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Modern Slavery Report

Modern Slavery Report – Brian Cullen Motors Ltd

May 30 2024, Brian Cullen Motors

1. Introduction

This report is made on behalf of Brian Cullen Motors Ltd (“Company”) and describes the actions
taken by the Company during the financial year ending December 31, 2023 to assess, prevent
and reduce the risk that forced labour or child labour is used at any step in its operations and
supply chains pursuant to the requirements of section 11 of the Fighting Against Forced Labour
and Child Labour in Supply Chains Act (“Act”). This Report constitutes the first report prepared
by the Company under the Act.

2. Structure, Activities and Supply Chains

The Company is a Corporation based in St. Catharines, Ontario.

The Company specializes in the retail sale of motor vehicles and parts as well as
comprehensive vehicle servicing and repairs.

As a dealer of new and used vehicles and their parts, our supply chain is primarily based on the
supply chain of automotive manufacturers. Specifically, as an authorized General Motors dealer,
the majority of the Company’s procurement spend is through General Motors. General Motors
are actively traded on the New York Stock Exchange and their activities, policies, and
procedures receive scrutiny from several stakeholders.

We also purchase goods and services from other third party suppliers. These suppliers are all
local to our region and provide services to numerous other businesses, including competing
dealerships, within our region. No single third party supplier makes a material contribution to our
operations, aside from General Motors.

3. Policies and Due Diligence Processes

We do not employ any non-citizens and all employees must submit a copy of their driver’s
license upon hiring to confirm they are of legal engage to work in the Province of Ontario.

All third party suppliers who enter our facilities are known to at least one department manager
and there are no minors or forced laborers.

4. Assessment of Forced Labour and Child Labour Risks

The Company has not independently engaged in its own risk assessment with regards to forced
labour or child labour in its supply chain. As the majority of the Company’s supply chain is
based on the supply chain of General Motors, it relies on the assessment undertaken by
General Motors with regards to the extent of this risk.

5. Remediation Measures

The Company has not identified any instances of forced labour or child labour in its supply
chain, and so no remediation measures have been taken.

6. Remediation of Loss of Income

The Company has not identified any instances where the measures it has implemented to
eliminate forced labour or child labour from its supply chain has led to the loss of income, and
so no remediation measures have been taken to address this issue.

7. Training

All employees are required to participate in HR training upon hire, which clearly indicate their
rights and responsibilities as employees and/or managers.

All members of management are expected to behave ethically and represent the Company in a
positive manner at all times. Benefiting from forced labour or child labour would be a breach of
the company’s ethics.

8. Assessing Effectiveness

The Company has not taken any action to assess its effectiveness in addressing risks of forced
labour and child labour in its activities and supply chains.

9. Approval and Attestation

This report has been approved by the ownership and management of Falls Chevrolet Cadillac
Buick GMC Ltd. in accordance with section 11(4)(a) 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 entity or entities listed above.
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 above.

Full name: Tammy Hartin

Title: Secretary Treasurer

Date: May 29, 2024

Signature: Tammy Hartin

I have the authority to bind Brian Cullen Motors Ltd.

General Motors of Canada Company Modern Slavery Report 2023