DocuSign Envelope ID: 6B6F5620-7AE2-4999-A25F-0C12E83D0734

Roquette Canada Ltd. | a member of theRoquette Group2024 Reportto the Minister of Public Safety Regarding Forced Labour and Child Labour
Pursuant to Bill S-211, An Act to Enact the Fighting Against Forced Labour andChild Labour in Supply Chains Act and to amend the Customs Tariﬀ(“Modern Slavery Act”)
Fiscal Year 2023

DocuSign Envelope ID: 6B6F5620-7AE2-4999-A25F-0C12E83D0734

1. Roquette Canada Ltd.’s structure, activities, and supply chains.
Structure. At Roquette, we are united behind a shared purpose – oﬀering the best of nature. Roquette
Canada Ltd. (hereinafter “Roquette Canada”) is part of the Roquette Group, a global leader in plantbased ingredients and a supplier of pharmaceutical excipients. Roquette Canada is incorporated under
the laws of Canada and is located at 40117 Road 65N, Portage la Prairie, MB R1N 3B5. Roquette Canada
is a subsidiary of Roquette Frères, which has global headquarters in France. Roquette Canada, as amember of the Roquette Group and a subsidiary of Roquette Frères, substantially relies upon theeﬀorts of the Roquette Group and Roquette Frères for the purposes of managing and monitoring its
supply chain operations and compliance programs.
Roquette Canada has one location in Canada, a pea protein plant in Portage la Prairie, located outsideof Winnipeg, in Manitoba. Roquette Canada employs between 100 to 125 employees. Roquette
Canada is not a federal Crown corporation or a subsidiary of a federal Crown corporation. Roquette
Canada is submitting this Report based on its 2023 ﬁnancial year and this is its ﬁrst report for thistopic; this is not an amendment of a prior report nor is it a joint report.
Activities and Supply Chain. Globally, the Roquette Group is a family-owned global leader in plantbased ingredients and a leading provider of pharmaceutical excipients. Founded in 1933, the company
currently operates in more than 100 countries, through more than 30 manufacturing sites, andemploys around 10,000 people worldwide. In 2021, Roquette Canada’s new pea protein plant opened
and is focused on the business of converting yellow peas into various products for its customers
including pea protein and starch. Roquette Canada procures goods and raw materials from Canada
and the United States and sells pea protein and starch to customers both within Canada and outsideof Canada, largely to the United States, Mexico and China.

2. The steps the entity has taken during its previous financial year to preventand 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.
The Roquette Group and Roquette Canada are committed to reducing the risk of forced labour andchild labour both in Canada and globally. Our ethics and compliance strategy is founded on theRoquette values, our Code of Conduct, and our SpeakUp system. Compliance with applicable laws andthe principles of integrity, honesty, and ethical business practices are at the heart of who we are, theproducts and services we deliver, and how we conduct ourselves.
The Roquette Group and Roquette Canada have taken a number of steps in ﬁscal year 2023 to preventand reduce the risk that forced labour or child labour is used in the production of goods in Canada orelsewhere.
Speciﬁcally, Roquette Canada maintains a Supplier Code of Conduct based on several foundational
documents: the Universal Declaration of Human Rights, the principles of the United Nations GlobalRoquette Canada Ltd.

2A member of the Roquette GroupDocuSign Envelope ID: 6B6F5620-7AE2-4999-A25F-0C12E83D0734

Compact, the International Labor Organization convention, and Roquette’s own Code of Conduct. TheSupplier Code of Conduct says that suppliers shall prohibit forced labor and child labor in compliancewith, among others, the fundamental ILO conventions. Roquette Canada enforces and measurescompliance with the Supplier Code of Conduct through various measures explained more fully
throughout this Report.
Roquette Canada requires all suppliers, vendors and contractors that do business with Roquette toagree to comply with the Supplier Code of Conduct as part of the contract and purchase order that issigned, as well as through the initial vendor onboarding process that is mandatory for all newsuppliers, vendors and contractors. Roquette’s contracts also allow Roquette to terminate a supplier,vendor or contractor if they violate the Supplier Code of Conduct. The Roquette Supplier Code ofConduct is publicly available at Roquette Supplier Code of Conduct.
Additionally, as identiﬁed below in more detail, in 2023 Roquette Canada conducted trainings for its
employees, used a whistleblowing program to identify complaints regarding violations of the Code ofConduct, utilized a background check system to perform vetting and due diligence of its clients,
suppliers and all other relevant third parties, and has maintained membership in the UN Global
Compact which proclaims as one of its ten principles the elimination and abolition of forced and childlabour.
For more speciﬁc details on the steps that Roquette Canada has taken on these topics in 2023, pleaserefer to the Non-Financial Performance Statement 2023 Report which is publicly available at Roquette
Sustainability Report.

3. Roquette Canada’s policies and its due diligence processes in relation toforced labour and child labour.
The Roquette values are authenticity, excellence, well-being, and forward-looking. These values shape
all that we do.
The Roquette Group and Roquette Canada have a Global Code of Conduct that strictly and expressly
forbids all forms of modern slavery, including forced labor and human traﬃcking, as well as forbidding
all forms of labor for children under the minimum age set by International Labor Organization (ILO)
standards. The Roquette Global Code of Conduct is publicly available at Roquette Code of Conduct.
The Code of Conduct is incorporated into Roquette’s terms and conditions of sale that it uses with its
customers, and is also part of Roquette’s mandatory onboarding and training of all employees as
further described below.
Roquette Canada has set up several channels for whistleblowers so that any employee can reportbehavior they feel breaches the above fundamental rights to their line manager or to the HumanResources department. A whistleblowing system called SpeakUp has been set up, which is ananonymous digital platform open to all employees as well as external partners. The whistleblower
guide guarantees the protection of any whistleblower acting in good faith and the absence of any
retaliatory measures of any form or nature whatsoever. This guide is available on the intranet in theRoquette Canada Ltd.

3A member of the Roquette GroupDocuSign Envelope ID: 6B6F5620-7AE2-4999-A25F-0C12E83D0734

Group’s nine languages. Anyone can call to report a complaint anonymously. Roquette is committed
to maintaining a “Speak Up” culture by promoting an open and trusting dialogue with employees at
all levels and other stakeholders. Roquette advises its employees that if they wish to report a potential
violation of the law, or improper or unethical behavior, they may raise a question or report a concern
using the Roquette Speak Up system. Roquette protects those who Speak Up and raise concerns
appropriately; Roquette does not retaliate against anyone who raises a concern, or against those whoassist in investigations of suspected violations.
Additionally, Roquette Canada uses a background check software called Exiger to vet and perform due
diligence over all clients, suppliers, and third parties. The software detects both adverse media reports
and articles as well as criminal or legal violations related to both child labour and forced labour of any
third party. Roquette Canada would not work with a third party that has been found to be in violationof forced labour or child labour laws or policies.
Finally, Roquette Group and Roquette Canada’s commitments towards the prevention of forced labourand child labour are further evidenced by Roquette’s membership in the UN Global Compact, aninitiative that identiﬁes ten principles for corporate sustainability and a principles-based approach to
doing business. This includes operating in ways that, at a minimum, meet fundamental responsibilities
in the areas of human rights, labour, environment, and anti-corruption. Responsible businesses enact
the same values and principles wherever they have a presence. The UN principle number four is forthe elimination of all forms of forced and compulsory labour and principle number ﬁve is for theeﬀective abolition of child labour. The UN Global Compact page showing Roquette’s membership is
publicly available at Roquette | UN Global Compact and the UN Global Compact ten principles are
publicly available at The Ten Principles | UN Global Compact.

4. The parts of Roquette Canada’s business and supply chains that carry a riskof forced labour or child labour being used and the steps it has taken toassess and manage that risk.
Roquette Canada recognizes that the Act requires entities to identify parts of their activities and supply
chains that carry a risk of forced labour or child labour; however, identifying parts of an entity’s
activities and supply chains that carry a risk does not require indicating that forced labour or childlabour was or is actually being used.
Roquette Canada has considered the ways in which its activities and supply chains could potentiallycause, contribute to or be directly or indirectly linked to actual or potential risk that forced labour orchild labour is used, and, although Roquette Canada has not identiﬁed any forced labor and child laborwithin its own activities or within its supply chain, Roquette Canada has nonetheless implemented
strict hiring policies, such that every new employee has to sign the Roquette Code of Conduct toensure that no underage employees are hired and all new hires are on a voluntary basis, both of which
are part of Roquette Canada’s human resources policies.
With regard to supply chain, Roquette Canada recognizes that the risk cannot be eliminated in thesupply of raw materials by farmers, however, to minimize this risk, every supplier has to sign theRoquette Supplier Code of Conduct and spot audits will be performed.
Roquette Canada Ltd.

4A member of the Roquette GroupDocuSign Envelope ID: 6B6F5620-7AE2-4999-A25F-0C12E83D0734

Additionally, Roquette recently performed corruption risk mapping and theoretical risks have been
identiﬁed; the solution to prevent against such theoretical risks will be ad hoc auditing.

5. Any measures taken to remediate any forced labour or child labour.
Roquette Canada is not aware of a situation where remedial actions have been necessary. Roquette
Canada will continue to educate its employees and enforce its policies going forward.

6. Any measures taken to remediate the loss of income to the mostvulnerable families that results from any measure taken to eliminate theuse of forced labour or child labour in its activities and supply chains.
Roquette Canada is not aware of a situation where remedial actions for loss of income have beennecessary. Roquette Canada will continue to educate its employees and enforce its policies goingforward.

7. The training provided to employees on forced labour and child labour.
Roquette Canada requires all employees to be trained each year on the Global Code of Conduct.
Additionally, Roquette’s Code states that each employee is responsible for being familiar with andcomplying with all applicable labor laws and regulations, and reporting any behaviors which go against
any individual’s fundamental rights to a manager or the Human Resources Department.
In 2023, training sessions were conducted on site and in person by the Chief Compliance Oﬃcer andlocal Roquette Canada management. The training covered all areas of the corporate due diligenceobligations including the ﬁght against forced labor and child labor. One of the objectives of the training
was to explain that big companies such as Roquette have speciﬁc obligations and enhanced
responsibility to monitor and remedy the potential adverse impacts of its own activities and those ofits value chain on human rights and on the environment.

8. How the entity assesses its effectiveness in ensuring that forced labour andchild labour are not being used in its business and supply chains.
To reduce and prevent the risk of forced and child labour within our operations and supply chains, weassess the eﬀectiveness of our actions to continuously improve our compliance program.
Roquette Canada closely monitors the whistleblowing alerts that are received and each case isinvestigated by a neutral alert committee at a corporate level. Sanctions are systematically applied
where a breach is substantiated. So far no breach relating to forced labor and child labor has been
demonstrated within Roquette Group or Roquette Canada. In addition, both the compliance function
and the implementation of the compliance program are subject to regular internal and external audits.

Roquette Canada Ltd.

5A member of the Roquette GroupDocuSign Envelope ID: 6B6F5620-7AE2-4999-A25F-0C12E83D0734

Additionally, in 2023 the Roquette Group conducted corruption risk mapping in order to determine
strengths and weaknesses for diﬀerent types of risks, and forced labour and child labour were includedin the mapping.
The table below identiﬁes a comprehensive picture of all eﬀorts taken by Roquette Group.
Activity
Governance

Measuring Eﬀectiveness• Mandatory employee compliance with Global Code ofConduct upon onboarding•

Annual mandatory Code of Conduct training for allemployees globally•

Required adherence by Suppliers to Supplier Code ofConduct•

Inclusion of Code of Conduct in terms and conditions ofsale with customers

Engagement•

Membership to UN Global Compact identifying ten
principles of corporate social responsibility includingprohibition and abolition of forced and child labour

Enterprise Risk Management•

Corruption risk mapping

Monitoring•

Vendor and supplier due diligence and screening throughExiger•

Ad hoc audits, internal and external•

Right to audit vendors and suppliers included indownstream contracts•Speak Up, an anonymous online / phone platform
operated by an independent provider, with alerts
monitored by committee and investigated without
retaliation

Grievance Mechanism

9. Attestation.
This Report was approved by our Board of Directors on May 24, 2024.
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. BasedRoquette Canada Ltd.

6A member of the Roquette GroupDocuSign Envelope ID: 6B6F5620-7AE2-4999-A25F-0C12E83D0734

on my knowledge, and having exercised reasonable diligence, I attest that the information in thereport is true, accurate and complete in all material respects for the purposes of the Act, for thereporting year listed above.

__________________________________________

Brendon Boland

Chief Financial Officer of Roquette Canada Ltd.
May 24, 2024
I have the authority to bind Roquette Canada Ltd.

Roquette Canada Ltd.

7A member of the Roquette Group