Annual Report 2023:
Canada Fighting Against Forced and Child Labour Act
This disclosure is provided pursuant to the Canada Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “Act”) with respect to Cardinal Glass Industries, Inc. and any of its subsidiaries (Cardinal IG Company, Cardinal GG Company, Cardinal FG Company, Cardinal CT Company and Cardinal LG Company) that are subject to the Act (“Cardinal Companies”). This is not an admission that any of the Cardinal® Companies is subject to the Act if, in fact, such entity is not subject to the Act.
Cardinal Companies do not knowingly use “child labour” or “forced labour,” as defined under the Act, in their activities or supply chains. Cardinal Companies include in their standard Purchase Order Term and Conditions required representations that neither the supplier nor the supplier’s subcontractors/suppliers use any form of slave labor, forced, bonded or indentured labor, illegal prison labor, illegal child labor, and do not physically abuse their workers or engage in human trafficking or sexual exploitation. Cardinal Companies also generally obligate suppliers in supply agreements to comply with all applicable laws, including, without limitation, child labor and forced labor laws.
Each of the Cardinal Companies was similarly operated and addressed matters relating to forced labour and child labour in the same manner. (a) Each of the Cardinal Companies was a corporation. The Cardinal Companies engaged in business relating to the manufacture, processing, and sale of glass and insulating glass units primarily for use in residential window applications. Materials were obtained by each of the Cardinal Companies separately from third party suppliers although certain of the Cardinal Companies received a substantial portion of their materials from the other Cardinal Companies. (b) Cardinal Companies’ standard Purchase Order Term and Conditions required representations that the supplier, the supplier’s subcontractors/suppliers do not use any form of slave labor, forced, bonded or indentured labor, illegal prison labor, illegal child labor, and do not physically abuse their workers, engage in human trafficking or sexual exploitation. Cardinal Companies entered a number of supply agreements requiring the applicable suppliers to comply with applicable laws, including laws relating to forced labour and child labour. Cardinal Companies’ personnel and executives with significant industry experience and knowledge met from time to time to evaluate the business practices of suppliers to assess them, including with respect to risks associated with forced labour and child labour. Diligence processes were based on the evaluated risk of forced labour and child labour. (c) International suppliers or sub-tier suppliers of materials are believed to carry the greatest risk of forced labour and child labour in the supply chain of the Cardinal Companies. The steps taken to assess and manage risk of forced labour and child labour are stated in (b) above. (d) Not applicable, no forced labour or child labour was identified and no measures were taken to remediate forced labour and child labour. (e) Not applicable, no loss of income to the most vulnerable families was identified that results from any measure taken to eliminate the use of forced labour or child labour in Cardinal Companies activities and supply chain given that no forced labour or child labour was identified at Cardinal Companies or in its supply chain. (f) Human resource personnel were trained with respect to employment law which include applicable legal prohibitions on forced labour or child labour. (g) The Cardinal Companies assessed their effectiveness in ensuring that forced labour and child labour are not being used in their businesses and supply chains during the meetings referenced in (b) above. The Cardinal Companies intend to continue to monitor for indicators of forced labour and child labour in their supply chains and intend to take appropriate action if forced labour or child labour in their businesses or their supply chains is suspected or identified.
This report has been approved pursuant to Section 11(4)(b)(ii) by the Board of Directors of Cardinal Glass Industries, Inc.