CTSC Disclosure

For purposes of this CTSC Disclosure, “GVS” means CTC Triangle (USA) LLC dba GVS, a wholly-owned subsidiary of Canadian Tire, and its affiliates and subsidiaries. “Canadian Tire” means Canadian Tire Corporation, Limited and its family of companies including Mark’s, FGL Sports Ltd., Helly Hansen, and PartSource.

Engagement in verification of product supply chains to evaluate and address risks of human traffic and slavery.

Canadian Tire conducts risk assessments to identify potential risks in Canadian Tire’s direct supply chain through a number of different perspectives that includes Country Risk, Vendor Risk, Factory Risk and Product Risk. Risks of human trafficking and slavery are included in this assessment. This internal assessment engages many different internal stakeholders, on site visits by Canadian Tire employees during vendor selection and production product quality review and verification audits are completed by third party global service providers for initial Business Social Compliance Initiative “BSCI” audits and reaudits for any corrective action plans.

Compliance with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.

All suppliers agree to adhere to the SCBC, which includes language regarding forced and slave labour and compliance to all labour and human rights local laws. All suppliers are responsible for ensuring that their materials suppliers also meet the requirements outlined in the SCBC and those areas audited through the BSCI factory audits.

Maintenance on internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.

All employees (including contractors) must agree to the Employee Code of Business conduct and Human Resources is responsible for ensuring that all employees are aware and adhering to the Code of Conduct and addressing any incidents of non-compliance.

The SCBC policy is a Canadian Tire Board Policy and is owned by the Canadian Tire CEO. Responsibility for compliance is delegated to the Senior Merchandise Leadership Team and oversight is managed by Risk and Regulatory Affairs.

Training on human trafficking and slavery for company employees and management who have direct responsibility for supply chain management.

All Canadian Tire employees responsible for owned brands suppliers are trained to ensure they understand how to identify human trafficking and slavery in direct supply chains. Sourcing and Product Quality Assurance teams who frequent factories have received in depth training to understand BSCI audits and what to look for when in factories. Additionally, escalation processes are in place if incidents are identified by Canadian Tire employees.