Bill S.211 Compliance
Compliance with Canadian 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
 Modern Slavery Report for the Financial Year ended 2023
This report is made pursuant to Bill S-211, An Act to enact the Fighting Against Forced Labour and Child Labour in Supply Chains Act. Â This, our initial report outlines the approach and initiatives by the entity, Regina Motor Products (1970) Ltd. (we, us, our) to identify and address, prevent and reduce the risks of forced labour and child labour used at any step in our business operations and supply chains during the financial year commencing, January 1, 2023 and ending December 31, 2023.
Structure and Supply Chain   Â
Regina Motor Products (1970) Ltd. was established in 1952, and throughout a family’s legacy, is a corporation still owned and operated by Ledingham family today. Specializing in the retail sales of motor vehicles and parts, as well as extensive vehicle servicing and repair not limited to physical or mechanical.  Trading under the business name Regina Motor Products (1970) Ltd. employing on average 70 employees, a vehicle dealership located at Regina in the province of Saskatchewan. A corporation that strives for compliance beyond regulatory conformity to be proactive towards ongoing regulations and developing industry best practices. This is achieved through continuous monitoring and engagement with our franchisor and our suppliers.  Continued operations today as a certified dealer of new and used vehicles and their parts, our supply chain is primarily based on the supply chains of automotive manufacturers.  Specifically, under dealer contracts for sales and service with General Motors of Canada, for all vehicles, parts, equipment and service covered by those agreements, we refer you to their submission (link found at the end of this report).  Nonetheless, we recognize the interconnection we have and will continue to undertake diligent efforts to ensure that all our product suppliers are in line with the provisions outlined in the Act to do our part to eliminate Forced and Child labour from our supply chains. We also purchase goods and services from other third-party suppliers, including parts, office supplies, chemical supplies, sanitary and various consumable supplies. We are an entity that will not tolerate or condone suppliers that do not respect their workers human rights and will not be part of any human trafficking related activities, forced labour or child labour in any supply chains. All efforts should be made by suppliers to provide workers with safe and secure environment locations, without coercion, intimidation, threats or harassment directly or indirectly to pressure workers in anyway.  Our company takes pride each day in what we do to better our community, our employees and their families, to bring the best to everyone. Our commitment is to uphold our values, integrity and accountability. As a franchisee that adheres to the legislative requirements, we want to be part of the initiative to strengthen respect for human rights by Canadian Companies in their operations and supply chains abroad.
As a retailer we are at the end of the supply chain and entirely dependant on the franchisers and suppliers we operate with to turn over the products we sell and need to service our operations. We acknowledge the significance of sourcing products from suppliers that have ethical standards, treat their workers fairly, and prioritize labour and legislative standards. At this time, we are in the process to independently engage in risk assessments with regards to forced and child labour in our supply chain. The majority of the supply chain is based on the supply chain of General Motors of Canada and we are relying on the assessment undertaken by General Motors with regards to the extent of this risk. Recognizing the interconnections affect, we have taken serious efforts in being diligent to ensure our suppliers and their supply chains are abiding by the legalities of the Act. Through extensive inquiries, including using the Public Safety of Canada’s website and the searchable catalogue of supplier reports, we will be diligent in obtaining the processes and assurances, including policy, procedure, confirming with third party company practice on the legislative requirements, this will be at the forefront of purchase practices at Regina Motor Products (1970) Ltd.  and continue to be a performed measure. Increasing industry awareness and transparency to drive all supply chains to improve practices will be a force to free violation of human right, forced labour and child labour, to obligate supplier code of conduct. We will keep our management team apprised of the current and future regulations by holding regular meetings, posting information and memos of understanding. Our ongoing training includes awareness programs, campaigns and bulletins of legislation and changes to the Act, continued on a regular basis each fiscal year.  By holding suppliers accountable through confirmation that their products and purchase chains are conformed, keeps them diligent in their practices with their supply chains by adhering to the legislative requirements and compliance, which will strengthen business relations and pre-purchase procedures.
Risks in Supply Chain
It is our commitment to respect human rights and ensure that forced labour and child labour are not a part of any production of products within the supply chain or of our outsourced product chains.  To continually question legal compliance, confirming suppliers comply with all applicable laws and regulations within the country and countries they operate with or in will help to recognize and assess risk. Our franchise agreements limit how and when we can obtain specific documentation in which information on those supply chains is detailed, recognizing this we respect and rely on the role our franchiser has taken in their own manufacturing company policies and actions to prevent and reduce risk of forced labour and child labour risks. Our suppliers are as well recognizing the significance of sourcing products from suppliers with ethical standards in which we have confidence in their compliance. We will remain vigilant to emerging shifts or swings in our regular purchases that could possibly be an indicator of supply chain problems that leads to unethical processes. This would raise questions as to the accountability of the supply chain and its production beginning link, raising a flag to our purchase practices, this indication would cause cancelling product purchases and ceasing business relations with a questionable suppliers conduct. Remediation measures would then be looked at and acted upon, at this time we have not had any indication or identified any instances where we have needed to take actions against supply chains that has led to loss of income or matters of remediation needing to be addressed.
Assessing Effectiveness
At Regina Motor Products it is our top priority to maintain compliance and uphold ethical standards, in respecting human rights and ensuring legal conformity in our Canadian franchise operations, as well as being committed to ensure our supply chain is free from Forced Labour and Child Labour from beginning to end. We are moving forward with setting up more effective measures of regular review of policy and procedures related to the Act. By increasing employee awareness, partnering with external organizations and working with suppliers to address the risks, making everyone involved aware will be a priority in company planning to assess effectiveness on addressing risks of forced labour and child labour in our activities and supply chains to be proactive should a circumstance arise.  Discussions with authority figures of suppliers and manufacturers to ensure they are accountable for their confirmations on their own supply chain will be performed to ensure the effectiveness of their actions in the event a risk is recognized and acted upon.  To date no instances of forced labour or child labour have been identified to engage in any remediation measures nor has any income loss to employees or families been experienced in 2023.
Conclusion
Our operational framework is committed to adherence to Bill S-211, An Act to enact the Fighting Against Forced Labour and Child Labour in Supply Chains Act for the financial year ending 12/31/2023. As we continue to navigate the complexities of the franchise landscape, our pledge is to uphold the provisions and continue to grow with the changes and updates as they are presented.
Approval and Attestation
This report has been issued on behalf of Regina Motor Products (1970) Ltd. as presented and approved by the board of directors. 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. 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: Jason Ledingham
Title: Sole Director and President
Date: May 28, 2024
Franchisor: General Motors of Canada Company
https://www.gm.ca/en/home/supply-chain-responsibility.html
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