May 2024
Supply Chains Act - Report
1. Introduction
This report is made on behalf of Larry Hudson Chevrolet Buick GMC Inc. and HLK Wallace Investments Ltd. (the “Company”) 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 Company under the Act.
2. Structure, Activities and Supply Chains
The Company consists of two corporations, owned by the same shareholders and are based in Listowel, Ontario.
The Company specializes in the retail sale of motor vehicles and parts as well as comprehensive vehicle servicing and repairs. Larry Hudson Chevrolet Buick GMC Inc. is located at 1000 Wallace Ave N, in Listowel, Ontario. HLK Wallace Investments Ltd. operates under the trade name of Hudson’s Listowel KIA, and is located at 890 Wallace Ave. N, in Listowel, Ontario. Both stores are franchised new car dealers who also sell used vehicles and provides service and required parts for vehicles.
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 an authorized General Motors of Canada Company dealer and KIA Canada dealer, the majority of the Company’s procurement spend is with General Motors of Canada Company and KIA Canada. Please see the following links to our Original Equipment Manufacturers (OEM’s) website:
General Motors of Canada Company: https://www.gm.ca/en/home.html
KIA Canada: https://www.kia.ca/en
3. Policies and Due Diligence Processes
The Company will take all the appropriate measures so that no Forced Labour or Child Labour occurs within our organization including the Company, suppliers and vendors.
This includes:
1. Embedding responsible business conduct into policies and management systems;
2. Identifying and assessing adverse impacts in operations, supply chairs and business relationships;
3. Ceasing, preventing and mitigating adverse impacts;
4. Tracking implementation and results;
5. Communicating how impacts are addressed; and
6. Providing for or cooperating in remediation when appropriate.
The Company will submit an annual report on or before May 31st of each year outlining the steps taken for the prevention and reduction of risk ensuring 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.
We will review and refer to the OEM’s website to ensure compliance regarding Forced Labour and Child Labour in Supply Chains.
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 the majority of the Company’s supply chain is based on the supply chain of General Motors of Canada Company and KIA Canada, it relies on the assessment undertaken by General Motors of Canada Company and KIA Canada with regards to the extent of this risk.
As a certified dealer, we operate under contracts for sales and service with the Canadian subsidiaries of the following OEM’s General Motors of Canada Company and KIA Canada. For all vehicles, parts, equipment and service covered by those agreements, we refer you to their submission.
Here are the links to our OEM’s Modern Slavery Reports:
General Motors of Canada Company: https://www.gm.ca/en/home/supply-chain-responsibility.html
KIA Canada: COMING May 31st, 2024
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 has access to general training through DealerPilot (our Health and Safety training platform) on forced labour and child labour. This can be provided to any departments in the future.
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 Katie Imrie of Larry Hudson Chevrolet Buick GMC Inc. and HLK Wallace Investments Ltd. 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: Katie Imrie
Title: HR Manager/ Shareholder
Date: May 30th, 2024
Signed: Katie Imrie (Signature present on official document)
I have the authority to bind Larry Hudson Chevrolet Buick GMC Inc. and HLK Wallace Investments Ltd.