This disclosure is provided pursuant to the Canada Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “Act”) with respect to Cardinal Glass Industries, Inc. and any of its subsidiaries (Cardinal IG Company, Cardinal GG Company, Cardinal FG Company, Cardinal CT Company and Cardinal LG Company) that are subject to the Act (the “Cardinal Companies”). This is not an admission that any of the Cardinal® Companies are subject to the Act if, in fact, such entity is not subject to the Act.

The Cardinal Companies do not knowingly use “child labour” or “forced labour,” as defined under the Act, in their activities or supply chains. Each of the Cardinal Companies has adopted a Code of Conduct and a Supplier Code of Conduct requiring compliance with applicable laws, rules and regulations related to the prevention of human rights abuses, including prohibitions against trafficking in persons, slave labor, forced labor and child labor in their operations and supply chains.

Each of the Cardinal Companies was similarly operated and addressed matters relating to forced labour and child labour in the same manner.

(a) Each of the Cardinal Companies was a corporation. The Cardinal Companies engaged in business relating to the manufacture, processing, and sale of glass and insulating glass units primarily for use in residential window applications. Materials were obtained by each of the Cardinal Companies separately from third party suppliers although certain of the Cardinal Companies received a substantial portion of their materials from the other Cardinal Companies.

(b) The Cardinal Companies have adopted a Code of Conduct pursuant to which the Cardinal Companies are to comply with applicable laws, rules and regulations related to the prevention of human rights abuses, including prohibitions against trafficking in persons, slave labor and child labor, and pursuant to which the Cardinal Companies and its suppliers at all tiers are to use diligence to identify violations of any law or regulation related to human rights at their organizations and in their supply chains, as well as the use of child labour and forced labour (as defined under the Fighting Against Forced Labour and Child Labour in Supply Chain Act adopted in Canada) and human trafficking. Such obligation includes assessing risks, and investigating actual and suspected violations. Suppliers to the Cardinal Companies are to cooperate and provide the Cardinal Companies information requested relating to the foregoing, take appropriate action to address risks of human rights violations and take remedial action to eliminate violations within their supply chains serving the Cardinal Companies. The Cardinal Companies have also adopted a Supplier Code of Conduct with similar terms to be applicable to suppliers to the Cardinal Companies and their supply chains. The standard Purchase Order Terms and Conditions of the Cardinal Companies incorporate the Supplier Code of Conduct and prohibit suppliers and their supplier’s subcontractors/suppliers from using any form of slave labor, forced, bonded or indentured labor, illegal prison labor, illegal child labor, and any physically abuse of their workers, engagement in human trafficking or sexual exploitation. The Cardinal Companies have been and intend to continue educating personnel on the Supplier Code of Conduct and standard Purchase Order Terms and Conditions to increase awareness and implementation. The Cardinal Companies’ personnel and executives, who have significant industry experience and knowledge, met from time to time to evaluate the business practices of suppliers to assess them, including with respect to risks associated with forced labour and child labour.  Diligence processes were based on the evaluated risk of forced labour and child labour.
(c) International suppliers or sub-tier suppliers of materials are believed to carry the greatest risk of forced labour and child labour in the supply chain of the Cardinal Companies. The steps taken to assess and manage risk of forced labour and child labour are stated in (b) above. (d) Not applicable, no forced labour or child labour was identified and no measures were taken to remediate forced labour and child labour.
(e) Not applicable, no loss of income to the most vulnerable families was identified that results from any measure taken to eliminate the use of forced labour or child labour in the Cardinal Companies activities and supply chain given that no forced labour or child labour was identified at the Cardinal Companies or in their supply chains.
(f) Human resource personnel were trained with respect to employment law which include applicable legal prohibitions on forced labour or child labour.
(g) The Cardinal Companies assessed their effectiveness in ensuring that forced labour and child labour are not being used in their businesses and supply chains during the meetings referenced in (b) above. The Cardinal Companies intend to continue to monitor for indicators of forced labour and child labour in their supply chains and intend to take appropriate action if forced labour or child labour in their businesses or their supply chains is suspected or identified.

In accordance with the requirements of the Act, and in particular Section 1 thereof, the undersigned person, in the capacity of Chief Financial Officer of the Cardinal Companies, attests that I have reviewed the information contained in the report on behalf of the governing bodies of the Cardinal Companies. 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 within this report.