Policies & Compliance — Industrie Fabco

Supplier and Sustainable Development Policy

This policy sets out Industrie Fabco’s principles and requirements with respect to its suppliers in matters of legal compliance, business ethics, human rights, occupational health and safety, and environmental protection.

It aims to promote responsible and sustainable practices throughout the supply chain by establishing clear expectations and fostering collaboration based on integrity, transparency, and respect for applicable standards.

1. Purpose of the Policy

The purpose of this policy is to:

ensure that suppliers adopt practices consistent with applicable standards relating to human rights, occupational health and safety, business ethics, and sustainable development, in alignment with Industrie Fabco’s values;
clearly communicate the Company’s expectations to its suppliers, both during the selection process and throughout the business relationship;
encourage suppliers to govern and improve their own supply chains to ensure compliance with the principles set out in this policy;
establish a self-assessment mechanism to verify supplier compliance;
apply to all suppliers providing raw materials used in the manufacturing of Industrie Fabco products.

2. Compliance with Laws and Regulations

Suppliers must comply with all applicable laws, regulations, and standards, whether municipal, provincial, national, or international, including, without limitation, competition laws.

3. Working Conditions and Workplace Environment

Suppliers undertake to:

comply with legal requirements regarding minimum working age and working conditions for young workers;
provide working conditions that comply with applicable standards, including hours of work, remuneration, leave, and overtime;
respect fundamental human rights, including the prohibition of forced labour, modern slavery, or any form of coercion;
ensure a recruitment process based on fairness, diversity, inclusion, and non-discrimination;
maintain a workplace free from psychological or sexual harassment;
promote gender equality and respect for the rights of minorities and Indigenous peoples;
ensure that any use of security services is carried out in compliance with human rights.

4. Occupational Health and Safety

Suppliers must comply with applicable occupational health and safety standards, including those under Quebec legislation, and implement the necessary measures to protect the health, safety, and physical integrity of their workers.

5. Business Ethics

Suppliers must conduct their activities with integrity and transparency. In this regard, they undertake to:

prevent environmental harm and respect human rights in business decisions, including investment decisions;
comply with applicable land ownership and land use laws;
prohibit any form of corruption, fraud, collusion, or extortion;
protect the confidentiality of information obtained in the course of business relationships, including financial, technical, or commercial information;
implement personal information protection policies compliant with applicable laws;
maintain accurate accounting practices and comply with tax obligations;
comply with competition laws and refrain from any agreements between competitors, including those relating to:
- price fixing;
- market allocation or division;
- production control or restriction;
proactively manage any conflict of interest situations;
respect intellectual property rights and refrain from using counterfeit products;
comply with export control laws and economic sanctions;
implement a confidential reporting (whistleblowing) mechanism and protect individuals acting in good faith from retaliation.

6. Environment

Suppliers must adopt responsible practices aimed at reducing their environmental footprint. Accordingly, they undertake to:

implement environmental policies appropriate to their activities;
manage energy and water consumption efficiently;
reduce emissions and waste materials;
control the use and handling of hazardous materials;
promote these principles within their own supply chains.

7. Responsible Sourcing of Aluminium

Industrie Fabco prioritizes the sourcing of aluminium from companies that respect human rights, business ethics principles, and sustainable development requirements.

8. Communication of the Policy

This policy is communicated to suppliers upon onboarding and is also available on Industrie Fabco’s website.

9. Verification and Compliance

Industrie Fabco provides suppliers with a self-assessment questionnaire to verify the implementation and compliance with this policy.

Effective date: April 15, 2019

Environmental Policy

This policy sets out Industrie Fabco’s commitments regarding environmental protection and sustainable development. It aims to frame the Company’s practices to reduce its environmental footprint, integrate environmental considerations into decision-making, and promote continuous improvement of environmental performance in collaboration with stakeholders.

1. Context and Commitment

In a context where environmental issues are increasingly significant, Industrie Fabco recognizes the importance of considering the environmental impact of its activities.

The Company is committed to a responsible, sustainable, and transparent approach toward its stakeholders. Through this policy, it establishes a structured framework to integrate environmental considerations into all its activities, with a view to continuous improvement and positive societal contribution.

2. Scope

This policy applies to all activities of Industrie Fabco and serves as a reference framework for its relationships with internal and external stakeholders, including employees, clients, suppliers, and business partners.

3. Commitments

Industrie Fabco undertakes to:

comply with all applicable environmental laws, regulations, and standards;
protect the environment by implementing responsible practices, including energy consumption, water use, atmospheric emissions, waste management, and the safe handling of hazardous materials;
integrate environmental considerations into decision-making and management practices;
consider, where appropriate, the life cycle of manufactured products;
foster innovation to improve environmental performance and offer more sustainable solutions to clients;
engage employees and suppliers in achieving environmental objectives;
provide appropriate training to employees to enhance environmental awareness and competencies;
implement a continuous improvement process to enhance environmental performance;
measure results, assess progress, and communicate relevant information to stakeholders.

4. Responsibilities

This policy is approved by senior management, which assumes leadership and accountability.

Its implementation is supported by the management team and the Environmental Manager, responsible for deploying actions arising from the environmental plan.

The policy and its objectives are reviewed annually in alignment with the Company’s strategic planning process.

Senior management ensures dissemination of the policy and its understanding throughout the organization. Each employee is responsible for its application within their duties.

Effective date: January 11, 2019

Complaint Handling Policy

This policy establishes the framework for receiving and processing complaints related to Industrie Fabco’s business practices. It aims to ensure confidential, fair, and timely handling of reports while protecting individuals who submit complaints in good faith from any form of retaliation.

1. Purpose

Any individual or legal entity wishing to file a complaint regarding Industrie Fabco’s business practices may do so confidentially in accordance with this policy.

Industrie Fabco undertakes to treat all complaints or reports diligently, impartially, and confidentially.

2. Protection Against Retaliation

Industrie Fabco prohibits any form of retaliation against a person who submits a complaint or report in good faith.

Accordingly, no employee or collaborator shall be subject to discrimination, disciplinary measures, dismissal, suspension, or any other form of harm as a result of reporting an act that may be contrary to laws, rules, or Company policies, including the Code of Ethics.

3. Eligibility

Any person who considers that their rights have been affected may file a complaint, including:

employees;
suppliers;
subcontractors;
any third party in a relationship with the Company.

4. Filing a Complaint

A complaint may be submitted in writing, by email, or by telephone to one of the following designated contacts:

Louise Caya, Vice President and Controller;
Pierre Cusson, Operations Director;
Caroline Cardoso, Quality and Environmental Manager.

Complaints submitted by email must be sent to [email protected].

5. Complaint Handling

Designated officers undertake to:

ensure confidential and timely processing of complaints;
analyze facts objectively and impartially;
take appropriate measures depending on the nature and severity of the situation.

Depending on the nature or complexity of the complaint, its handling may be fully or partially delegated to an independent external party.

6. Company Commitment

Industrie Fabco reaffirms its commitment to maintaining an ethical, transparent, and respectful business environment. Every complaint is considered an opportunity for continuous improvement of the Company’s practices.

Last updated on 19 - 04 - 2026.