Joint Compliance Report to Law S-211 for Automobiles Delec Inc. (ALBI le Géant) and its Subsidiaries

Subsidiaries:

• ALBI LE GÉANT INC. (Mazda Mascouche)
• 9216-8038 QUÉBEC INC. (Hyundai Mascouche)
• 9317-3771 QUÉBEC INC. (Chevrolet GM Laval)

These subsidiaries hold assets valued at least $20 million and generated revenues of at least $40 million for the 12-month financial period ending December 31, 2023.

Declaration Year: December 31, 2023

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

1. Measures Taken to Prevent and Mitigate Risks Related to Forced Labor and Child Labor

• 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 been unable to assess the risk with our various international manufacturers to determine if they have resorted to forced labor or child labor in their supply chains.
• ALBI le Géant has not implemented any preventive measures concerning potential risks of forced labor and child labor in the manufacturers' supply chains, given that we have no oversight, influence, visibility, impact, or other means of risk assessment due to the retailer/manufacturer business relationship.
• ALBI le Géant will evaluate the feasibility of obtaining information from the manufacturers of our dealerships, namely 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

• ALBI le Géant is a group of car dealerships operating in Mascouche, Repentigny, Laval, St-Eustache, Mont-Tremblant, and Saint-Agathe. ALBI le Géant has eleven dealerships in Quebec with over 600 employees, all located in the province of Quebec.
• 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 car brands sold to Canadian consumers by ALBI le Géant are international manufacturers' brands, 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, from auctions, competing dealerships, or our customers.
• The 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 retailed to Canadian consumers. Parts are also sourced directly from Canadian automobile manufacturers or other Canadian parts retailers.

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

• ALBI le Géant has not yet implemented policies or due diligence processes with manufacturers related to forced labor and child labor. However, ALBI le Géant will consider partnering with automobile manufacturers to ensure 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 at Risk of Forced Labor or Child Labor and Measures Taken to Assess and Manage This Risk

• We estimate that the risk areas for forced labor or child labor in supply chains in the automotive industry are likely among parts suppliers and component manufacturers that manufacturers use for assembling new vehicles. As a retailer, we do not know the complete origin of the parts nor the raw materials from which they were made. We know that mining is probably an industry with a high risk of forced labor or child labor in some regions of Africa or Asia. ALBI le Géant does not know the origin of metals for all the parts used in the supply chain by various manufacturers, nor the subcontractors or regions selected for raw material extraction. There is a risk at this level if manufacturers have not properly and diligently selected their subcontractors to avoid the risk of forced labor or child labor.
• Given our position as a vehicle and parts retailer, we have no visibility on the supply chain nor on 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

• ALBI le Géant has not taken any measures to remedy forced labor or child labor in manufacturers' activities and supply chains, given our retailer relationship with automotive manufacturers. Additionally, we have no visibility on their subcontractor selection as we are not the manufacturer of the imported goods.

6. Measures Taken to Address Losses of Income for the Most Vulnerable Families Caused by Any Measures to Eliminate Forced Labor or Child Labor

• ALBI le Géant has not taken any measures to address the loss of income for the most vulnerable families caused by any measures to eliminate forced labor or child labor due to its retailer relationship with automotive manufacturers and lack of visibility on their subcontractor selection.

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

• No training is provided to employees, as all our purchases are made directly from automotive manufacturers or Canadian parts retailers. None of our employees can make purchasing decisions that would permit or prevent forced labor and child labor in the vehicle supply chain. Given our retailer situation, we deem that implementing training on the subject for our employees is not relevant at the moment.

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

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

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 implement reasonable efforts in line with the requirements of Law S-211 with our manufacturers. For now, 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.