Forced Labour and Child Labour
May 2024
Supply Chains Act - Report – WOLFE AUTOMOTIVE GROUP
1. Introduction
This report is made on behalf of the Wolfe Automotive Group (“WAG”). WAG is comprised of the legal entity of 1145041 Alberta Ltd and all its subsidiaries, including: GSL Chevrolet Cadillac Ltd., Edmonton Motors Limited, Western GMC Buick Ltd, Westgate Chevrolet (2018) Ltd, and Wolfe Chevrolet GMC Buick Canmore Ltd and the joint partnership subsidiary Alberta LeaseCo.
As 1145041 Alberta Ltd owns majority stakes in all of the noted entities, a consolidated report has been prepared, and on a consolidated basis, all three conditions ($20m in assets, $40m in revenue, 250 employees) are met for the group.
WAG’s efforts to ensure we prevent and reduce the risk of forced labour and child labour were in place well before the Reporting Period of January 1, 2023 through December 31,2023, but continued through the Reporting Period and thereafter.
WAG is committed to ethical business practices and does not support, condone or accept any form of modern slavery in our organization or our business partners.
2. Structure, Activities and Supply Chains
The Company is a corporation based in Calgary, Alberta with subsidiaries that are comprised of automotive dealerships in Calgary, Edmonton (x3) and Canmore.
All five dealerships are comprised of new and used sales, service, and parts departments. Westgate also includes a Bodyshop facility. As of December 31, 2023, WAG had approximately 400 employees across it’s dealership operations.
As a dealer of new and used vehicles and their parts, our supply chain is primarily based on the supply chain of our automotive manufacturer. Specifically, as an authorized General Motors Canada (“GM”) dealer, the majority of the Company’s procurement spend is with GM. GM issued their report on Modern Slavery May 23, 2024 and it can be found on their website.
From an analysis of our 2023 financial information, 76% of our Cost of Sales are purchased direct from GM. We also purchase goods and services from other third-party suppliers. From an analysis of our 2023 financial information, 22% of our cost of sales is from used vehicles. These items are purchased second hand from various suppliers (mostly from individuals). However, the underlying source of these items are from OEM’s, and as a GM dealer, the majority of our used vehicles are GM brand.
The aggregate of our purchases, being 76% direct from GM and 22% indirect from GM, mean that ~98% of our goods and services are from GM.
3. Policies and Due Diligence Processes
As an authorized GM dealer, our policy and due diligence process is to undertake a detailed review of the Modern Slavery Report produced by GM. We have and will continue to analyze their report to ensure appropriate steps are being taken to minimize and eliminate the risk of modern slavery in our supply chain.
A secondary policy we have in place is to assess new major vendors when onboarding them. This policy ensures a mirror process of the one we have in place for GM takes place, with an assessment and review of the ESG actions undertaken by prospective major vendors.
Overarching our specific policies is our strong corporate governance, with the Board and Executive Leadership of our Company being responsible for the stewardship of the group, and maintaining a culture of respect, integrity, and good practices with respect to supply chain management. The Board and Executive Leadership team assesses the risks of forced labour or child labour in our activities and supply chains, reviewed business conduct across the group and via regular review of our policies and practices, and engages with certain supply chain partners on the issue of addressing forced labour or child labour.
4. 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 most of the Company’s supply chain is based on the supply chain of GM, we rely on the assessment undertaken by GM with regards to the extent of this risk.
We have adopted a zero-tolerance stance in relation to Forced and Child Labour. This position has been in place for many years, and is re-affirmed during executive leadership workshops, to ensure all WAG companies leadership have awareness and ownership over ensuring we work collectively towards minimizing and eliminating the risk of modern slavery in our supply chain.
All employees are educated on our corporate policies upon joining WAG, and this includes “Employee Conduct”. This includes “…WAG expects employees to follow rules of conduct that will protect the interests and safety of all team members and the organization.” It also states “Employees must honor and comply with all laws …”.
With specific reference to GM’s 2021 Corporate Human Rights Benchmark (CHRB) Disclosure1, we note a continued effort over the past few years to proactively assess the risk of Child Labour in the supply chain of our Tier 1 supplier, GM.
We also considered the GM Supplier Code of Conduct2, that explicitly prohibits the use of Child Labour.
1 https://investor.gm.com/static-files/a0e2cb9d-5d47-448c-b9a3-2bc396205af6
2 https://investor.gm.com/static-files/b7d3c605-a597-486c-86e2-dbbeb6a25a42
5. Remediation Measures
The Company has not identified any instances of forced labour or child labour in its supply chain, and so no remediation measures have been taken.
6. Remediation of Loss of Income
The Company 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.
7. Training
The Company provides mandatory on-boarding training on the company’s code of conduct and expectations. This includes an acknowledgement and consent of all new employees to affair their understanding of the policies and procedures outlined within our employee handbook.
8. 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.
9. Approval and Attestation
This report has been approved by the Board of Directors of WAG in accordance with section “11(4)(b)(ii)” 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 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: Ashley Wolfe
Title: President and Director
Date: May 31, 2024
Signature: /signed copy filed in corporate minute book/
I have the authority to bind the Wolfe Automotive Group (1145041 Alberta Ltd).
Supply Chains Act - Report – WOLFE AUTOMOTIVE GROUP
1. Introduction
This report is made on behalf of the Wolfe Automotive Group (“WAG”). WAG is comprised of the legal entity of 1145041 Alberta Ltd and all its subsidiaries, including: GSL Chevrolet Cadillac Ltd., Edmonton Motors Limited, Western GMC Buick Ltd, Westgate Chevrolet (2018) Ltd, and Wolfe Chevrolet GMC Buick Canmore Ltd and the joint partnership subsidiary Alberta LeaseCo.
As 1145041 Alberta Ltd owns majority stakes in all of the noted entities, a consolidated report has been prepared, and on a consolidated basis, all three conditions ($20m in assets, $40m in revenue, 250 employees) are met for the group.
WAG’s efforts to ensure we prevent and reduce the risk of forced labour and child labour were in place well before the Reporting Period of January 1, 2023 through December 31,2023, but continued through the Reporting Period and thereafter.
WAG is committed to ethical business practices and does not support, condone or accept any form of modern slavery in our organization or our business partners.
2. Structure, Activities and Supply Chains
The Company is a corporation based in Calgary, Alberta with subsidiaries that are comprised of automotive dealerships in Calgary, Edmonton (x3) and Canmore.
All five dealerships are comprised of new and used sales, service, and parts departments. Westgate also includes a Bodyshop facility. As of December 31, 2023, WAG had approximately 400 employees across it’s dealership operations.
As a dealer of new and used vehicles and their parts, our supply chain is primarily based on the supply chain of our automotive manufacturer. Specifically, as an authorized General Motors Canada (“GM”) dealer, the majority of the Company’s procurement spend is with GM. GM issued their report on Modern Slavery May 23, 2024 and it can be found on their website.
From an analysis of our 2023 financial information, 76% of our Cost of Sales are purchased direct from GM. We also purchase goods and services from other third-party suppliers. From an analysis of our 2023 financial information, 22% of our cost of sales is from used vehicles. These items are purchased second hand from various suppliers (mostly from individuals). However, the underlying source of these items are from OEM’s, and as a GM dealer, the majority of our used vehicles are GM brand.
The aggregate of our purchases, being 76% direct from GM and 22% indirect from GM, mean that ~98% of our goods and services are from GM.
3. Policies and Due Diligence Processes
As an authorized GM dealer, our policy and due diligence process is to undertake a detailed review of the Modern Slavery Report produced by GM. We have and will continue to analyze their report to ensure appropriate steps are being taken to minimize and eliminate the risk of modern slavery in our supply chain.
A secondary policy we have in place is to assess new major vendors when onboarding them. This policy ensures a mirror process of the one we have in place for GM takes place, with an assessment and review of the ESG actions undertaken by prospective major vendors.
Overarching our specific policies is our strong corporate governance, with the Board and Executive Leadership of our Company being responsible for the stewardship of the group, and maintaining a culture of respect, integrity, and good practices with respect to supply chain management. The Board and Executive Leadership team assesses the risks of forced labour or child labour in our activities and supply chains, reviewed business conduct across the group and via regular review of our policies and practices, and engages with certain supply chain partners on the issue of addressing forced labour or child labour.
4. 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 most of the Company’s supply chain is based on the supply chain of GM, we rely on the assessment undertaken by GM with regards to the extent of this risk.
We have adopted a zero-tolerance stance in relation to Forced and Child Labour. This position has been in place for many years, and is re-affirmed during executive leadership workshops, to ensure all WAG companies leadership have awareness and ownership over ensuring we work collectively towards minimizing and eliminating the risk of modern slavery in our supply chain.
All employees are educated on our corporate policies upon joining WAG, and this includes “Employee Conduct”. This includes “…WAG expects employees to follow rules of conduct that will protect the interests and safety of all team members and the organization.” It also states “Employees must honor and comply with all laws …”.
With specific reference to GM’s 2021 Corporate Human Rights Benchmark (CHRB) Disclosure1, we note a continued effort over the past few years to proactively assess the risk of Child Labour in the supply chain of our Tier 1 supplier, GM.
We also considered the GM Supplier Code of Conduct2, that explicitly prohibits the use of Child Labour.
1 https://investor.gm.com/static-files/a0e2cb9d-5d47-448c-b9a3-2bc396205af6
2 https://investor.gm.com/static-files/b7d3c605-a597-486c-86e2-dbbeb6a25a42
5. Remediation Measures
The Company has not identified any instances of forced labour or child labour in its supply chain, and so no remediation measures have been taken.
6. Remediation of Loss of Income
The Company 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.
7. Training
The Company provides mandatory on-boarding training on the company’s code of conduct and expectations. This includes an acknowledgement and consent of all new employees to affair their understanding of the policies and procedures outlined within our employee handbook.
8. 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.
9. Approval and Attestation
This report has been approved by the Board of Directors of WAG in accordance with section “11(4)(b)(ii)” 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 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: Ashley Wolfe
Title: President and Director
Date: May 31, 2024
Signature: /signed copy filed in corporate minute book/
I have the authority to bind the Wolfe Automotive Group (1145041 Alberta Ltd).
