In August 2023, the Board approved a zero-tolerance Statement on Forced and Child Labour (our “Forced Labour Statement”) which is attached to the Report as Schedule “A” and available on our Investors Relations website. Our Forced Labour Statement highlights that AutoCanada is a people-driven company that upholds values such as integrity, one of our core values, and is opposed to any form of modern slavery. Our intention is to continue to share our Forced Labour Statement with certain of our large suppliers and confirm that they are aligned with this position.

AutoCanada’s corporate governance framework is supported by a number of policies, documents and practices, a number of which are related to or affirm our zero-tolerance stance on modern slavery.

AutoCanada’s Code of Business Conduct (the “Code of Conduct”) requires AutoCanada and all its directors, officers, employees and consultants (“AutoCanada Personnel”) to adhere to the highest ethical standards and to comply with all applicable laws. More specifically, the Code of Conduct articulates the following: “AutoCanada and all AutoCanada Personnel shall comply with the letter and spirit of all laws and regulations applicable to AutoCanada’s activities. A concern for what is right must underlie all business decisions.” The Code of Conduct further provides that all AutoCanada personnel are “encouraged to report, verbally, or in writing any evidence of improper practice of which they are aware” with the term "improper practice" meaning “any illegal, fraudulent, dishonest, unsafe, negligent or otherwise unethical action by a director, officer, employee or consultant.” AutoCanada Personnel are required to certify their understanding of and adherence to the Code of Conduct once every two years.

AutoCanada’s Whistleblower Policy (the “Whistleblower Policy”) encourages the reporting, including confidential reporting, of questionable business practices, including suspected cases of modern slavery. Notably, the Whistleblower Policy encourages the prompt reporting of “all evidence of activity by [AutoCanada], any director, officer, employee or consultant that may constitute any of the following: (1) breaches of the Code of Conduct; and (2) breaches of any statute, law, legislation, rule or law governing the operations of the [AutoCanada]’s business and operations”. Any allegations of these wrongdoings will be further investigated under the Whistleblower Policy. Taken together, AutoCanada’s Code of Conduct and Whistleblower Policy seeks to ensure that the conduct of all AutoCanada Personnel and overall business operations are in accordance with our corporate values, policies and expectations and at all times remain compliant with the Act.

AutoCanada has implemented a recent practice that prior to entering into significant agreements with a given supplier or service provider, AutoCanada may conduct a review of a supplier’s or service provider’s governance practices and policies regarding modern slavery. This allows AutoCanada to assess a supplier’s adherence better and compliance with the Act and confirm that its business operations do not involve forced labour or child labour before entering into any formal agreement. In furtherance of the foregoing, AutoCanada may consider requesting the inclusion of a provision in certain contracts in which suppliers or service providers covenant that they will comply with all applicable laws and/or confirm that neither they nor their supply chains engage in or are aware of any modern slavery within their supply chain. In implementing its contractual affirmation procedures to date,
AutoCanada has taken a contextual approach based on: (1) the perceived risks associated with the supplier or service provider; (2) the length of the business relationship between AutoCanada and the supplier or service provider; and (3) AutoCanada’s understanding of the strength of the supplier’s or service provider’s own human rights and modern slavery policies and practices.