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Compliance Report: Fighting Against Forced Labour and Child Labour in Supply Chains Act

Date: May 16, 2024
Prepared for: Minister of Public Safety
Prepared by: Greg Dickie, President of Atlantic All-Weather Windows Ltd

Introduction

This initial report is prepared by Atlantic All-Weather Windows Ltd. for the Fiscal Year ending Jan 31,
2024, in compliance with the requirements of Canadian Bill S-211, also known as the Fighting Against
Forced Labour and Child Labour in Supply Chains Act. The purpose of this report is to outline the
measures taken by the company to combat forced labour and child labour within its supply chains.

Structure, Activities and Supply Chains

Headquartered in Port Elgin, New Brunswick, Atlantic All-Weather Windows Ltd. Is a manufacturer of
windows and entrance systems, with operations and employees only in Canada. Being a Canadiancontrolled private corporation (CCPC), the company is incorporated in the province of New Brunswick
under business number 100323252 and is considered an entity as defined by the Act.

Atlantic All-Weather Windows Ltd. strives to use North American based suppliers and/or distributors for
all components used in our products and any finished goods intended for resale. Some of these
suppliers and/or distributors may source components or finished products from outside of North
America, which in turn may be supplied to our company. Atlantic All-Weather Windows Ltd. does not
directly import finished goods outside of Canada for direct sale to consumers.

Policy Statement and Due Diligence

Atlantic All-Weather Windows Ltd acknowledges its responsibility to uphold human rights standards and
ensure that forced labour and child labour are prohibited within its supply chain. The company is
committed to ethical sourcing practices and maintaining transparency throughout its supply chain
processes.

To mitigate the risk of forced labour and child labour, the following due diligence procedures have been
implemented:

• Supplier Code of Conduct: Atlantic All-Weather Windows Ltd has established a Supplier Code of
  Conduct that outlines our expectations regarding labour standards, including prohibitions
  against forced labour and child labour. Suppliers are required submit a Declaration of
  Compliance affirming adherence to these standards as a condition of doing business with the
  company.
• Supply Chain Transparency: Atlantic All-Weather Windows Ltd maintains transparency within its
  supply chains by mapping out the various tiers of suppliers and subcontractors involved in the
  production process. This enables the identification of potential risks and take appropriate action
  to address them. A list of current suppliers is available at www.atlanticwindows.com.

Risk Mitigation

To identify potential risks of forced labour and child labour within its supply chains, Atlantic All-Weather
Windows Ltd references the World Vision Canada’s Top Risky Goods by Import Value and the Bureau of
International Labor Affairs (ILAB) List of Countries At Risk to Use Child Labour or Forced Labour to
evaluate the potential risk relative to the geographical regions, suppliers, and subcontractors involved in
the production and distribution of their products.

Remediation and Accountability

In case an instance of forced labour or child labour are identified within its supply chains, Atlantic AllWeather Windows Ltd is committed to taking swift and decisive action, committing to work its partners
on remediation measures, which may include termination of contracts with non-compliant suppliers,
providing support to affected workers, and implementing corrective actions to prevent future
occurrences.

Atlantic All-Weather Windows Ltd is dedicated to transparency and accountability in our efforts to
combat forced labour and child labour. An annual report will provide progress on implementation and
enforcement of the anti-forced labour and child labour policies, including any challenges encountered
and steps taken to address them.

Training

With respect to continuous improvement, Atlantic All-Weather Windows Ltd established a committee to
learn about the Act and how to apply the requirements in practice, making suppliers and other partners
aware of the importance of the Act, and their responsibilities as part of its supply chains.

Assessing Effectiveness

The target by the end of Fiscal 2025 is to ensure all partners are aware of the Act and each supplier
submits a signed Declaration of Compliance (or similar) affirming adherence to these standards. Beyond
this, no actions have been taken to assess the effectiveness in preventing and reducing risks of forced
labour and child labour in the activities and supply chains.

Conclusion

In accordance with the requirements of Canadian Bill S-211, Atlantic All-Weather Windows Ltd is
committed to upholding the highest standards of ethical sourcing and labour practices within its supply
chains. By implementing robust due diligence procedures, fostering transparency, and holding itself and
its suppliers accountable, aiming to prohibit forced labour and child labour from its operations and
contribute to a more sustainable and ethical global supply chain.

Please feel free to reach out if you require any further information or clarification regarding Atlantic AllWeather Windows Ltd.’s compliance with the Fighting Against Forced Labour and Child Labour in Supply
Chains Act.  Click here to see our suppliers.

See our Vendors here.

Sincerely,
Greg Dickie, P.Eng | President
Atlantic All-Weather Windows Ltd