Joint Compliance Report to Law S-211 for Automobiles Delec Inc. (ALBI le Géant) and its Subsidiary 9317-3771 QUEBEC INC (Chevrolet GM Laval)

Reporting Year: December 31, 2023

This report details the measures taken by ALBI le Géant to comply with Law S-211 and meet the requirements regarding the prevention of forced labor and child labor in its operations and supply chains.

1. Measures Taken to Prevent and Mitigate the Risk of Forced Labor and Child Labor

• Commitment: ALBI le Géant is committed to preventing any form of forced labor or child labor in its operations and supply chain. As a retailer with 11 car dealerships in Quebec, ALBI le Géant has not been able to assess the risk with our various international manufacturers to determine if they have used forced labor or child labor in their supply chains.
  
  
• Lack of Preventive Measures: ALBI le Géant has not applied any preventive measures concerning the potential risk of forced labor and child labor in the supply chains of manufacturers, given that we have no oversight, influence, visibility, impact, or other means of risk assessment due to the retailer/manufacturer business relationship.
  
  
• Future Actions: ALBI le Géant will evaluate the feasibility of obtaining information from the manufacturers of our concerned dealerships: Hyundai Canada, GM Canada, and Mazda Canada, to understand how they prevent and mitigate the risk of forced labor or child labor in their supply chains.
  
  

2. Structure, Activities, and Supply Chains

• Structure: ALBI le Géant is a group of car dealerships operating in Mascouche, Repentigny, Laval, St-Eustache, Mont-Tremblant, and Saint-Agathe, with eleven dealerships in Quebec and over 600 employees, all located in Quebec.
  
  
• Activities: Our activities include the sale and purchase of new and used vehicles, as well as related services such as parts sales and vehicle repair services. The new vehicle brands sold to Canadian consumers by ALBI le Géant are from international manufacturers, including Nissan, Kia, Hyundai, GM, Chevrolet, Genesis, Mazda, and Volvo. Additionally, ALBI le Géant sells all brands of used vehicles in Quebec, purchased directly from the Canadian market, auctions, competing dealerships, or our customers.
  
  
• Supply Chains: New vehicles sold by ALBI le Géant are imported by Canadian entities of the manufacturers and then purchased by one of our eleven dealerships to be sold at retail to Canadian consumers. As for parts, sourcing is also done directly from Canadian automotive manufacturers or other Canadian parts retailers.
  
  

3. Policies and Due Diligence Processes Related to Forced Labor and Child Labor

• Current State: ALBI le Géant has not yet implemented policies or due diligence processes with manufacturers regarding forced labor and child labor. However, ALBI le Géant will consider working in partnership with automotive manufacturers to ensure that best practices are applied and efforts are made to guarantee ethical working conditions throughout the supply chain.
  
  

4. Parts of the Business and Supply Chains with Risk of Forced Labor or Child Labor and Measures Taken to Assess and Manage This Risk

• Risk Areas: We estimate that the parts at risk of forced labor or child labor in automotive supply chains are likely among the parts suppliers and component manufacturers used by the manufacturers for vehicle assembly. As a retailer, we do not know the complete origin of the parts, nor do we know from what raw materials they were all made. We are aware that mining is probably an industry with a high risk of forced labor or child labor in certain regions of Africa or Asia. ALBI le Géant does not know the original source of the metals for all parts used in the supply chain by various manufacturers, nor their subcontractors, nor the regions selected for raw material extraction. There is a risk at this level if the manufacturers have not properly and diligently selected their subcontractors to avoid the risk of forced labor or child labor.
  
  
• Visibility: Due to our position as a vehicle and parts retailer, we have no visibility into the supply chain or the selection of suppliers and subcontractors chosen by any of our manufacturers. Currently, it is impossible for us to know the measures taken by various international manufacturers to assess and manage this risk.
  
  

5. Measures Taken to Remedy the Use of Forced Labor or Child Labor

• Current Measures: ALBI le Géant has taken no measures to remedy forced labor or child labor in the activities and supply chains of manufacturers, given our retailer relationship with automotive manufacturers and the lack of visibility on their subcontractor selection.
  
  

6. Measures Taken to Address Income Losses of the Most Vunerable Families Resulting from Measures to Eliminate Forced Labor or Child Labor

• Current Measures: ALBI le Géant has taken no measures to address income losses of the most vulnerable families resulting from measures to eliminate forced labor or child labor, given our retailer relationship with automotive manufacturers and our lack of visibility on their subcontractor selection.
  
  

7. Training Provided to Employees on Forced Labor or Child Labor

• Current Training: No training is provided to employees, given that all our purchases are made directly from automotive manufacturers or Canadian parts retailers. None of our employees can make a purchase decision that would allow or prevent forced labor and child labor in the vehicle supply chain. Given our retailer situation, we judge that providing training on the subject to our employees is not relevant at the moment.
  
  

8. Evaluation of the Effectiveness of Our Efforts to Avoid Forced Labor or Child Labor

• Current Evaluation: No measures have been taken to evaluate the effectiveness of preventing and reducing the risks of forced labor and child labor in the activities and supply chains of automotive manufacturers.
  
  

Conclusion

ALBI le Géant is committed to respecting human rights, including the prohibition of forced labor and child labor, in all its activities and supply chains. We will make reasonable efforts in line with the requirements of Law S-211 with our manufacturers. For the moment, we are reassured to know that all our manufacturers are present in Canada and must comply with Law S-211. We are confident that they will demonstrate that they are implementing various verification processes and taking adequate control measures to ensure there is no forced labor or child labor in their supply chains.