Annual Report pursuant to the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “Act”)

Annual Report pursuant to the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “Act”)

Introduction, Organization and Structure

This report is being filed as a joint report (in accordance with section 11(2) of the Act) with respect to the activities of The True North Entertainment Complex Limited Partnership, Winnipeg Jets Hockey Club Limited Partnership and TN Arena Limited Partnership (all three together, “True North”). The reporting period is from July 1, 2022 – June 30, 2023 (the “Reporting Period”).

Activities

True North is a privately owned and operated company that is located in Winnipeg, Manitoba, Canada and is primarily focused on sports and entertainment. True North owns and operates Canada Life Centre (a 15,300 seat arena and concert venue), the Winnipeg Jets Hockey Club (a National Hockey League franchise), the Manitoba Moose Hockey Club (an American Hockey League franchise), hockey for all centre (a community sports complex) and the Burton Cummings Theatre for Performing Arts (a 1,500 seat concert venue). Additionally, True North operates retail stores which sell Winnipeg Jets and Manitoba Moose merchandise. Lastly, True North operates a real estate division, True North Real Estate Development.

Supply Chains

True North relies on a supply chain located primarily in North America. Below is a summary of the direct and indirect goods and services purchased:

  • Food and Beverage Costs: food and beverage, concessionaire management.
  • Retail Operations Costs: clothing and other items sold in store.
  • Entertainment Costs: promotional giveaways, equipment.
  • Technology Costs: information technology infrastructure, hardware providers, software suppliers, public cloud services; outsourced data centre services, data, and data feeds.
  • Marketing Costs: digital advertising including social media, television media and advertising services, marketing and market research.
  • People Costs: recruitment services, staff travel and accommodation.
  • Overheads: professional services, such as accountancy, audit and legal advice, banking and payment service providers, engineering professionals and architects, insurance, office equipment, cleaning and catering services.
  • Facility Maintenance Costs: services, such as equipment and infrastructure services, facility conversion and cleaning; equipment suppliers, facility infrastructure suppliers.

Policies and Due Diligence Processes

Supplier Code of Conduct
Although outside of the Reporting Period, it remains relevant to indicate for the purposes of this Report that in 2024, True North drafted and is now in the process of implementing a Supplier Code of Conduct in order to provide suppliers with a clear set of expectations regarding ethical standards and to assist in ensuring that True North’s suppliers comply with laws and regulations relating to labour practices and human rights practices. With respect to child and forced labour specifically, the True North Supplier Code of Conduct states that suppliers will ensure there is no child labour, forced labour or exploitation of any kind within their organization or within any suppliers who are supplying their organization.

Within the True North Supplier Code of Conduct, True North reserves the right to terminate its relationship with a supplier who fails to comply with the standards contained therein. The True North Supplier Code of Conduct also indicates that a supplier shall agree to meet with True North upon request, to review compliance with the True North Supplier Code of Conduct.

Legal Agreements
For suppliers with whom contractual legal agreements are established, specific clauses obligating the contracted supplier to adhere to the True North Supplier Code of Conduct have been formulated and will be included in all future legal agreements.

Internal Procedures Regarding Employment
All True North employment contracts adhere to applicable employment standards, including a requirement that all young people must complete the Young Workers Readiness Certificate Course, with a certificate of completion that is signed by their parent and/or guardian prior to commencing work.

Part of Business and Supply Chain that Carry a Risk of Forced Labour and Child Labour

With respect to the supply of goods and services, True North assesses the risk of forced labour and child labour at being minimal to non-existent. The majority of True North suppliers are from geographies that have modern slavery or similar regulations in place, thereby substantially mitigating geographic/country risk.

With respect to its own workforce, True North assesses the risk of forced labour and child labour as being non-existent. True North has a department that oversees the application of specific human resource policies and a portion of the True North workforce is covered by a collective agreement, thereby helping negate the risk of forced or child labour.

Remediation, if applicable

Not applicable. No incidences of child labour or forced labour were identified in True North activities or supply chain. True North therefore did not take any measures to remediate an instance of forced labour or child labour.

Remediation of Loss of Income of Vulnerable Families, if applicable

Not applicable. True North has not identified any loss of income to vulnerable families resulting from measures taken to eliminate the use of forced labour or child labour in True North’s activities and supply chains.

Training Provided to Employees on Forced Labour and Child Labour

True North undertakes to identify those employees who engage suppliers or conduct contract negotiations and who therefore require specific training with respect to forced labour or child labour in the supply chain. By the end of True North’s 2025 fiscal year (ending June 30, 2025), training will be created and delivered by in-house counsel to any identified individuals and to all members of True North’s executive management.

Effectiveness

In preparing this report, True North engaged a cross-functional working group made up of individuals within the organization with knowledge of True North’s supply chain, and with
individuals responsible for the oversight of finance and legal. The working group performed an extensive examination of the True North supply chains and risk processes. No child labour or forced labour has been identified at this time. The intent of True North is to continue monitoring for indicators of child labour or forced labour in the True North supply chain, including performing due diligence on vendors, including anti-child labour and forced labour representations in material supply agreements with suppliers, and providing training to identified employees.

Approval

This report was approved by the Board of Directors of Winnipeg Jets Hockey Club Inc. and True North Sports & Entertainment Limited, as being a joint report of The True North Entertainment Complex Limited Partnership, Winnipeg Jets Hockey Club Limited Partnership and TN Arena Limited Partnership, in accordance with subsection 11(4)(b)(ii) of the Act.

In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for the entities listed above. Based on 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 period listed above.

I have authority to bind True North.


John Olfert, President & Chief Operating Officer, on behalf of True North
May 22, 2024