Report
REPORT ON COMBATING FORCED LABOR IN SUPPLY CHAINS
Report jointly issued by:
GESTION OCÉAN INC.
9145-9164 QUÉBEC INC.
9079-2508 QUÉBEC INC.
9431-3418 QUÉBEC INC.
9431-3558 QUÉBEC INC.
9215-7064 QUÉBEC INC.
GESTION CHANTIERS MARITIMES OCÉAN INC.
GESTION REMORQUAGE OCÉAN INC.
GESTION TMO/DRAGAGE OCÉAN INC.
May 31, 2024
INTRODUCTION
This report has been prepared in accordance with and for the purpose of complying with the Act on Combating Forced Labor and Child Labor in Supply Chains, L.C. 2023, c. 9 (the "Act"). It outlines the measures taken by Groupe Océan for the period from August 1, 2022, to August 31, 2023, to identify and address the risks of forced labor and child labor in its activities and supply chains. It should be noted that the financial year-end covered by this report for some Entities is July 31, 2023, while for others it is August 31, 2023.
ABOUT GROUPE OCÉAN
For 50 years, Groupe Océan has been part of the maritime landscape in Quebec, and now in Canada and the Caribbean. It is a leader in integrated maritime services on the Saint Lawrence, is present throughout Canadian territory, and continues its international development.
IDENTIFICATION OF ENTITIES
For the purposes of this report, the term "Entity" has the meaning provided in the Act.
In this report, and solely for the purposes of this report, the term "Groupe Océan" refers to all the Entities that have jointly approved this report, namely:
| Legal Name of the Entity | Type of Organization | Quebec Business Number | Federal Business Number | Head Office Address | Sector of Activity |
|---|---|---|---|---|---|
| GESTION OCÉAN INC. | Corporation incorporated on August 26, 1991, governed by the Business Corporations Act, RLRQ c S-31.1 | 1143497684 | 895374742 | 500-105 Abraham-Martin Street Québec (Quebec) G1K 8N1 Canada | Holding Company |
| 9145-9164 QUÉBEC INC. | Corporation incorporated on August 25, 2004, governed by the Business Corporations Act, RLRQ c S-31.1 | 1162448014 | 849020276 | 500-105 Abraham-Martin Street Québec (Quebec) G1K 8N1 Canada | Holding Company |
| 9079-2508 QUÉBEC INC. | Corporation incorporated on May 4, 2005, governed by the Business Corporations Act, RLRQ c S-31.1 | 1162971551 | 877436121 | 500-105 Abraham-Martin Street Québec (Quebec) G1K 8N1 Canada | Holding Company |
| 9431-3418 QUÉBEC INC. | Corporation incorporated on December 15, 2020, governed by the Business Corporations Act, RLRQ c S-31.1 | 1176064294 | 788526200 | 500-105 Abraham-Martin Street Québec (Quebec) G1K 8N1 Canada | Holding Company |
| 9431-3558 QUÉBEC INC. | Corporation incorporated on December 15, 2020, governed by the Business Corporations Act, RLRQ c S-31.1 | 1176064690 | 788528404 | 500-105 rue Abraham-Martin Québec (Québec) G1K 8N1 Canada | Holding Company |
| 9215-7064 QUÉBEC INC. | Corporation incorporated on November 5, 2009, governed by the Business Corporations Act, RLRQ c S-31.1 | 1166209297 | 837886258 | 500-105 Abraham-Martin Street Québec (Quebec) G1K 8N1 Canada | Holding Company and Intellectual Property Licensing Company |
| GESTION CHANTIERS MARITIMES OCÉAN INC. | Corporation incorporated on July 31, 2014, governed by the Business Corporations Act, RLRQ c S-31.1 | 1170254230 | 833967383 | 500-105 rue Abraham-Martin Québec (Québec) G1K 8N1 Canada | Holding Company |
| GESTION REMORQUAGE OCÉAN INC. | Corporation incorporated on July 31, 2014, governed by the Business Corporations Act, RLRQ c S-31.1 | 1170254453 | 837728799 | 500-105 Abraham-Martin Street Québec (Quebec) G1K 8N1 Canada | Holding Company |
| GESTION TMO/DRAGAGE OCÉAN INC. | Corporation incorporated on October 17, 2013, governed by the Business Corporations Act, RLRQ c S-31.1 | 1169549137 | 827993635 | 500-105 rue Abraham-Martin Québec (Québec) G1K 8N1 Canada | Holding Company |
SUBJECTION TO THE LAW
Each Entity within Groupe Océan is subject solely to Canadian reporting requirements. Although, with the exception of 9215-7064 Québec inc., each Entity within Groupe Océan is a corporation with no commercial activity, it qualifies as an Entity due to the commercial activities of its operating subsidiaries and sub-subsidiaries. Thus, through their subsidiaries and sub-subsidiaries, each of Groupe Océan’s Entities has a commercial presence in Canada, as they have an establishment in Canada, conduct activities there, or own assets there and, according to their consolidated financial statements, meet at least two of the following conditions for at least one of their last two fiscal years:
a) they have assets worth at least $20,000,000;
b) they have generated revenues of at least $40,000,000;
c) they employ an average of at least 250 employees.
A. STRUCTURE, ACTIVITIES, AND SUPPLY CHAINS
STRUCTURE OF GROUPE OCÉAN
Legal and Organizational Structure
Each Entity within Groupe Océan is a corporation governed by the Business Corporations Act, RLRQ c S-31.1. We refer you to the introduction section of this report for more information on each Entity.
The companies controlled, directly or indirectly, by the Entities of Groupe Océan can be segmented into seven main categories:
a) Companies operating activities related to shipyards;
b) Companies operating activities related to pilot services on the Saint Lawrence River;
c) Companies operating towing activities;
d) Companies operating dredging activities;
e) Companies operating maritime works;
f) Companies operating equipment and vessel rental activities;
g) Companies operating personnel management and administrative services activities.
Although each operating company is part of the same corporate group, they operate distinct businesses and are contractually autonomous.
Number of Employees
Groupe Océan, considering all its subsidiaries and sub-subsidiaries, has approximately 1,007 employees located in Canada and about 37 employees located in Jamaica.
Governance of Entities
It is possible to distinguish two categories of Entities within Groupe Océan based on their governance: on one side, the Entities that directly or indirectly control 9215-7064 Québec inc., and on the other side, 9215-7064 Québec inc. and its subsidiaries and sub-subsidiaries. The distinction is made at the level of 9215-7064 Québec inc. due to the presence of institutional investors as shareholders, namely: CDP Investissements inc. and Fonds de solidarité des travailleurs du Québec (F.T.Q.). Certain decisions of 9215-7064 Québec inc. and its subsidiaries and sub-subsidiaries require the consent of these investors to take effect.
The day-to-day management and operation of the subsidiaries and sub-subsidiaries of 9215-7064 Québec inc. is the responsibility of the President and CEO of 9215-7064 Québec inc., Mr. Jacques Tanguay. He has the authority to bind each of these subsidiaries or sub-subsidiaries regarding their supply chains.
As for the Entities that directly or indirectly control 9215-7064 Québec inc., namely 9431-3418 Québec inc., 9079-2508 Québec inc., 9145-9164 Québec inc., and Gestion Océan inc., they also have no employees and neither produce nor import any goods. These Entities are controlled, directly or indirectly, by Mr. Gordon Bain and are managed by their respective boards of directors.
OUR ACTIVITIES
Groupe Océan operates in the maritime services sector. The tables below illustrate the main activities carried out by companies that are directly or indirectly controlled by an Entity of Groupe Océan, as well as the types of goods produced, sold, distributed, or imported, and their annual quantities.
Considering that Gestion Océan inc., 9145-9164 Québec inc., 9079-2508 Québec inc., 9431-3418 Québec inc., 9431-3558 Québec inc., and 9215-7064 Québec inc. control all the Entities mentioned in the tables below, the information mentioned in these tables applies to them as well.
Production; Sales and Distribution
| Targeted Entity | Economic Activities of Subsidiaries and Sub-subsidiaries It Controls | Jurisdiction of Business Operations | Production; Sales; Distribution | Relevant Goods and Approximate Quantities | Jurisdiction (Exportation) |
|---|---|---|---|---|---|
| GESTION CHANTIERS MARITIMES OCÉAN INC. | Shipbuilding and Repair | Canada | Production, Sales, Processing | Imported Steel for Shipbuilding and Repair: 1.5 million pounds Imported Engines for Shipbuilding and Repair: 4 to 8 complete engines Imported Ship Parts for Shipbuilding and Repair: Several thousand diverse components for mechanical systems, hydraulics, pneumatics, navigation equipment, finishing components (doors, windows, walls, paint, insulation), industrial tools, and manufacturing supplies. | Canada |
| GESTION REMORQUAGE OCÉAN INC. | Harbor Towing | Canada et Jamaïque | N/A | N/A | N/A |
| GESTION TMO/DRAGAGE OCÉAN INC. | Dredging Services | Canada | N/A | N/A | N/A |
Importation
| Targeted Entity | Economic Activities of Subsidiaries and Sub-subsidiaries It Controls | Jurisdiction of Business Operations | Relevant Goods and Approximate Quantities Imported (Annual Basis) | Jurisdiction (Importation) |
|---|---|---|---|---|
| GESTION CHANTIERS MARITIMES OCÉAN INC. | Shipbuilding and Repair | Canada | Steel: 1.5 million pounds Moteurs : 4 à 8 moteurs complets Ship Parts: Several thousand diverse components for mechanical systems, hydraulics, pneumatics, navigation equipment, finishing components (doors, windows, walls, paint, insulation), industrial tools, and manufacturing supplies. | Canada, United States, China, Germany, Spain, France, United Kingdom, Italy, Netherlands, Norway, Romania, Turkey |
| GESTION REMORQUAGE OCÉAN INC. | Harbor Towing | Canada et Jamaïque | Several thousand diverse components necessary for our navigation and harbor towing operations, including mechanical components, safety equipment, paint, finishing parts, anchors, chains, mooring lines, nautical charts, electronic and automation components, navigation aid systems, hydraulic parts, pumps, engines, piping, and plumbing. | Canada, United States, Belgium, Czechia, Denmark, India, Jamaica, Netherlands |
| GESTION TMO/DRAGAGE OCÉAN INC. | Dredging Services | Canada | Several thousand diverse components necessary for our navigation and harbor towing operations, including mechanical components, safety equipment, paint, finishing parts, anchors, chains, mooring lines, nautical charts, electronic and automation components, navigation aid systems, hydraulic parts, pumps, engines, piping, and plumbing. Additionally, there are equipment specific to dredging operations, such as buckets, dredging cranes, workboats, seabed detection equipment, barges, and winches. | Canada, United States, China, Germany, Netherlands, Norway |
OUR SUPPLY CHAINS
Our supply network includes approximately 1,500 direct and capital goods suppliers, as well as 150 service providers. This network includes various strategic partners covering a wide range of areas, such as the supply of raw materials, electronic components, propulsion systems, and technical and logistical services.
Our suppliers are primarily located in Canada, the United States, and the European Union. A small percentage of them are located in Asia. The goods we source from Asia include mechanical components, hydraulic components, wall panels, doors, windows, anchors, mooring lines, chains, and anodes.
As a vertically integrated company, we are involved in all stages of the value chain, including shipbuilding, maintenance, and operations. This integration allows us to ensure consistent quality and optimal coordination at every stage of our projects. Nearly all of our supplier network plays a dual role, serving as both direct and indirect suppliers. They supply our shipyards for contracts intended for our external clients and also contribute to the manufacturing, maintenance, repair, and upkeep of our own assets for our maritime and towing operations.
B. POLICIES AND DUE DILIGENCE PROCESSES RELATED TO FORCED LABOR AND CHILD LABOR
Given the nature of Groupe Océan's supply chains and the fact that almost all jurisdictions involved in the importation of goods used by Groupe Océan have enacted laws prohibiting forced labor and child labor, the Entities within Groupe Océan have not, at this time, implemented specific policies or due diligence processes regarding forced labor and child labor.
C. RISKS OF FORCED LABOR OR CHILD LABOR
Groupe Océan has entrusted the management of its human resources to one of the subsidiaries of 9215-7064 Québec inc., which ensures that the employment standards set out by applicable Canadian and provincial laws are followed by all operating subsidiaries and sub-subsidiaries of Groupe Océan. Therefore, to the best of Groupe Océan's knowledge, no risks of forced labor or child labor have been identified in its own activities or those of its subsidiaries and sub-subsidiaries. However, considering Groupe Océan's supply chains and the jurisdictions involved in the importation of goods used by Groupe Océan, the Entities within Groupe Océan have not, at this time, begun a formal process to determine the risks of forced labor or child labor being used in the activities of their direct or indirect suppliers.
D. MEASURES TAKEN TO REMEDY THE USE OF FORCED LABOR OR CHILD LABOR
Given that Groupe Océan has not identified any risks of forced labor or child labor being used in its own activities, those of its subsidiaries and sub-subsidiaries, or those of their direct or indirect suppliers, no measures have been taken to remedy forced labor or child labor within Groupe Océan's activities and supply chains.
E. MEASURES TAKEN TO REMEDY REVENUE LOSSES CAUSED BY THESE MEASURES
Since Groupe Océan has not taken any measures to remedy forced labor or child labor within its activities and supply chains, no measures have been taken to remedy the revenue losses of the most vulnerable families caused by any measure aimed at eliminating the use of forced labor or child labor within Groupe Océan's activities and supply chains.
F. EMPLOYEE TRAINING
Considering Groupe Océan's supply chains and the jurisdictions involved, the Entities within Groupe Océan have not, at this time, implemented training on forced labor and child labor but have established a health and safety training program that is accessible to all employees based on their trade and, in some cases, is mandatory.
G. ASSESSMENT OF THE EFFECTIVENESS AND IMPACT OF OUR ACTIONS
Given Groupe Océan's supply chains and the jurisdictions involved, and since the Entities within Groupe Océan have not, at this time, implemented policies or due diligence processes regarding forced labor and child labor, no measures have been taken to assess the effectiveness of preventing and reducing the risks of forced labor or child labor within Groupe Océan's activities and supply chains.
APPROVALS
This report has been approved by the respective boards of directors of the following Entities: 9431-3418 Québec inc., 9079-2508 Québec inc., 9145-9164 Québec inc., and Gestion Océan inc., which appointed Mr. Gordon Bain as the signatory of the report.
In accordance with the requirements of the Act on Combating Forced Labor and Child Labor in Supply Chains, and in particular Section 11 of this Act, I certify that I have reviewed the information contained in the report for the entity or entities listed above. To the best of my knowledge, and after exercising due diligence, I certify that the information contained in the report is truthful, accurate, and complete in all material respects for the purposes of the Act, for the reporting year mentioned above.
