Supply Chains Report
- Introduction
This report is submitted on a consolidated basis by Setay Motors Inc. , Image Automobiles Inc. ,
Guelph Nissan Infiniti Inc. , JP Motors Sales Inc. , Setay Holdings Limited, Guelph City Auto Holdings
Inc., 2368068 Ontario Inc., Landlink Incorporated, Landlink Rymal Holdings Inc. , and Landlink
Holdings Corporation and describes the actions taken by the Company during the financial year
ending December 31, 2023 to access, 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 Company under the Act.
- Structure, Activities, and Supply Chains
The Company is an Automotive Dealer Group based in Hamilton, Ontario, with locations in
Burlington, Ontario, and Guelph, Ontario. The Company specializes in the retail sales of motor
vehicles, as well as fleet sales, and in-house leasing. Among other things, we offer retail sales of
parts, comprehensive vehicle servicing and repairs, as well as body shop repairs.
As a dealer group 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 Canada,
Honda Canada, Nissan Canada, Infiniti Canada, and Mazda Canada dealer locations, the majority of
the Company’s procurement spend is with these original equipment manufacturers.
General Motors Canada: https://www.gm.ca/en/home.html/,
Honda Canada: https://www.honda.ca/en/,
Nissan Canada: https://www.nissan.ca/,
Infiniti Canada: https://www.infiniti.ca/,
Mazda Canada: https://www.mazda.ca/.
We also purchase goods and services from other third-party suppliers such as cleaners, contractors,
etc. We ensure that due diligence is carried out by asking our suppliers to provide information on
their own policies regarding their sourcing of goods and services, as well as their employment
practices.
- Polices and Due Diligence Processes
The Company will take appropriate measures to ensure no Forced Labour or Child Labour occurs
within our organization including the company, suppliers, vendors, and contractors. The employer
will verify the age of the employee at the time of employment, training company workers,
communicating the policy with anyone who the company does business with, including, but not
limited to, suppliers, vendors, and contractors. Additionally, as far as practicable, the dealership will
ensure that forced/child labour has not been used in our supply chain and will ensure that where
possible vendors that can assure there is no forced/child labour will be the vendor of choice.
The Company will submit an annual report on or before May 31st of each year outlining the
prevention and reduction of risk that forced labour or child labour isn’t being used within our
organization or supply chain in relation to goods that are imported into Canada by the Company.
The company will assess our supply chain to make sure we are mitigating the risk of forced/child
labour in relation to our operations and supply chain. We will use vendors in our supply chain that
adhere to our policy and legislation. The company will utilize ESG supportive and ethically sourced
vendors where applicable in order to assure that regional workers have a fair opportunity for
income.
The Company expects that employees will assist in the fulfilment of responsibilities under this policy
manual and all applicable laws. The Company recognizes that both the employer and the employee
have obligations in maintaining a safe, compliant, and fair workplace. Employees are expected to
ensure an understanding of this policy and issues around forced/child labour. Any employee who
feels that there is a breach of this policy are asked to report to Human Resources,
hr@queenstonautogroup.com. All reports will be gathered in good faith and will be investigated by
the Company. If the Company, through the course of an investigation, discovers that modern slavery
has occurred, in any form, the business relationship with the offending organization will
immediately be terminated.
- 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 Canada, Honda Canada, Nissan Canada, Infiniti Canada, and
Mazda Canada, it relies on the assessment undertaken by these OEMs with regards to the extent of
this risk.
- Remediation Measures
The Company has not identified any instances of forced labour in its supply chain, and so no
remediation measures have been taken.
- Remediation of Loss of Income
The Company has not identified any instances where the measures it 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.
- Training
The Company provides training on Forced Labour and Child Labour in the Supply Chains. This
training course is mandatory for all employees on our HRIS system, DealerPilot HR.
- Assessing Effectiveness
The Company has not taken any action to assess its effectiveness in addressing risks of forced labour
and child labour in its activities and supply chains.
- Approval and Attestation
i) This report has been approved by the Chief Executive Officer of Setay Motors Inc. 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 listen above.
Full Name: Gordon Albini
Title: Chief Executive Officer
Signature:
Date: 31/05/24
I have the authority to bind Setay Motors Inc.
ii) This report has been approved by the Chief Executive Officer of Image Automobiles Inc. 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 listen above.
Full Name: Gordon Albini
Title: Chief Executive Officer
Signature:
Date: 31/05/24
iii) This report has been approved by the Chief Executive Officer of Guelph Nissan Infiniti Inc. 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 listen above.
Full Name: Gordon Albini
Title: Chief Executive Officer
Signature:
Date: 31/05/24
I have the authority to bind Guelph Nissan Infiniti Inc.
iv) This report has been approved by the Chief Executive JP Motors Sales Inc. 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 listen above.
Full Name: Gordon Albini
Title: Chief Executive Officer
Signature:
Date: 31/05/24
I have the authority to bind JP Motors Sales Inc.
v) This report has been approved by the Chief Executive Setay Holdings Limited 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 listen above.
Full Name: Gordon Albini
Title: Chief Executive Officer
Signature:
Date: 31/05/24
I have the authority to bind Setay Holdings Limited.
vi) This report has been approved by the Chief Executive Guelph City Auto Holdings Inc. 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 listen above.
Full Name: Gordon Albini
Title: Chief Executive Officer
Signature:
Date: 31/05/24
I have the authority to bind Guelph City Auto Holdings Inc.
vii) This report has been approved by the Chief Executive 2368068 Ontario Inc. 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 listen above.
Full Name: Gordon Albini
Title: Chief Executive Officer
Signature:
Date: 31/05/24
I have the authority to bind 2368068 Ontario Inc.
viii) This report has been approved by the Chief Executive Landlink Incorporated 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 listen above.
Full Name: Gordon Albini
Title: Chief Executive Officer
Signature:
Date: 31/05/24
I have the authority to bind Landlink Incorporated
ix) This report has been approved by the Chief Executive Landlink Rymal Holdings Inc. 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 listen above.
Full Name: Gordon Albini
Title: Chief Executive Officer
Signature:
Date: 31/05/24
I have the authority to bind Landlink Rymal Holdings Inc.
x) This report has been approved by the Chief Executive Landlink Holdings Corporation. 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 listen above.
Full Name: Gordon Albini
Title: Chief Executive Officer
Signature:
Date: 31/05/24
I have the authority to bind Landlink Holdings Corporation.
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