"RES Canada is involved in the development, construction, and management of renewable energy projects",0,0,0,0,1,0,0,0,0,0,0
SID_399,15652,"The company operates across various segments of the renewable energy sector, including wind, solar, energy storage, and transmission",0,0,0,0,1,0,0,0,0,0,0
SID_399,15653,The key activities and services provided by RES Canada are summarized below,0,0,0,0,1,0,0,0,0,0,0
SID_399,15654,"Project Development Site Identification and Analysis: Identifying and assessing potential sites for renewable energy projects based on factors such as resource availability (wind speeds, solar irradiance), land use, and environmental impact",0,0,0,0,1,0,0,0,0,0,0
SID_399,15655,"Permitting and Regulatory Compliance: Securing the necessary permits and approvals from local, regional, and national regulatory bodies",0,0,0,0,1,0,0,0,0,0,0
SID_399,15656,This includes environmental impact assessments and community consultations,0,0,0,0,1,0,0,0,0,0,0
SID_399,15657,"Renewable Energy Systems Canada Inc 5605 avenue de Gasp, bureau 508 Montral, Qubec H2T 2A4, Canada 514 525 2113 | info@res-group.com",0,0,0,0,0,0,0,0,0,0,0
SID_399,15658,Land Acquisition: Negotiating land leases or purchases for the development of renewable energy projects,0,0,0,0,1,0,0,0,0,0,0
SID_399,15659,"Engineering, Procurement, and Construction (EPC) Design and Engineering: Providing detailed design and engineering services to optimize the performance and efficiency of renewable energy installations",0,0,0,0,1,0,0,0,0,0,0
SID_399,15660,"Procurement: Sourcing high-quality components and materials, such as wind turbines, solar panels, inverters, and balance of plant (BOP) equipment, from reputable suppliers",0,0,0,0,1,0,0,0,0,0,0
SID_399,15661,"Construction Management: Overseeing the construction process, including site preparation, installation of renewable energy systems, and commissioning of the projects to ensure they meet quality, safety, and performance standards",0,0,0,0,1,0,0,0,0,0,0
SID_399,15662,"Operations and Maintenance (O&M) Monitoring and Control: Utilizing advanced monitoring systems to oversee the performance of renewable energy assets in real-time, ensuring they operate efficiently and reliably",0,0,0,0,1,0,0,0,0,0,0
SID_399,15663,Maintenance Services: Conducting routine and preventive maintenance to maximize the lifespan and performance of the renewable energy systems,0,0,0,0,1,0,0,0,0,0,0
SID_399,15664,This includes troubleshooting and repairs as needed,0,0,0,0,1,0,0,0,0,0,0
SID_399,15665,Asset Management: Providing comprehensive management services to optimize the financial and operational performance of renewable energy projects,0,0,0,0,1,0,0,0,0,0,0
SID_399,15666,"Energy Storage Solutions Battery Energy Storage Systems (BESS): Designing and deploying energy storage solutions that complement renewable energy projects, providing grid stability, and enhancing energy reliability and flexibility",0,0,0,0,1,0,0,0,0,0,0
SID_399,15667,Integration with Renewable Projects: Ensuring seamless integration of storage systems with wind and solar installations to optimize energy usage and management,0,0,0,0,1,0,0,0,0,0,0
SID_399,15668,"Transmission and Infrastructure Grid Connection: Developing the necessary infrastructure to connect renewable energy projects to the electrical grid, including substations and transmission lines",0,0,0,0,1,0,0,0,0,0,0
SID_399,15669,"Grid Services: Providing services that support grid stability and reliability, such as frequency regulation and demand response",0,0,0,0,1,0,0,0,0,0,0
SID_399,15670,"Sustainability and Innovation Sustainable Practices: Committing to sustainable development practices that minimize environmental impact, promote biodiversity, and support local communities",0,0,0,0,0,0,0,0,0,0,0
SID_399,15671,"Research and Development: Investing in R&D to innovate and enhance renewable energy technologies, improve efficiency, and reduce costs",0,0,0,0,1,0,0,0,0,0,0
SID_399,15672,Consulting and Advisory Services Feasibility Studies: Conducting comprehensive feasibility studies to evaluate the potential and viability of renewable energy projects,0,0,0,0,1,0,0,0,0,0,0
SID_399,15673,"Project Financing: Assisting in securing financing for projects through partnerships, investors, and financial institutions",0,0,0,0,1,0,0,0,0,0,0
SID_399,15674,Strategic Planning: Providing strategic advice and planning services to optimize renewable energy portfolios and investment decisions,0,0,0,0,1,0,0,0,0,0,0
SID_399,15675,"Community Engagement Stakeholder Engagement: Engaging with local communities, stakeholders, and indigenous groups to ensure projects are developed with their input and support",0,0,0,0,1,0,0,0,0,0,0
SID_399,15676,Corporate Social Responsibility (CSR): Implementing CSR initiatives that benefit local communities and contribute to sustainable development,0,0,0,0,1,0,0,0,0,0,0
SID_399,15677,"RES Canadas supply chain is integral to its operations, focusing on the development, construction, and management of renewable energy projects",0,0,0,0,0,0,0,0,0,0,0
SID_399,15678,Heres an overview of RES Canada's supply chain and component sourcing: Wind Turbines and Solar Panels: Sourcing wind turbines and solar panels from leading manufacturers using the due diligence policies and procedures described in this Report,0,0,0,0,0,1,0,0,0,0,0
SID_399,15679,"Balance of Plant (BOP) Components: This includes electrical systems, substations, transformers, and other necessary infrastructure components, typically sourced from specialized manufacturers",0,0,0,0,0,1,0,0,0,0,0
SID_399,15680,"Overall, RES Canada's supply chain is designed to support its goal of delivering high-quality renewable energy projects efficiently and sustainably",0,0,0,0,0,0,0,0,0,0,0
SID_399,15681,"It involves a comprehensive approach that integrates sourcing, logistics, project management, and maintenance, all underpinned by a commitment to sustainability and innovation",0,0,0,0,0,0,0,0,0,0,0
SID_399,15682,POLICIES AND DUE DILIGENCE PROCESSES,0,0,0,0,0,0,0,0,0,0,0
SID_399,15683,"RES Canada works within and applies a policy framework set at the RES Group level, which includes: RES Group Supply Chain Code of Conduct (Supply Code of Conduct), RES Group procurement policies and RES Group Modern Slavery and Human Trafficking Policy",0,0,0,0,0,0,0,1,0,0,0
SID_399,15684,Supply Code of Conduct,0,0,0,0,0,0,0,0,0,0,0
SID_399,15685,"The supply code of conduct sets out minimum behavioral standards that RES expects of its partners and suppliers in all countries in which RES operates or procures goods and services, all employees including subcontracted labour, and all suppliers of goods and services",0,0,0,0,0,0,0,0,0,0,0
SID_399,15686,"This includes standards in relation to modern slavery, human rights and labour practices",0,0,0,0,0,0,0,1,0,0,0
SID_399,15687,Our supply chain partners must not engage in or benefit from forced or compulsory labour or human trafficking in any form,0,0,0,0,0,0,0,1,0,0,0
SID_399,15688,"Employees must have the freedom of movement during their employment and the right to terminate their contracts at any time, provided they give reasonable notice",0,0,0,0,0,0,0,1,0,0,0
SID_399,15689,"Wages, identity cards, travel documents, or other essential documents must not be withheld to prevent an employee from leaving their job",0,0,0,0,0,0,0,1,0,0,0
SID_399,15690,"Recruitment fees or ""deposits"" from workers are prohibited, and no employment fees or costs should be charged, either fully or partially, to employees",0,0,0,0,0,0,0,1,0,0,0
SID_399,15691,The use of child labour is strictly prohibited in our operations and throughout our supply chain,0,0,0,0,0,0,0,1,0,0,0
SID_399,15692,"RES Supply Code of Conduct is being progressively applied to its key global suppliers and other suppliers, either contractually, or as a separate instrument signed by a senior representatives of the supplier",0,0,0,0,0,0,0,1,0,0,0
SID_399,15693,Procurement Policies,0,0,0,0,0,0,0,0,0,0,0
SID_399,15694,"RES procurement policies take account of the principles behind relevant global initiatives, including the UN Global Compact and Ethical Trading Initiative Base Code",0,0,0,0,0,0,0,0,0,0,0
SID_399,15695,RES is a member of the United Nations Global Compact (UNGC) reinforcing its dedication to sustainable business practices,0,0,0,0,0,0,0,1,0,0,0
SID_399,15696,RES works with a broad supply chain including specialist equipment manufacturers,0,0,0,0,0,1,0,0,0,0,0
SID_399,15697,We believe that our suppliers should be working to ensure modern slavery does not occur,0,0,0,0,0,0,0,0,0,0,0
SID_399,15698,"This includes our suppliers subcontractors, who may use temporary and agency employees",0,0,0,0,0,1,0,0,0,0,0
SID_399,15699,Modern Slavery and Human Trafficking Policy,0,0,0,0,0,0,0,0,0,0,0
SID_399,15700,RES Groups Modern Slavery and Human Trafficking Policy sets out RES Groups commitment to do all that is reasonably practicable to support the eradication and prevention of modern slavery and human trafficking,0,0,0,0,0,0,0,1,0,0,0
SID_399,15701,"Like the Supply Code of Conduct, this policy applies to RES business activities in all countries in which RES operates or procures goods and services and all employees including subcontracted labour",0,0,0,0,0,0,0,1,0,0,0
SID_399,15702,Due Diligence,0,0,0,0,0,0,0,0,0,0,0
SID_399,15703,"RES periodically reviews risks related to modern slavery, focusing on major suppliers with a global manufacturing footprint, such as those providing wind turbines and electrical equipment for our projects",0,0,0,0,0,0,0,1,0,0,0
SID_399,15704,We have addressed the modern slavery issues with some of our closest partners in this sector,0,0,0,0,0,0,0,1,0,0,0
SID_399,15705,"Measures taken by these partners include membership in the UN Global Compact, the publication of human rights policies, the establishment of sustainability committees, codes of conduct, and communication routes for staff specifically addressing business ethics",0,0,0,0,0,0,0,1,0,0,0
SID_399,15706,"Additionally, RES conducts social and environmental due diligence on projects and implements responsible supply chain management practices, which include a code of conduct for suppliers, the monitoring of their suppliers, audits, and follow-up actions",0,0,0,0,0,0,0,0,0,0,0
SID_399,15707,RISK OF FORCED LABOUR BEING USED AND REMEDIATION MEASURES,0,0,0,0,0,0,0,0,0,0,0
SID_399,15708,"In assessing the risk in relation to Forced Labour, RES Canada works with suppliers of major equipment to identify any component manufacturing or sourcing from countries that could be considered higher risk (by reference to the latest edition of The Global Slavery Index)",0,0,0,0,0,0,0,1,0,0,0
SID_399,15709,"Through this RES Canada has identified that the vast majority of its project development, construction and operation activities are all taking place in countries considered relatively low-risk and take the steps set out above in relation to the activities of our supply chain",0,0,0,0,0,0,1,0,0,0,0
SID_399,15710,"Despite this, RES Canada has identified forced labour risks associated with the types of products it produces, purchases or distributes and the types of products it sources, based on the locations of where some of its components are indirectly sourced from",0,0,0,0,0,0,1,0,0,0,0
SID_399,15711,"During the Reporting Period, RES Canada did not identify any instances of Forced Labour in its activities and supply chains",0,0,0,0,0,0,1,0,0,0,0
SID_399,15712,"Further, during the Reporting Period RES Canada did not identify any instances of loss of income of the vulnerable families as a result of the steps RES Canada has taken to eliminate risks of Forced Labour",0,0,0,0,0,0,0,0,0,0,0
SID_399,15713,"For this reason, no remediation measures regarding these issues has been necessary",0,0,0,0,0,0,0,0,1,0,0
SID_399,15714,TRAINING,0,0,0,0,0,0,0,0,0,0,0
SID_399,15715,"At the moment, RES Canada does not provide a training dedicated to Forced Labour issues specifically",0,0,0,0,0,0,0,1,0,0,0
SID_399,15716,ASSESSING EFFECTIVENESS,0,0,0,0,0,0,0,0,0,0,0
SID_399,15717,"Though RES Canada does not currently have in place significant measures to assess its effectiveness in combatting Forced Labour, RES does conduct regular reviews and audits of its policies and procedures concerning Forced Labour and, in these reviews, considers how these policies and procedures could be improved",0,0,0,0,0,0,0,0,0,1,0
SID_399,15718,"RES Canada employs a systematic approach to audit its policies and procedures to ensure compliance, efficiency, and continuous improvement",0,0,0,0,0,0,0,0,0,1,0
SID_399,15719,"Internal Audits Regular Internal Reviews: Conducting regular internal audits to review compliance with company policies, industry standards, and regulatory requirements",0,0,0,0,0,0,0,1,0,1,0
SID_399,15720,These audits help identify areas for improvement and ensure adherence to best practices,0,0,0,0,0,0,0,0,0,0,0
SID_399,15721,"Departmental Audits: Each department, such as procurement, health and safety, environmental compliance, and project management, may undergo periodic audits to ensure they follow established protocols and guidelines",0,0,0,0,0,0,0,0,0,1,0
SID_399,15722,"Compliance Audits Regulatory Compliance: Ensuring compliance with local, provincial, and national regulations through regular audits",0,0,0,0,0,0,0,0,0,0,0
SID_399,15723,"This includes environmental regulations, health and safety standards, and industry-specific requirements",0,0,0,0,0,0,0,0,0,0,0
SID_399,15724,"Contract Compliance: Auditing compliance with contractual obligations to partners, suppliers, and clients, ensuring all terms and conditions are met",0,0,0,0,0,0,0,1,0,0,0
SID_399,15725,On-site Audits: Auditing compliance with subcontractors ensuring all terms and conditions are met,0,0,0,0,0,0,0,1,0,0,0
SID_399,15726,"Continuous Improvement Feedback Mechanisms: Implementing systems to collect feedback from employees, clients, and stakeholders",0,0,0,0,0,0,0,0,0,1,0
SID_399,15727,This feedback is used to continuously improve policies and procedures,0,0,0,0,0,0,0,0,0,0,0
SID_399,15728,Corrective Actions: Establishing a framework for corrective actions based on audit findings,0,0,0,0,0,0,0,0,1,0,0
SID_399,15729,"This includes identifying root causes, implementing solutions, and monitoring the effectiveness of these actions",0,0,0,0,0,0,0,0,0,0,0
SID_399,15730,Governance and Oversight Board and Executive Oversight: Ensuring that the board of directors and executive management provide oversight of the auditing process,0,0,0,0,0,0,0,1,0,0,0
SID_399,15731,"This includes reviewing audit reports, endorsing corrective actions, and monitoring compliance",0,0,0,0,0,0,0,0,0,1,0
SID_399,15732,"Audit Committees: Establishing dedicated audit committees that oversee the auditing process, ensuring it is thorough, unbiased, and aligned with the companys strategic objectives",0,0,0,0,0,0,0,0,0,1,0
SID_399,15733,"By employing a combination of these methods, RES Canada can effectively audit its policies and procedures, ensuring they are robust, compliant, and aligned with industry best practices",0,0,0,0,0,0,0,0,0,0,0
SID_399,15734,APPROVAL AND ATTESTATION,0,0,0,0,0,0,0,0,0,0,0
SID_399,15735,This Report was approved pursuant to subparagraph 11(4)(a) of the Act by the Board of Directors of Renewable Energy Systems Canada Inc,1,0,0,0,0,0,0,0,0,0,0
SID_399,15736,"In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the Report for the entity or entities listed above",0,0,0,0,0,0,0,0,0,0,0
SID_399,15737,"Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the Report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above",0,0,0,0,0,0,0,0,0,0,0
SID_399,15738,"Full name: Andr Cangu Title: President and Chief Executive Officer Date: July 3, 2024",0,0,0,0,0,0,0,0,0,0,0
SID_399,15739,Signature,0,0,0,0,0,0,0,0,0,0,0
SID_399,15740,I have the authority to bind Renewable Energy Systems Canada Inc,0,0,0,0,0,0,0,0,0,0,0
SID_399,15741,RESOLUTIONS OF THE DIRECTORS of SYSTMES D'NERGIE RENOUVELABLE CANADA INC,0,0,0,0,0,0,0,0,0,0,0
SID_399,15742,and its version RENEWABLE ENERGY SYSTEMS CANADA INC,0,0,0,0,0,0,0,0,0,0,0
SID_399,15743,(the Corporation),0,0,0,0,0,0,0,0,0,0,0
SID_399,15744,"The undersigned, being all of the directors of the Corporation, and being entitled to vote on the resolutions hereinafter set forth as if the same had been submitted at a meeting of the directors of the Corporation duly called and held for the purpose of acting on such resolutions, do hereby resolve, in lieu of a meeting of the directors of the Corporation as follows",0,0,0,0,0,0,0,0,0,0,0
SID_399,15745,Annual Report,0,0,0,0,0,0,0,0,0,0,0
SID_399,15746,RECITALS,0,0,0,0,0,0,0,0,0,0,0
SID_399,15747,"On or before May 31, 2024, the Corporation is required to report (the Report) to the Minister of Public Safety and Emergency Preparedness under the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Act) on the steps the Corporation has taken during its previous financial year to prevent and reduce the risk that forced child labour is used at any step of the production of goods in Canada or elsewhere by the Corporation or of goods imported into Canada by the Corporation",0,0,0,0,0,0,0,0,0,0,0
SID_399,15748,The Corporation is also required to complete a questionnaire (the PSC Questionnaire) when submitting the Report,0,0,0,0,0,0,0,0,0,0,0
SID_399,15749,"A Report and PSC Questionnaire were filed by the Corporation on May 31, 2024",0,0,0,0,0,0,0,0,0,0,0
SID_399,15750,The Corporation is seeking to file revised versions of the Report and PSC Questionnaire,0,0,0,0,0,0,0,0,0,0,0
SID_399,15751,A Draft of the revised version of the Report has been provided to the directors of the Corporation,0,0,0,0,0,0,0,0,0,0,0
SID_399,15752,"THAT pursuant to paragraph 11(4) of the Act, the Report in the form of draft provided to the directors of the Company is authorized and approved",0,0,0,0,0,0,0,0,0,0,0
SID_399,15753,"THAT each director and officer of the Company, acting alone, is authorized to do all such acts deliver all such other documents as in such directors or officers opinion may be necessary or desirable to complete the transactions hereby approved and authorized",0,0,0,0,0,0,0,0,0,0,0
SID_399,15754,General,0,0,0,0,0,0,0,0,0,0,0
SID_399,15755,"THAT the present resolutions may be executed by the parties hereto by means of electronic mail or telecopy; they may also be executed in separate counterparts, each of which, when so executed, shall be an original, but all such counterparts together shall constitute one and the same document",0,0,0,0,0,0,0,0,0,0,0
SID_399,15756,[Signature page follows],0,0,0,0,0,0,0,0,0,0,0
SID_399,15757,"THE FOREGOING RESOLUTIONS ARE HEREBY CONSENTED TO AND SIGNED BY THE DIRECTORS OF THE CORPORATION, THE WHOLE PURSUANT TO THE BUSINESS CORPORATIONS ACT (QUBEC), AS OF JULY 3, 2024",0,0,0,0,0,0,0,0,0,0,0
SID_399,15758,Eduardo Medina,0,0,0,0,0,0,0,0,0,0,0
SID_399,15759,Andr Cangu,0,0,0,0,0,0,0,0,0,0,0
SID_399,15760,Henrik Brandt,0,0,0,0,0,0,0,0,0,0,0
SID_399,15761,Douglas McAlpine,0,0,0,0,0,0,0,0,0,0,0