Supply Chain

2024 Annual Report under the Fighting Against the Forced Labour and Child Labour in Supply Chains Act (the “Act”)

Company Name: Ice River Springs Water Co. Inc. (“IRS”)

Head Office: 485387 30 Sideroad, Shelburne, Ontario, L9V 3N5

Reporting Period: January 1, 2024 to December 31, 2024

Introduction

Forced labour and child labour are contrary to our purpose, vision and values. We do not tolerate forced labour and child labour in our organization or in those of our suppliers and subcontractors. We hold ourselves to the highest standards and expect our directors, officers and employees to act with integrity and to comply at all times with the letter and spirit of all applicable laws, regulations and rules. This annual report outlines the policies and procedures we have in place and the steps taken to reduce the risk that forced labour and child labour is used at any step of the production of goods in Canada.

Structure, Activities and Supply Chains

  • Structure: IRS is a company incorporated under Ontario’s Business Corporations Act, 1990 (OBCA) that produces bottled water. IRS owns and operates its own recycling facility and uses 100% recycled PET plastic to manufacture its bottles. As of December 31, 2024, IRS employs almost 500 team members across Canada.
  • Activities: IRS owns and operates six water bottling facilities, a recycling plant and an extrusion plant all located in Canada (5 in Ontario, 1 in Quebec, 1 in Alberta, 1 in British Columbia).
  • Supply Chains: IRS sources its raw materials from suppliers in Canada and the United States, including PET bales recovered from curbside collection and deposit-and-return systems which it transforms into food grade recycled PET (rPET) resin for use in new packaging.

Policies and due diligence processes

IRS has a corporate employee policy in place regarding involuntary labor. This policy’s stated objective is to “find practical, meaningful and appropriate responses to support the prevention and effective elimination of child labour and forced labour practices, in accordance with the principles set forth by the International Labour Organization (ILO) and by the Canada Labor Code and similar legislations in force in each of the provinces of Canada”.

While this policy is focused on employment practices, IRS’s vertically-integrated and circular economy model (see illustration below) causes IRS to prioritize local suppliers of products and services in countries with strong and enforceable child/forced labour laws.