Anti-Slavery Policy

Policy PDF files
English | French

PURPOSE

Through the expertise of our people and the quality of our services, The State Group Inc. aims to make our customers’ operations easier, more efficient, and more sustainable. We firmly believe that caring for the people involved in our business, communities, operations, and supply chains is crucial to our mission and a sustainable future. We also believe that sustainability encompasses operating our business responsibly and ethically. This policy outlines The State Group Inc.’s commitment to addressing modern slavery, including human trafficking and labour exploitation.

APPLICABILITY

This policy applies to all The State Group Inc. employees, contractors, and suppliers, regardless of their operating location. Compliance with this policy is mandatory.

MODERN SLAVERY

Modern slavery is a broad term used to describe situations where coercion, intimidation, or deception are used to exploit victims and jeopardize or undermine their freedom. Modern slavery can take various forms, including the following: human trafficking, slavery, servitude, forced labour, debt bondage, deceptive recruitment practices, and child labour.

OUR COMMITMENT TO COMBATING MODERN SLAVERY

The State Group Inc. will not tolerate modern slavery in any part of our business or our suppliers’ operations. However, we recognize that modern slavery is a complex issue, and that our activities or our supply chain may unintentionally be linked to modern slavery practices.

We are committed to taking ongoing steps to identify, monitor, and reduce or eliminate modern slavery risks in our supply chain in order to protect potential victims of modern slavery.

The State Group Inc. has an internal modern slavery working group (consisting of senior management leaders) that is responsible for developing and implementing controls that identify, monitor, and reduce or eliminate modern slavery risks within the business. We will also comply with reporting requirements in accordance with Canada’s Bill S-211, the “Fighting Against Forced Labour and Child Labour in Supply Chains Act”.

EXPECTATIONS

All employees of The State Group Inc. are responsible for:

Exercising professional and ethical judgment in the performance of their duties.
Avoiding any activity that might lead to a breach of this policy.
Participating in modern slavery training as required.
Treating any concern about modern slavery seriously and respectfully.
Reporting suspected or confirmed cases of modern slavery in any part of The State Group Inc.’s business or its supply chains.
Taking appropriate actions to investigate and eliminate any suspected or confirmed incidents of modern slavery within The State Group Inc.’s business or its supply chains.

The State Group Inc. expects our employees to promptly raise any concerns with their manager where they have any reason to suspect that a particular act, the treatment of workers, or their working conditions within any of our operations or supply chains constitute any form of modern slavery.

All managers and senior leaders of The State Group Inc. are responsible for:

Forwarding identified issues and reported concerns in a prompt manner.
Ensure that those reporting to them understand and comply with this policy.

All The State Group Inc. suppliers and contractors are responsible for:

Not engaging in child labour or other forms of forced or compulsory labour, human trafficking, or debt bondage.
Escalating and investigating any suspected case of modern slavery or breach of this policy to ensure that the rights and wellbeing of affected persons are protected.
Making efforts to strengthen their modern slavery policies and mitigation efforts in respect of their business and their supply chains.
Reporting any case of suspected modern slavery to The State Group Inc

POLICY ENFORCEMENT AND MODERN SLAVERY MITIGATION FRAMEWORK

We expect and encourage employees, suppliers, and contractors to report any concerns regarding modern slavery, including suspected cases or areas of concern. Concerns may be reported to any supervisor or management team member, or anonymously via the following methods:

Website: www.lighthouse-services.com/stategroup
Phone: English-speaking USA and Canada: 833-870-0008
French-speaking Canada: 855-725-0002
E-mail: reports@lighthouse-services.com (must include company name with report)

Should The State Group Inc. become aware of any breaches of this policy or potential modern slavery issues in its operations or supply chains, we will take appropriate action in a timely manner and in accordance with all applicable laws.

The State Group Inc. has a modern slavery mitigation framework, which we apply on a case-by-case basis in determining how to respond to incidents of modern slavery in our operations and supply chains. Response steps may include working with our suppliers to prepare a corrective action plan and resolve the matter as soon as practicable, notifying regulators, or potentially terminating a business relationship.

Any employee, supplier, or contractor of The State Group Inc. who breaches their obligations under this policy or engages in retaliation against any person who raises concerns about modern slavery risk will face investigation and possible disciplinary action, which could include termination of the employment or business relationship.

POLICY REVIEW AND PUBLICATION

This policy will be reviewed every two years at a minimum to ensure it remains consistent with all relevant legal requirements and the constantly evolving nature of the business. This policy may be amended, withdrawn, or replaced at The State Group Inc.’s discretion.

April 2024