SUPPLY CHAIN ACT

SUPPLY CHAIN ACT


ANNUAL REPORT CONCERNING THE RISK OR USE OF FORCED LABOUR AND CHILD LABOUR IN SUPPLY CHAINS

POLICY STATEMENT:

This annual report (this “Report”) on the risk or use of any forced labour or child labour in the business and supply chain of Anmar Mechanical and Electrical Contractors Ltd. (“Anmar”) as well as any actions taken by Anmar to monitor, assess, mitigate, and remediate the same, as appropriate, is dated as of May 29, 2024 and is being delivered in respect of the Companies’ financial year ended September 30, 2023 (the “Reporting Period”). This Report has been prepared in accordance and compliance with the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “Act”).

A. STRUCTURE, ACTIVITIES, AND SUPPLY CHAINS

Anmar was incorporated on May 29, 1989 under the laws of Ontario, and is headquartered in 199 Mumford Road, Lively, Ontario, P3Y 1L2. Anmar is the parent entity of various subsidiaries, including: Anmar Energy Ltd., Castec Inc., Anmar Mechanical and Electrical Contractors LLC. and Castec Scaffolding Inc.

Anmar as established in 1989 as an industrial fabrication and installation company, and continues to grow and expand its capabilities and expertise, servicing the needs of the smelting, refining, and steel mill sectors. Operating from its 130,000 sq. ft. facility, with its subsidiary companies, Anmar services the metals and heavy industrial industries on a worldwide basis. Specifically, Anmar provides such services as blast furnace repairs, industrial furnace repairs, smelting furnace repairs, emergency smelter repairs, and industrial stove repairs. Anmar’s fabrication plant is capable of manufacturing a variety of customized components for all types of heavy industrial situations. From small scale parts to immense structures, Anmar has the ability to design and build to suit the needs. Products include heat exchangers, hoppers and chutes, vent stacks, mass flow bins and bag houses. The majority of supplies required during the manufacturing process are obtained within North America.

B. STEPS TAKEN TO PREVENT AND REDUCE RISKS OF FORCED LABOUR AND CHILD LABOUR

During the Reporting Period, Anmar developed and implemented an action plan for addressing forced labour and/or child labor. This action plan was formalized into a policy statement subsequent to the reporting period.

C. POLICIES AND DUE DILIGENCE PROCESSES

During the Reporting Year, Anmar did not implement any policies and due diligence processes in respect of the use of forced labour and/or child labour. However, on January 1, 2024, Anmar implemented an Anti-Slavery Policy (the “Policy”), which outlines Anmar’s procedures when it comes to forced labour, human trafficking, servitude, and compulsory labour for the purposes of personal or commercial gain, and affirms Anmar’s commitment to acting with integrity and adhering to strong ethical practices in all of its business and employment agreements. The Policy applies to Anmar, its clients, and anyone working on behalf of Anmar including service providers, suppliers, volunteers, contractors, consultants, and third-party representatives.

The Policy states that Anmar will not contract with any organization and/or client or person who is engaged in the use of forced or trafficked labour, including slavery or servitude. The Policy also states that Anmar will assess any risks associated with human trafficking and forced labour which could be associated with its supply chain (this could include a study of the geographic area or include the products that are being received from purchasers, up to and including the nature of the business transaction itself). The Policy further notes that Anmar will ensure that due diligence is carried out by asking its suppliers to provide information on their own policies regarding their sourcing of goods and services, as well as their employment practices.

The Policy invites any employees who may have any concerns or suspicions regarding the use of forced labour by Anmar and/or its service providers, suppliers, volunteers, contractors, consultants, and third-party representatives, to report such concerns to Anmar’s management team or human resources department. The Policy affirms that all reports will be gathered in good faith and investigated by Anmar. Should such investigation lead to the conclusion that force labour has occurred, in any form, the Policy states that Anmar will terminate its relationship with the offending organization.

D. POLICIES AND DUE DILIGENCE PROCESSES

During the Reporting Period, Anmar did not undertake the process of identifying which parts of its activities and supply chain carry a risk of forced labour or child labour being used. However, the Policy affirms Anmar’s commitment to identify and assess any risks associated with human trafficking and forced labour which could be associated with its supply chain.

E. REMEDIATION OF FORCED LABOUR AND CHILD LABOUR IN ACTIVITIES AND/OR SUPPLY CHAINS

During the Reporting Period, Anmar did not take any measures to remediate the use of forced labour or child labour in its operations and supply chain (“Remediation Measures”).

F. REMEDIATION OF LOSS OF INCOME IN MOST VULNERABLE FAMILIES

As Anmar did not take any measures to remediate the use of forced labour or child labour in its own operations and supply chain, Anmar consequently did not take any measures to remediate any loss of income to the most vulnerable families resulting from any Remediation Measures.

G. TRAINING ON FORCED LABOUR AND CHILD LABOUR

During the Reporting Period, Anmar did not provide any training to employees regarding forced labour and child labour.

H. ASSESSING EFFECTIVENESS OF FORCED LABOUR AND CHILD LABOUR PREVENTION MECHANISMS

During the Reporting Period, Anmar did not implement any policies or put in place any procedures to assess its effectiveness in ensuring that forced labour and child labour are not being used in its operations or supply chains.

ATTESTATION

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 Anmar Mechanical and Electrical Contractors Ltd. 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.

ANMAR MECHANICAL AND ELECTRICAL CONTRACTORS LTD.

Giovanni Grossi

Director,

May 30, 2024

I have authority to bind Anmar Mechanical and Electrical Contractors Ltd.

Approved by the Board of Directors of Anmar Mechanical and Electrical Contractors Ltd. this 30 day of May, 2024.


ANNUAL REPORT CONCERNING THE RISK OR USE OF FORCED LABOUR AND CHILD LABOUR IN SUPPLY CHAINS

POLICY STATEMENT:

This annual report (this “Report”) on the risk or use of any forced labour or child labour in the business and supply chain of Anmar Mechanical and Electrical Contractors Ltd. (“Anmar”) as well as any actions taken by Anmar to monitor, assess, mitigate, and remediate the same, as appropriate, is dated as of May 29, 2024 and is being delivered in respect of the Companies’ financial year ended September 30, 2023 (the “Reporting Period”). This Report has been prepared in accordance and compliance with the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “Act”).

A. STRUCTURE, ACTIVITIES, AND SUPPLY CHAINS

Anmar was incorporated on May 29, 1989 under the laws of Ontario, and is headquartered in 199 Mumford Road, Lively, Ontario, P3Y 1L2. Anmar is the parent entity of various subsidiaries, including: Anmar Energy Ltd., Castec Inc., Anmar Mechanical and Electrical Contractors LLC. and Castec Scaffolding Inc.

Anmar as established in 1989 as an industrial fabrication and installation company, and continues to grow and expand its capabilities and expertise, servicing the needs of the smelting, refining, and steel mill sectors. Operating from its 130,000 sq. ft. facility, with its subsidiary companies, Anmar services the metals and heavy industrial industries on a worldwide basis. Specifically, Anmar provides such services as blast furnace repairs, industrial furnace repairs, smelting furnace repairs, emergency smelter repairs, and industrial stove repairs. Anmar’s fabrication plant is capable of manufacturing a variety of customized components for all types of heavy industrial situations. From small scale parts to immense structures, Anmar has the ability to design and build to suit the needs. Products include heat exchangers, hoppers and chutes, vent stacks, mass flow bins and bag houses. The majority of supplies required during the manufacturing process are obtained within North America.

B. STEPS TAKEN TO PREVENT AND REDUCE RISKS OF FORCED LABOUR AND CHILD LABOUR

During the Reporting Period, Anmar developed and implemented an action plan for addressing forced labour and/or child labor. This action plan was formalized into a policy statement subsequent to the reporting period.

C. POLICIES AND DUE DILIGENCE PROCESSES

During the Reporting Year, Anmar did not implement any policies and due diligence processes in respect of the use of forced labour and/or child labour. However, on January 1, 2024, Anmar implemented an Anti-Slavery Policy (the “Policy”), which outlines Anmar’s procedures when it comes to forced labour, human trafficking, servitude, and compulsory labour for the purposes of personal or commercial gain, and affirms Anmar’s commitment to acting with integrity and adhering to strong ethical practices in all of its business and employment agreements. The Policy applies to Anmar, its clients, and anyone working on behalf of Anmar including service providers, suppliers, volunteers, contractors, consultants, and third-party representatives.

The Policy states that Anmar will not contract with any organization and/or client or person who is engaged in the use of forced or trafficked labour, including slavery or servitude. The Policy also states that Anmar will assess any risks associated with human trafficking and forced labour which could be associated with its supply chain (this could include a study of the geographic area or include the products that are being received from purchasers, up to and including the nature of the business transaction itself). The Policy further notes that Anmar will ensure that due diligence is carried out by asking its suppliers to provide information on their own policies regarding their sourcing of goods and services, as well as their employment practices.

The Policy invites any employees who may have any concerns or suspicions regarding the use of forced labour by Anmar and/or its service providers, suppliers, volunteers, contractors, consultants, and third-party representatives, to report such concerns to Anmar’s management team or human resources department. The Policy affirms that all reports will be gathered in good faith and investigated by Anmar. Should such investigation lead to the conclusion that force labour has occurred, in any form, the Policy states that Anmar will terminate its relationship with the offending organization.

D. POLICIES AND DUE DILIGENCE PROCESSES

During the Reporting Period, Anmar did not undertake the process of identifying which parts of its activities and supply chain carry a risk of forced labour or child labour being used. However, the Policy affirms Anmar’s commitment to identify and assess any risks associated with human trafficking and forced labour which could be associated with its supply chain.

E. REMEDIATION OF FORCED LABOUR AND CHILD LABOUR IN ACTIVITIES AND/OR SUPPLY CHAINS

During the Reporting Period, Anmar did not take any measures to remediate the use of forced labour or child labour in its operations and supply chain (“Remediation Measures”).

F. REMEDIATION OF LOSS OF INCOME IN MOST VULNERABLE FAMILIES

As Anmar did not take any measures to remediate the use of forced labour or child labour in its own operations and supply chain, Anmar consequently did not take any measures to remediate any loss of income to the most vulnerable families resulting from any Remediation Measures.

G. TRAINING ON FORCED LABOUR AND CHILD LABOUR

During the Reporting Period, Anmar did not provide any training to employees regarding forced labour and child labour.

H. ASSESSING EFFECTIVENESS OF FORCED LABOUR AND CHILD LABOUR PREVENTION MECHANISMS

During the Reporting Period, Anmar did not implement any policies or put in place any procedures to assess its effectiveness in ensuring that forced labour and child labour are not being used in its operations or supply chains.

ATTESTATION

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 Anmar Mechanical and Electrical Contractors Ltd. 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.

ANMAR MECHANICAL AND ELECTRICAL CONTRACTORS LTD.

Giovanni Grossi

Director,

May 30, 2024

I have authority to bind Anmar Mechanical and Electrical Contractors Ltd.

Approved by the Board of Directors of Anmar Mechanical and Electrical Contractors Ltd. this 30 day of May, 2024.