mila-ai4h/AIMS.au huggingface dataset:
[SID_298] Additionally, the Reporting Entities will endeavour to review policies and procedures related to forced labour and child labour
[SID_298] Conclusion and Approval The Reporting Entities will endeavor to regularly assess progress and identify areas of improvement
[SID_298] 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
[SID_298] 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
[SID_298] 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
[SID_298] 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
[SID_298] Stephen Johnston signed Director May 31, 2024
[SID_298] I have the authority to bind Equicapita Income LP and Equicapita Income Trust
[SID_301] 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)
[SID_301] This Report is made on behalf of Jim Pattison Developments Ltd (JPD) and is not a joint report
[SID_301] Page 2 of 6
[SID_301] INTRODUCTION Forced labour and child labour, each as defined in the Act, are crimes and serious violations of human rights
[SID_301] 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
[SID_301] 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
[SID_301] II
[SID_301] CORPORATE OVERVIEW AND SUPPLY CHAINS Company Structure and Background JPD is a private corporation incorporated in December 2001 under business registration number 122022882 BC0001
[SID_301] JPD is a company of The Jim Pattison Group which has been in operation since December 2001
[SID_301] 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
[SID_301] The leadership team provides the framework and support for each of its departments daily operations
[SID_301] 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
[SID_301] 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)
[SID_301] The JPD portfolio includes the largest portfolio of grocery anchored shopping centres in British Columbia and Alberta
[SID_301] Our portfolio overall is conservatively valued at over $4 billion
[SID_301] 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
[SID_301] In addition, JPD undertakes independent projects which span retail, office, industrial, and residential development
[SID_301] Page 3 of 6 Supply Chain JPDs supply chain includes businesses that are based in both Canada and the United States
[SID_301] These businesses provide contractual services and products in final form to our company on an as required basis
[SID_301] 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
[SID_301] 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
[SID_301] This process includes planning for the required needs, budgeting, sourcing of goods and services using a competitive analysis and evaluation of reputable suppliers
[SID_301] 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
[SID_301] While in 2023, JPD procured goods and services from approximately 896 suppliers and contractors with total expenditures being approximately $124 million
[SID_301] 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
[SID_301] While in 2023, JPDUS procured goods and services from approximately 88 suppliers and contractors with total expenditures being approximately $66 million
[SID_301] III
[SID_301] 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
[SID_301] We are committed to consistently evolve and improve our approach and policies
[SID_301] JPD is committed to maintaining high ethical standards and conducting legitimate business practices
[SID_301] This is the foundation of our company, its policies, and principles
[SID_301] JPD strives on professionalism and lawful and ethical conduct of its employees
[SID_301] 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
[SID_301] 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
[SID_301] Through our Whistleblower Policy, we encourage the identification and prevention of any misconduct that may impact our commitment
[SID_301] 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
[SID_301] 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
[SID_301] 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
[SID_301] 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
[SID_301] 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
[SID_301] To mitigate this risk, we follow a due diligence approach that includes the following steps
[SID_301] Supplier visits
[SID_301] Supplier confirmation; and
[SID_301] Embedding responsible business conduct into policies and management systems
[SID_301] IV
[SID_301] RISK ASSESSMENT AND MANAGEMENT JPD intends to engage in various activities to identify, assess, and manage supplier risk
[SID_301] In assessing the risk of forced and child labour in our business and supply chains, we will engage with our peers to discuss risks
[SID_301] To identify the business activities with the greatest exposure to these risks, we consider the following factors
[SID_301] Reliance on low skilled workforce
[SID_301] Dangerous or undesirable work; and
[SID_301] Presence of migrant workers
[SID_301] 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
[SID_301] 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
[SID_301] As such, we continue to follow a risk-based approach to our due diligence activities
[SID_301] 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
[SID_301] 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
[SID_301] Page 5 of 6
[SID_301] MODERN SLAVERY REMEDIATION MEASURES JPD requires our suppliers to adhere to high standards of ethical conduct
[SID_301] Forced and child labour is strictly prohibited
[SID_301] We also undertake diligence efforts to ensure that the risk of forced labour and child labour is mitigated in our business
[SID_301] 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
[SID_301] Suspension or termination of a supplier, sub-supplier or contractor
[SID_301] Actions to prevent forced labour or child labour and associated harms from reoccurring
[SID_301] Actions to support victims of forced labour or child labour
[SID_301] Grievance mechanisms; and
[SID_301] Formal apologies
[SID_301] VI
[SID_301] LOSS OF INCOME REMEDIATION MEASURES JPD does not currently have measures in place to remediate any forced or child labour in our supply chain
[SID_301] 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
[SID_301] VII
[SID_301] 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
[SID_301] Employees are educated on our values and policies and informed of how to report wrongdoing under our Whistleblower Policy
[SID_301] We provide employees with ongoing and periodic training opportunities to ensure that all employees have current knowledge
[SID_301] All personnel ensure the applicable policies and procedures are provided to all suppliers
[SID_301] JPD currently does not have specific training measures in place on forced and child labour
[SID_301] VIII
[SID_301] ASSESSING EFFECTIVENESS Monitoring Approach JPD monitors compliance with our policies on an ongoing basis
[SID_301] We also review any concerns raised through our Whistleblower Policy and other informal mechanisms of employee feedback
[SID_301] To date, no significant concerns or complaints have been identified
[SID_301] We also assess the effectiveness of our policies by
[SID_301] Setting up a regular review or audit of the organizations policies and procedures related to forced labour and child labour; and
[SID_301] 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
[SID_301] 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
[SID_301] 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
[SID_301] IX
[SID_301] 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
[SID_301] This Report will be made available on our company website (www.jpdevelopments.com)
[SID_301] 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
[SID_301] 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
[SID_301] Date: May 31, 2024 Jim Pattison Developments Ltd Per: __________________________ David Bell, President I have the authority to bind the Company
[SID_302] 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)
[SID_302] 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
[SID_302] 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
[SID_302] Over the years, Melloul-Blamey has continued to evolve and adapt to the ever-changing construction market
[SID_302] Today, we offers a full range of services to meet the needs of our clients
[SID_302] Melloul-Blameys portfolio of services includes: general contracting, construction management, design-build, real estate development services, specialty contracts and green building
[SID_302] As of December 31, 2023, Melloul-Blamey had approximately 260 employees
[SID_302] Melloul-Blamey does not manufacture goods or handle raw materials
[SID_302] As a construction company, Melloul-Blamey works with more than 800 suppliers and subcontractors
[SID_302] 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
[SID_302] In the future we are planning to put in place an effective forced labour and child labour risk mitigation program
[SID_302] 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
[SID_302] No other action was taken by Melloul- Blamey in this area during the Reporting Period
[SID_302] Policies, Due Diligence and Controls At the moment, Melloul-Blamey does not have policies regarding forced labour, child labour or human rights in general
[SID_302] We have not developed due diligence processes or controls in regards to these topics
[SID_302] 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
[SID_302] 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
[SID_302] 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
[SID_302] 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
[SID_302] However, our risk assessment process with respect to this issue is currently non existence
[SID_302] We expect to set-up a compliance program to address this issue in the future
[SID_302] 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
[SID_302] 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
[SID_302] 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
[SID_302] 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
[SID_302] 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
[SID_302] Our consultation and governance process In preparing this Report, we have consulted our external legal counsel
[SID_302] 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
[SID_302] Conclusion We are committed to preventing forced labour and child labour from taking place in our businesses and in our supply chain
[SID_302] Accordingly, we expect to develop policies, procedures and practices to address these risks in the future
[SID_302] 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
[SID_302] Based
[SID_302] 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
[SID_302] Dated this 15th day of May, 2024 Mellloul-Blamey Construction Inc
[SID_302] Per: /s/ Joel Melloul
[SID_302] Joel Melloul, Director, I have the authority to bind Melloul-Blamey Construction Inc
[SID_304] 2023 Report American Textile Company, Incorporated (ATC) is a Pennsylvania corporation entirely owned by its holding company American Textile Company, Incorporated (a Delaware corporation)
[SID_304] ATC is a manufacturer and distributor of utility bedding including pillows, mattress protectors, and other bedding items
[SID_304] ATC maintains its corporate headquarters in Duquesne, Pennsylvania, USA
[SID_304] ATC does not have any employees in Canada
[SID_304] ATC has over 1,000 employees located primarily in the United States, with a small office in Shanghai, China
[SID_304] ATC serves as importer of record to Canada for one retail customer
[SID_304] ATC is aware of the risk of forced labor and child labor particularly in textile mills and vets all supplier and partners
[SID_304] ATC will not engage suppliers or partners if ATC suspects the entity is involved in forced labor or child labor
[SID_304] ATCs suppliers are located primarily in China, India and Pakistan
[SID_304] For the year 2023 ATC and its auditors not identified any evidence of slavery or child labor in ATCs supply chain
[SID_304] 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
[SID_304] 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
[SID_304] Audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains
[SID_304] ATC has an independent third party audit its suppliers compliance with ATCs standards for slavery and child labor in its supply chain
[SID_304] Our suppliers are on varying audit schedules which are scheduled, announced and confirmed with our suppliers
[SID_304] 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
[SID_304] 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)
[SID_304] Internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking
[SID_304] ATC maintains internal accountability standards and procedures applicable to both employees and contractors who may fail to meet company standards
[SID_304] If an employee fails to meet the accountability standards and procedures they are subject to disciplinary action which may include termination
[SID_304] 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
[SID_304] 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
[SID_304] 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
[SID_304] ATC also reports pursuant to, and has fulfilled the requirements of, the California Transparency in Supply Chains Act
[SID_304] ATTESTATION AND SIGNATURE PAGE FOLLOWS