Modern Slavery Report

2023 Forced Labour and Child Labour                           

REPORT

 

1. Introduction

This report is made on behalf of the Surgenor Automotive Group (“Company”), which includes Surgenor
Chevrolet Buick GMC Cadillac Ltd. (operating as Surgenor Ottawa), 2321528 Ontario Ltd. (operating
as Surgenor Hyundai), Surgenor Barrhaven Chevrolet Buick GMC Ltd. (operating as Surgenor
Barrhaven), Surgenor Gatineau Chevrolet Cadillac Ltee. (operating as Surgenor Gatineau), 1514831
Ontario Ltd. (operating as Pathway Hyundai) Surgenor National Leasing Limited and 1561660 Ontario
Ltd. (operating as Surgenor Truck Centre Ottawa and Kingston) and describes the actions taken by
the Company during the financial year ending December 31, 2023, to assess, prevent and reduce the
risk that forced labour or child labour is used at any step in its operations and supply chains
pursuant to the requirements of section 11 of the Fighting Against Forced Labour and Child Labour
in Supply Chains Act (“Act”). This Report constitutes the first report prepared by the Surgenor
Automotive Group under the Act.

The Surgenor Automotive Group is committed to doing business ethically and takes a zero- tolerance
approach to all forms of modern slavery in our organization and seeks to minimize and eliminate the
risk of modern slavery in our supply chain. The Surgenor Automotive Group does not and has never
employed children.

 

2. Structure, Activities and Supply Chains

a. Structure
The Surgenor Automotive Group is an incorporated multi-location automotive dealership group
operating exclusively in Canada.

As of December 31, 2023, the Company includes 6 subsidiary entities operating vehicle dealerships
based in Ottawa, Ontario, Kingston Ontario, and Gatineau Quebec. More specifically, the Company
operates 6 franchised dealerships, comprised of 8 brands. The Company currently sells Chevrolet,
Buick, GMC, Cadillac, Hyundai, Volvo, Mack and Isuzu branded vehicles. In addition, the Company
operates an in-house leasing company.

The Surgenor Automotive Group has approximately 400 full-time employees located exclusively in
Canada.

b. Activities

The Surgenor Automotive Group’s core operations consist of the ownership and operation of
automotive retail dealerships in Eastern Ontario and Western Quebec.
The Surgenor Automotive group specializes in the retail sale of motor vehicles and parts as well as
comprehensive vehicle servicing and repairs, including collision repairs.

c. Supply Chains

As a dealer of new and used vehicles and their parts, our supply chain is primarily based on the
supply chain of automotive manufacturers. Specifically, as authorized General Motors, Hyundai,
Volvo, Mack and Isuzu dealers, the majority of the Company’s procurement spend is with General
Motors of Canada, Hyundai Auto Canada Corp., Volvo Group Canada Inc., Mack Trucks Canada and Isuzu
Commercial Truck of Canada Inc..

General Motors’ report pertaining to Bill S-211 or the Modern Slavery Act can be found by following
this link: https://www.gm.ca/en/home/supply-chain-responsibility.html.

Mack Trucks Canada and Volvo Group Canada Inc.’s can be found by following this link:
https://www.volvotrucks.ca/en-ca/media/vtna/files/2024-05-15-vgci-report.pdf.

Hyundai Auto Canada Corp. and Isuzu Commercial Truck of Canada Inc.’s reports will be shared as
they become available.

3. Assessment of Forced Labour and Child Labour Risks

The Company has not independently engaged in its own risk assessment with regards to forced labour
or child labour in its supply chain. As the majority of the Company’s supply chain is based on the
supply chain of General Motors, Hyundai, Volvo, Mack and Isuzu, it relies on the assessment
undertaken by General Motors, Hyundai, Volvo, Mack and Isuzu dealers with regards to the extent of
this risk. The manufacturer’s risk assessments can be found within the reports linked above.

4. Remediation Measures

The Surgenor Automotive Group has not identified any instances of forced labour or child labour in
its supply chain, and as such, no remediation measures have been taken.

5. Remediation of Loss of Income

The Surgenor Automotive Group has not identified any instances where the measures it has
implemented to eliminate forced labour or child labour from its supply chain has led to the loss of
income, and so no remediation measures have been taken to address this issue.

 

6. Training, Assessing Effectiveness and Next Steps

The Surgenor Automotive Group prides itself on providing on-going training for all staff to align
with our group’s motto of gaining “Customers for Life”. This training is routed in ethical
practices and procedures that ensure that we are conducting business the right way.

While there is no formal training in place today, during the next reporting period we will develop
general modern slavery awareness training for those involved in procurement to continue to raise
awareness and understanding of modern slavery and the risks across our operations and supply chain.

The Surgenor Automotive Group has not yet taken any action to assess its effectiveness in
addressing the risks of forced labour and child labour in its activities and supply chains but will
do so during this upcoming reporting period and moving forward.

We will also update our practices and policies as they pertain to Modern Slavery within our
Employee Handbook so that it can be accessed by our staff at any time.

7. Approval and Attestation

This report has been approved by the Board of Directors of the Surgenor Automotive Group in
accordance with section 11(4)(b)(i) of the Act.

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.
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 year listed above.

Full name: Matt Leslie

Title: CFO

Date: May 31, 2024

I have the authority to bind the Surgenor Automotive Group.