Modern slavery report 2025

1. Introduction

This report is issued by PRELCO Inc. (“Prelco” or the “Corporation”) for the fiscal year ended September 30, 2025. It outlines the measures adopted to prevent and reduce the risk of forced or child labour at all stages of the production of goods, both in Canada and abroad, as well as when the Company imports goods into Canada.

 

2. Measures taken to prevent and reduce the risks of forced labour and child labour

Respect for human rights is a core responsibility of our business and a core value that guides each of our operations. We pay close attention to the integrity of human rights in all aspects of our business and expect the same commitment from our business partners.

In general, we have implemented the following measures to prevent and reduce the risk of forced labour or child labour within our company and supply chains.

  • The Supplier Code of Conduct was established in March 2024.
  • In 2024, we conducted an initial assessment of the risks of forced labour and child labour in our supply chains to improve due diligence towards our suppliers.
  • We have submitted to our suppliers, our new due diligence process which contains the risks related to modern slavery, with the aim of verifying the process and improving it if necessary.
  • In 2025, we will integrate our Supplier Code of Conduct into the account application.

 

3. Structure, operations and supply chains

Prelco Inc., headquartered in Rivière-du-Loup in the Lower St. Lawrence, is a North American leader in the design and manufacture of glass solutions. Prelco operates in several strategic market segments; the building envelope, interior partitions, different types of glazing for the transportation market such as buses, trains, subways, tramways, commercial marine and recreational boats, as well as in the defence sector. The Prelco Group is proud to be able to offer the widest range of glass solutions in North America thanks to the development capacity of its technical team and the most diversified machine park.

  • Prelco Inc.’s products are produced in its 7 production sites:
  • Prelco inc., Rivière-du-Loup, QC (head office)
  • Vitrerie KRT, Rivière-du-Loup, QC
  • Prelco EDM, Saint-Jacques, NB
  • Prelco MTL, Montréal, QC
  • Prelco PBG, Plattsburgh, NY
  • Prelco PVE, Princeville, QC
  • Prelco BVE, Belleville, ON

Prelco’s supply chain consists of suppliers of products such as glass, adhesives, ceramic paints, metal or plastic components. The raw materials, components, articles and systems required to manufacture sealed units, laminated or monolithic glass or other glass solutions come from various suppliers around the world. The majority of these materials, components and systems come from suppliers with whom Prelco has long-term contracts. Prelco is currently working with about 100 suppliers with a direct link in the production chain in 8 countries and about 1300 suppliers of all kinds in a dozen countries, the list of our suppliers can be provided upon request.

 

4. Policies, governance and due diligence processes

Prelco is committed to integrating human rights considerations into its policies, governance framework and decision-making. In this sense, Prelco considers the management of environmental, social and governance (“ESG”) risks and opportunities to be an integral part of its success as a company. Prelco regularly monitors the sustainability risks that shape its operating environment and develops and implements strategies to improve its performance in the various areas of sustainability.

4.1 Declaration on Human Rights

With Prelco’s commitment to support human rights under the United Nations Global Compact, our Human Rights Statement reaffirms Prelco’s position to reject the use of child labour or forced labour. To support this endeavour, we expect all employees at all levels, as well as our business partners, to act in accordance with these same principles.

4.2 Code of Ethics

The Code applies to all members of the Prelco community, including the Board of Directors, management, and employees at all levels, in all countries, and in all legal entities of the Prelco community.

The Code addresses ethical conduct in our workplace, business practices and relationships with external parties. The principles set out in the Code suggest Prelco’s belief that honesty and integrity result in a positive work environment that builds trust for all parties. The Code describes the standards of behaviour expected of all individuals involved and applies to their daily activities and interactions with others. It also outlines the key responsibilities of Prelco leaders to demonstrate ethical conduct and create a work environment that reflects the code. Our Code requires us to uphold our core values, standards of behaviour, and commitment to the ten principles of the United Nations Global Compact in all our activities, everywhere.

4.3 Supplier Code of Conduct

Following Prelco’s vision for its suppliers, Prelco actively engages its supply chain by requiring its suppliers to adhere to its Code, which was developed with the ten principles of the United Nations Global Compact in mind. The Supplier Code, which was rolled out in April 2024, details what we expect from our suppliers in the areas of human rights, compliance with the law, health, safety and environment, anti-corruption, ethics and governance. The Supplier Code can be provided upon request. Our Supplier Code contains specific provisions preventing child labour and forced labour.

“.2 Respect for human rights: We refuse any collaboration with suppliers violating human rights such as forced labour or child labour. We stand for fair and ethical working conditions throughout our supply chain.»

 

5. Assessing and managing our risks

Prelco uses a risk-based approach to manage and assess the risk of forced labour and child labour. This approach helps us prioritize our efforts and adjust our actions. Our methodology for identifying risks in our supply chain, through our due diligence process, incorporates risk indicators by country, the category of the supplier and the type of product or service offered by the supplier. The resulting risk rating determines the level of additional due diligence to be applied, particularly with respect to forced labour and child labour, as well as the extent of ongoing monitoring and the frequency of reviews required.

Our method for identifying risks is based on

  1. the location of the supplier’s headquarters or production sites in countries with a low score on the Corruption Perceptions Index or at risk on the Global Slavery Index based on the products supplied to Prelco
  2. the origin of the goods or services originating from or delivered to the countries mentioned above
  3. the procurement of indirect goods and services by Prelco,
  4. the inclusion of raw materials in the products offered by the supplier to Prelco.

Prelco has implemented a comprehensive monitoring solution to detect global events that may impact its supply chain. This real-time solution enables Prelco to improve visibility into its supply chain, monitor global activities that may disrupt or affect its operations, and proactively manage risk. This system monitors natural disasters, labour disruptions, cyberattacks as well as financial and geopolitical risks, among other things.

 

6.Corrective actions

Prelco will ensure that a corrective plan is developed and implemented to improve and correct the situation. According to the principles of the United Nations Global Compact and our own policies, if a situation of non-compliance is identified, Prelco is committed to defining and implementing a corrective plan to improve and rectify the situation.

 

7. Training

Prelco employees receive personalized training on topics related to ethics and our policies. All new office employees receive a mandatory training package that includes a section on our Code of Ethics and each year, all employees in our administrative offices are required to attest that they comply with our Code of Ethics.

In 2024-25, Prelco intends to provide training to certain groups of employees, including on child labour and forced labour.

 

8.Evaluation of effectiveness

Prelco will put in place several measures to prevent and reduce the risk of the use of forced labour or child labour in its operations and supply chains. Currently, no steps have been taken to evaluate the effectiveness of these actions, but Prelco intends to further evaluate their effectiveness in preventing and reducing the risks of forced labour and child labour in its operations and supply chains.

 

9. Approval and Attestation

This report has been approved by Prelco.’s management in accordance with paragraph 11(4)(b) of the Act.

Pursuant to section 11 of the Act, I certify that I have reviewed this report for the entity mentioned. After due diligence, I confirm that the information is true, accurate and complete for the reporting year.

 

By Dominic Lavoie
President and Chief Executive Officer

Date: 30 mai 2025