Child Labour and Forced Labour Report

May 31, 2026

1. Introduction

This report has been prepared by Igloo Building Supplies Group Ltd. (“the Company”) in accordance with the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “Act”).

The Company is committed to conducting business in a responsible and ethical manner and actively supports the prevention of forced labour and child labour across its operations and supply chains.

This report outlines the steps taken in the last year to identify, assess, and reduce the risk that forced labour or child labour may be present at any stage of the Company’s business activities and supply chains, including the importation of goods into Canada. It also reflects the Company’s ongoing efforts to strengthen its understanding of these risks and to take reasonable and practical steps toward responsible sourcing.

2. Structure, Activities, and Supply Chains

2.1 Structure

  • Legal name: Igloo Building Supplies Group Ltd.
  • Locations:
    • Yellowknife, Northwest Territories,
    • Edmonton, Alberta, &
    • Long Sault, Ontario
  • Number of employees: ranges from 180 to 250 seasonally

The company is a Canadian controlled private corporation who also operates under a number of tradenames including: Igloo Drywall, Igloo Electrical, Igloo Exteriors, and Igloo Flooring.

2.2 Activities

The Company is engaged primarily in the wholesale distribution of building materials and home construction products, supplemented by limited manufacturing and supply and installation services.

Its product offerings include, but are not limited to:

  • Structural materials (joists, lumber, trusses):
  • Finishing materials (drywall, flooring, siding):
  • Electrical and lighting products; and 
  • Miscellaneous construction-related goods.

In addition to wholesale distribution, the Company:

  • Manufactures prefabricated components, including stairs and trusses: 
  • Provides supply and installation services for select product lines, which may include the use of approved subcontractors; and
  • Provides logistics support services, including the marshalling, crating, and packaging of goods for shipment to remote and northern regions of Canada.

Geographic areas of operation:

  • Primary operations: Canada

 

2.3 Supply Chains

The Company’s supply chain includes direct and indirect suppliers involved in:

  • Raw material sourcing (e.g., lumber, metals, electrical components):
  • Manufacturing of finished and semi-finished goods; and
  • Distribution and logistics.

Suppliers are located primarily in Canada, with additional sourcing from the United States and other international jurisdictions depending on product category.

The Company recognizes that supply chains may involve multiple tiers, where upstream manufacturing and raw material sourcing may occur in regions outside its direct visibility, consistent with typical global procurement structures.

3. Policies and Due Diligence Processes

The Company is committed to conducting its operations with integrity and in accordance with applicable laws and regulations, including those relating to labour and employment, and to upholding generally accepted standards of ethical business conduct across its operations and supply chains.

3.1 Policies

The Company maintains (or is developing) policies addressing:

  • Company Rules & Disciplinary Policy
  • Recruitment & Selection Policy
  • Reporting Violence & Harassment
  • Harassment & Discrimination Policy
  • Right to Refuse (Alberta) Policy

Taken together, and with the applicable laws and regulations these policies aim to prohibit:

  • Forced labour and human trafficking:
  • Child labour:
  • Coercion, threats, or involuntary work; and
  • Unlawful working conditions.

 

3.2 Due Diligence Processes

The Company undertakes due diligence measures aimed at identifying and reducing the risk of forced labour and child labour within its operations and supply chains. These measures include:

  • Sourcing from reputable suppliers expected to comply with applicable labour laws, including those prohibiting child labour:
  • Striving to follow responsible purchasing practices, including through promoting environmental, social, and ethical considerations into the procurement process; and
  • Prioritizing suppliers in Canada and the United States, which are generally considered lower-risk jurisdictions for forced and child labour.

 

These measures are intended to support the Company’s efforts to reduce the risk that forced labour or child labour may be present in the goods it procures, particularly where supply chains extend beyond direct suppliers or involve higher-risk jurisdictions.

4. Forced Labour and Child Labour Risks

The Company acknowledges that no supply chain is entirely risk-free, particularly where goods are sourced globally or through intermediaries.

4.1 Risk Areas Identified

Potential risk areas include:

  • Imported goods sourced indirectly through third-party distributors:
  • Provides supply and installation services for select product lines, involving the engagement of subcontractors where necessary:
  • Products manufactured outside Canada and the United States; and
  • Product categories such as:
    • Electrical components:
    • Lighting products:
    • Finished building materials; and
    • Consumer products purchased via e-commerce.

 

These areas may present elevated risk due to reduced visibility into upstream suppliers and varying regulatory environments across jurisdictions.

4.2 Risk Assessment Approach

Risk identification is based on:

  • Geographic location of suppliers;
  • Industry and product category risk; and
  • Complexity of supply chains (multi-tier sourcing).

 

To assess and manage these risks, the Company relies on the policies and processes as well as the applicable legislation and regulations in place. Additionally, the Company procures from reputable companies in jurisdictions where there is a lower risk of forced or child labour.

5. Remediation Measures

The Company is not aware of any evidence suggesting instances of forced labour or child labour in its operations or supply chains during the reporting period.

6. Remediation of Loss of Income

The Company is not aware of any loss of income to vulnerable families resulting from actions taken to eliminate forced labour or child labour risks.

7. Training

The Company does not currently provide formal training on forced labour and child labour.

The Company is evaluating various options for training programs to enhance employee awareness of forced labour and child labour risks, particularly for employees involved in procurement and supply chain management. This should be implemented in the next year.

8. Assessing Effectiveness

This report sets out the measures that the Company has in place to assess and reduce the risk that forced labour and child labour is used in our business and supply chains. The Company will continue to search for opportunities to identify, prevent, and respond to the risks presented by child and forced labour.

9. Approval and Attestation

This report has been approved by the Board of Directors of Igloo Building Supplies Group Ltd.

Attestation

In accordance with the requirements of the Fighting Against Forced Labour and Child Labour in Supply Chains Act (Act), and in particular section 11 thereof, I, in the capacity of President, attest that I have reviewed the information contained in this report on behalf of the governing body of the entity listed above. Based on my knowledge, and having exercised reasonable diligence, I attest that the information in this report is true, accurate, and complete in all material respects for the purposes of the Act for the reporting year referenced above.