Report on Forced Labour and Child Labour Risks

Fiscal Year ended: September 30, 2023 Report published: May 31, 2024

Introduction

The Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “Act”) requires that businesses state actions they have taken during the fiscal year to prevent and reduce the risk of forced labour or child labour within their operations and supply chain. This is a joint report for Mission Environmental Services Group Inc. (“Mission”) and its Canadian subsidiaries (collectively “Mission Group”). The following diagram sets out the Canadian Mission group and lists all subsidiaries that are included in this joint report. This report includes steps taken by Mission Group in its fiscal year ended September 30, 2023, as well as steps taken since then to the publication date of this report.

This report is not a revised version of a report already submitted for Mission Group for its financial year ended September 30, 2023. None of the entities included in this report are subject to reporting requirements under the supply chain legislation in another jurisdiction.

Mission Group is committed to complying with applicable laws and to acting with care and integrity as it works with employees, customers, and suppliers. Mission Group is committed to finding practical, meaningful, and appropriate responses to support the prevention and effective elimination of child labour and forced labour practices in Canada and around the world.

Steps Taken

During the year ended September 30, 2023 and since then to the publication date of this report, Mission Group has undertaken the following steps to prevent and reduce the risk that forced labour or child labour is used at any step of the production of goods in Canada or elsewhere by Mission Group or of goods imported into Canada by Mission Group:

Adopted a Preventing Child and Forced Labour Policy
Adopted a Supplier Code of Conduct
Implementing a Supplier Due Diligence Program
Executive orientations on the problem of forced labour and child labour and Mission Group's responses
Planning for sessions with general managers and procurement staff on the problem of forced labour and child labour and Mission Group's response

Structure, Activities, and Supply Chains

Mission is a Canada private company, incorporated in Alberta. It wholly owns the subsidiaries set out in the Introduction. The registered office for Mission and head office for Mission Group is located at #610, 1509 Centre Street SW, Calgary, Alberta. Mission Group has approximately 286 employees in Canada and 33 employees in the United States. Mission Group does not have any employees in any other country.

Mission Group is a group of locally based waste services companies in Alberta, British Columbia, and Washington. Its services include solid, liquid, and construction waste, as well as recycling and organic waste. Mission Group is primarily a services company, with goods sold including gravel and compost.

Mission Group’s supply chain is sourced almost entirely in Canada and United States, with some exceptions for products like tires and uniforms. Primary inputs to Mission Group include fuel, trucks and equipment, and parts for trucks and equipment.

Policies and Due Diligence Process

The following are the policies and due diligence process that Mission Group has put in place aimed at preventing and mitigating risks relating to the use of forced labour or child labour in its supply chains.

Preventing Child and Forced Labour Policy

Mission Group’s commitment begins with its own activities. This Policy applies to all employees

and contractors of Mission Group. The Policy provides that:

All labour must be voluntary
No labour is to be performed by children (under the age of 14 or the local minimum age).
Reliable records must be kept for all
Hazardous work is not to be performed by persons under 18 years of
Mission does not require original identification
Workers are not required to pay recruitment fees or incur
Workers have freedom of movement
Workers have freedom to terminate employment

There is zero tolerance for any breach of this Policy and retaliation for reporting is not permitted. A specific contact for questions and reporting is provided.

Supplier Code of Conduct

Mission Group suppliers are expected to adhere to the Supplier Code of Conduct. Adherence includes compliance with the Code by all suppliers, vendors, agents, and subcontractors and their respective facilities. The Code includes requirements similar those in the Mission Group Preventing Child and Forced Labour Policy, as well as the following:

Workers must be compensated with wages and benefits that meet minimum requirements established by applicable law and collective agreements.
Suppliers shall provide proof of payment to workers in the worker’s native
No deductions from wages, except those legally
Work hours are to be within that are legally
Supplier shall provide a safe, healthy, and sanitary working
Contact information for a Mission liason is provided for questions or reporting
Supplier is to comply with all applicable laws related to the code
Mission may, in its discretion, inspect the Supplier’s facilities

Mission may immediately terminate its business relationship (including any purchase order(s) and purchase contracts) with a supplier if that supplier or its partners fail to meet the Code.

Supplier Due Diligence Program

Mission Group has adopted a supplier due diligence program with a risk-based due diligence approach. Mission Group’s goal is to implement different approaches for different groups of suppliers. Suppliers have been grouped into the following categories and the current steps for each category are as indicated. The groupings and the steps will continue to evolve, with the goal being to increase due diligence over time. At present, the groupings are based on supplier spend, but Mission Group will refine these groupings to consider the supplier’s location and type of product or service. A tool being used to curate the grouping is the U.S. Department of Labour 2022 List of Goods Produced by Child Labor or Forced Labour.

Level	Steps Being Taken
Level 3 (high) Due Diligence	Carry out direct due diligence regardless of location of supplier or type of product or service. All suppliers in this category should have their own supply chain policies or adhere to ours. Online research has been carried out on all suppliers in this group as at May 27, 2024. Suppliers that do not have their own policies will be required to complete brief questionnaires.
Level 2 (medium) Due Diligence	Mission’s due diligence will vary with respect to suppliers in this group. Some suppliers in this category may be re-categorized as Level 1 or 3 as the groupings continue to evolve. In general: Make suppliers aware of Supplier Code of Conduct. Require suppliers to adhere to Supplier Code of Conduct or similar policies through purchase orders or similar contractual arrangements, where possible.
Level 1 (low) Due Diligence	No direct due diligence or requirements but implement the following best practices: Consolidate suppliers where possible. Using known suppliers where possible (local, visible brands, etc.). Learning more about all suppliers, particularly when the supplier is not visible. Be aware of indicators of human trafficking (guidelines provided). Move suppliers in this category that are outside Canada or United States to Level 2. Move suppliers in this category that provide high risk goods or services to Level 2.

Risk Assessment

Mission Group considers the risk of forced labour or child labour to be low in its operations in Canada as all employees are in Canada or the United States and the vast majority of products are sourced from Canada or the United States.

As part of its Supplier Due Diligence Program, to further assess risk, Mission Group will:

Carry out direct due diligence on its level 3 suppliers (initial due diligence completed May 27, 2024).
Require questionnaires from level 3 suppliers that do not have their own
Further curate the grouping of suppliers based on supplier’s location and type of product or service, and adopt steps, particularly for level 2 suppliers, for higher risk goods and goods and services from higher risk regions. Tires and uniforms are examples of supplies that may be considered higher risk.
Carry out training with Mission Group staff on identifying labour

Remediation

Mission Group has not identified risks related to forced labour or child labour in its supply chains at present and will continue to assess these risks. Further, Mission Group has not identified forced labour or child labour in its own direct operations. If and when risks are identified, Mission Group will develop and implement measures to remediate any forced labour or child labour.

As no instances of forced labour or child labour in its activities or supply chains have been identified by Mission Group, no measures have been taken to remediate the loss of income to the most vulnerable families that results from any measure taken to eliminate the use of forced labour or child labour.

Training

Initial training and awareness material has been provided to the senior executives of Mission. Initial training for general managers has been organized and more detailed training for general managers and other key staff involved with procurement is planned.

Effectiveness Assessment

Mission Group’s Supplier Due Diligence Program is an iterative program that is intended to be continually improved. As part of this program, Mission Group will develop measures to assess its effectiveness in ensuring that forced labour and child labour are not being used in its activities or supply chains.

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Approval and Attestation

This Report was approved by the board of directors of Mission pursuant to Section 11(4)(b)(ii) of the Act.

In accordance with the requirements of the Act, and in particular section 11 of the Act, 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.

I have the authority to bind Mission Environmental Services Group Inc.

Nathan Weiland, COO and Director

Mission Environmental Services Group Inc.