Canada Bill S-211

This statement is made pursuant to Bill S-211, An Act to enact the Fighting Against Forced Labour and
Child Labour in Supply Chains Act and to amend the Customs Tariff (“Act”). This statement outlines the
approach and initiatives by Redhead Equipment (collectively, “Redhead”) and to identify and address
the risks of forced labour and child labour in its business operations and supply chains during the
financial year commencing January 1, 2023 and ending December 31, 2023. This is the first version of
this report submitted in line with the requirements of the Act with no reporting requirements on similar
regulation in other jurisdictions.

This statement reinforces Redhead’s effort and committment to combat child or forced labour, human
trafficking, and other forms of modern slavery. We do not tolerate slavery or human trafficking in our
organization or in our manufacturers.

Structure, Activities and Supply Chains

Our Structure
The business was established in 1948 as WF Fuller Machinery Limited. Gordon Redhead worked for the
Fuller Brothers and when they wanted to sell the business in 1968, he purchased it. The name was
changed to Redhead Equipment Ltd. Gary Redhead started working for the company in 1969 and
purchased the business from his father in 1980. The structure was changed to a partnership in 2009 and
remains that way today.

Redhead Equipment has 10 locations in Saskatchewan, Canada. We are a Heavy Equipment Dealer for
Manufacturers including Case IH Agriculture, Case Construction, New Holland Agriculture, New Holland
Construction, Volvo Construction, Mack Trucks, Tigercat Forestry and Bombardier Recreational
Products. We sell equipment and sell parts and service for that equipment. Virtually all of our sales
revenue is in Canada, although every year we sell a couple of pieces of equipment into the US.
In terms of the Act’s threshold requirements, Redhead meets the definition of a reporting entity.

Supply Chain and Activities
Redhead’s supply chain includes 3,942 vendors. 3,679 or 93.3% of them are from Canada, 256 or 6.49%
are from the US and the remaining 7 or 0.18% are from outside of Canada and the US. In all cases, all
vendors regardless of origin are expected to adhere to Canadian rules and regulations.
Purchases are made primarily by our Management group, from Redhead approved vendors. Adding a
new vendor to our system requires a review of the vendor and it must be approved by a Corporate
Manager. With our 76-year history and reputation, we are very careful with who we choose to do
business with and don’t want to tarnish the Redhead reputation due to a subpar vendor. We have
committed ourselves to developing long-term relationships with our manufacturers and vendors that
benefit our customers, employees, Redhead Equipment and the manufacturers and vendors.
Our supply chain provides a mix of goods and parts and services related to those goods.
We have zero tolerance for child and forced labour in any of our operations or supply chains. We require
manufacturers and vendors to abide by applicable employment standards, labour, non-discrimination
and human rights legislation.

Company Policies and Due Diligence Processes

As an organization, Redhead is committed to ensuring that there is no modern slavery or human trafficking situations in our supply chains or in any part of our business.

  • We work within current employment legislation and apply best practices when recruiting. This includesrequiring all employees have Social Insurance Numbers and Driver’s licenses, if they will operate acompany vehicle. This helps ensure that all employees hired, can work in Canada and meet theworking age requirements for our industry.
  • In the future, we may hire summer students, that are 14 or 15 years old, but it will be in full compliancewith Saskatchewan Employment Act, with both permission of their parent or guardian and with completion of the Young Workers Readiness Certificate Course. These hires would be current employee’s children that are looking for summer employment.
  • In addition to our hiring due diligence, we run criminal record background checks as a condition of employment.
  • We comply with all applicable employment laws, including laws regarding minimum wage, minimum age of employment, working hours, overtime, health and safety and human rights, of which are outlined in our Employee Handbook.
  • We are implementing an ESG email address available to employees, customers and suppliers to report any concerns on a confidential and anonymous basis with regards to Environmental, Social or Governance concerns. This email address will go to our Chief Operating Officer, Chief Financial Officer and Human Resources Manager for investigation and resolution.
  • As part of standard practice, we perform reference checks on any new supplier to identify legal, ethical, and financial concerns prior to purchasing.
  • The Management team monitors current suppliers for any instances (actual or alleged) of legal or ethical concerns that would prevent Redhead from adhering to this legislation.

Risks in Supply Chain
Redhead considers the risk of child or forced labour in its supply chains to be extremely low. 93.3% of
our vendors are Canadian, 6.49% are from the US and the remaining 0.18% are from outside Canada or
the US.

We reviewed World Visions’ report “Supply Chain Risk Report 2023, Canada’s Growing Child & Forced
Labour Problem”. There are specific sections of interest, the Top 10 Risky Goods by Import Value, 2021
(CAD), the Top 10 Fastest Growing Risky Imports Over $1 Million, 2021-2022 (CAD) and the Full List of
Risky Imports and we do not import any of the items on these lists.
In addition, the inherent risk of child labour or forced labour is very low in Canada compared to other

There is a potential risk with tier two, tier three or further down the line suppliers for the manufacturers
and vendors we deal with. As part of our audit, we reviewed the supply chain legislation our
manufacturers are required to comply with in other jurisdictions. Our major manufacturers have been
bound by existing supply chain legislation going back to 2015. Additionally, many of our manufacturers
or vendors are Canadian companies and will be required to comply with Bill S-211 in Canada.
In all cases, all vendors within the supply chain are expected to abide by all pertinent legislation
including but not limited to child and forced labour, human rights, and health and safety. A high
majority of our suppliers are well known and established within the industry and typically have had a
long tenure in dealing with our organization.

Force Labour and Child Labour Risk
Redhead has initiated the process of identifying risks related to child labour and forced labour within its
operations. Based on the high majority of our manufacturers or vendors being Canadian or from the US,
we don’t import the top items from World Visions’ report, the inherent risk of child labour or forced
labour being very low in Canada, our manufacturers or vendors being subject to supply chain legislation
in other territories or Canada and the long reputation history we have with our manufacturers and
vendors, the risk of child labour or forced labour is extremely low at Redhead.

The company believes that the risk of Modern Slavery occurring in its operations is extremely low. This
assessment is based on the nature of its workforce and the comprehensive policies and procedures that
govern the recruitment, working conditions, and ethical treatment of employees and strict compliance
with the Saskatchewan Employment Act. Notably, Redhead’s entire labour force is based in Canada,
where stringent labour laws and regulations provide additional safeguards against such practices.
To date, no specific instances of forced or child labour have been identified within the company.
Redhead remains committed to maintaining high ethical standards and ensuring that all employees are
treated fairly and with respect. The company continues to monitor and assess potential risks regularly to
uphold its commitment to ethical labour practices.

Remediation Measures and Remediation Loss of Income
Redhead has initiated a comprehensive process in which to identify the risks of child labour and forced
labour within its operations and supply chains. This initiative involves a thorough examination of all
aspects of its business, to ensure that no exploitative practices are present. As such, Redhead has not
identified any instances of forced labour or child labour within its activities or those of its supply chains
to date.

As a result, the company has had no cause to begin any remediation activities related to these issues.
Redhead’s current operations and supply chains appear to be free of forced or child labour, indicating its
existing policies and procedures are effectively preventing such practices. As an organization, Redhead
remains committed to ensure its operations and supply chain remain free of such risks of child and
forced labour.

Furthermore, Redhead has not identified any instances where measures taken to eliminate forced
labour or child labour have resulted in a loss of income for vulnerable individuals or families. This
indicates that the company’s actions in this regard have not adversely impacted the livelihoods of
individuals or families dependent on its operations. Consequently, there has been no need for Redhead
to undertake any income remediation measures.
As an organization Redhead, remains committed to maintaining vigilant oversight of its operations and
supply chains to ensure ongoing compliance with ethical labour standards. The company continues to
prioritize the well-being and fair treatment of all individuals involved within its business operations.

In 2023, Redhead did not provide training to its employees on forced labour or child labour. However, in
subsequent reporting years, the company will explore training in the area of child and forced labour
with a view to incorporate that with our existing annual training plan provided to our employees.

Effectiveness Assessment
To assess the effectiveness of our approach we rely on input from all relevant internal and external
stakeholders, including customers, employees, suppliers and members of our communities. We
investigate and track any reports made to our ESG Hotline, our supervisors, and senior management

We are committed to the ongoing enhancement of our procurement processes and the identification
and mitigation of modern slavery risks within our supply chain. We will continually monitor our
suppliers and perform audits on our manufacturers and vendors to identify any areas of risk. We will
raise internal awareness of modern slavery issues through ongoing training.

Approval & Attestation
Redhead Equipment remains committed to preventing forced labour and child labour from taking place
in our business and supply chains, and we will continue to review our policies, procedures, and practices
periodically to determine any potential enhancements to ensure continued compliance with Bill S-211.
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 period
ending December 31, 2023.

Craig Slobodian, Chief Operating Officer
Redhead Equipment
Dated, May 29,2024