Report on Modern Slavery
Annual Report under the Fighting Against Forced Labour and Child Labour in Supply Chains Act (Canada)
May 23, 2024
Canada enacted its Fighting Against Forced Labour and Child Labour in Supply Chains Act and amended
its Customs Tariff (the “Act” or the “Canadian Modern Slavery Act”) in May 2023. Under the Act, companies
meeting specific criteria, including Resolute Health Corporation Limited (“Resolute”) and its wholly owned
subsidiaries listed below (together referred to as the “Company”) are required to prepare and file an annual
report with the Minister of Public Safety and Emergency Preparedness of Canada. This report describes
the risks within the Company’s supply chain, as well as the risk mitigation measures and diligence
procedures implemented to address such risks.
Steps to prevent and reduce risks of forced labour and child labour
The Company is committed to reducing the risks of forced labour and child labour in its supply chain and
endeavours to continuously improve its diligence, risk assessment and remediation processes. Steps taken
to date to reduce the risks of forced labour and child labour have consisted of conducting an internal
assessment of risks in the organization’s own activities and its supply chains. In addition, the development
and implementation of due diligence policies and processes for identifying, addressing and prohibiting the
use of forced labour and child labour in the organization’s activities and supply chains. These measures
are described in further detail below.
Structure, activities and supply chains
This joint report is prepared by Resolute, and on behalf of the following entities, all of which are wholly
owned subsidiaries of Resolute, for the reporting period from October 1, 2022 to September 30, 2023:
- The Snore Shop Atlantic Inc.;
- Advacare Inc.;
- Sleep Management Group Limited;
- Complete Respiratory Care Inc.;
- Coastal Sleep Homecare Services Inc.;
- Oxylife Respiratory Services Ltd.;
- Island CPAP Services and Supplies Ltd.
- Archer Respiratory Care Inc.; and
- Clinical Sleep Solutions Inc.
The Company operates sleep apnea clinics across Canada, with the corporate head office located in
Bedford, Nova Scotia.
This report outlines the Company’s business activities in Canada with respect to the sale of goods and
services. During the reporting period, the Company only operated in Canada and did not produce or
manufacture goods. The Company may from time to time import goods which would be considered to be
very minor dealings.
The Company sells goods and services directly to its patients through its websites across Canada and clinic
operations located in Nova Scotia, New Brunswick, Prince Edward Island, Quebec, Ontario and British
Columbia.
The goods sold by the Company are purchased primarily from companies in Canada, the United States
and New Zealand. The Company is very rarely the importer of record for purposes of Customs Canada.
The categories and range of suppliers is not broad as the Company operates in the specific market of sleep
apnea treatment with the majority of the goods sold being medical equipment which is approved by Health
Canada prior to the Company’s sale to consumers. The Company typically stocks inventory at the clinic
locations across Canada, and may use third-party warehousing locations. It is rare that equipment is
custom-ordered and shipped directly to a patient.
In addition to goods sold, the Company also sources services through its supply chain from third parties for
items such as software, professional services, advertising, rented clinic space and communications.
Due diligence in relation to forced labour and child labour
During the reporting period, the Company performed an assessment of its suppliers based on spend and
reviewed the policies and procedures associated with forced labour and child labour on its top suppliers
from a volume perspective of goods and services, representing over 50% of it’s annual total spend and over
90% of it’s cost of goods sold in Canada.
This assessment included a review of the suppliers’ policies and procedures as it relates to such items as
supply chain management, code of conduct and child labour. In addition, the Company from time to time
conducts due diligence on its major vendors in the context of forced labour, child labour and modern slavery
by reviewing publicly available documents and purchasing published reports by third party agencies that
provide commercial data and inights to assist in identifying potential risks.
Policies and due diligence processes
During the reporting period, the Company operated solely in Canada. Providing the Company’s employees
with a high standard of health and safety throughout the organization is one of the Company’s core values
and a top priority for the board of directors and senior management. The Company endeavours to engage
with suppliers that uphold similar high standards of health and safety for their employees. The Company
strives to engage with reputable and ethical companies in sourcing all its good and services. To accomplish
this, the Company may complete an internal review process of new suppliers’ public information. When
public information is not available, the Company may purchase third-party reports and enquire directly with
the supplier. In addition, the Company ensures that all medical equipment products sold are approved by
Health Canada.
Based on our review of policies and procedures, for selected vendors, through publicly available information
and third-party reports, the Company did not identify any risks in its supply chain related to forced labour or
child labour and further investigation or termination of supplier relationships was not deemed necessary.
The Company will continue to engage with vendors throughout the relationship with the vendor for future
reporting periods. In addition, the analysis prior to onboarding of new suppliers, includes the due diligence
procedures as outlined above.
Areas of Risk
As a provider of healthcare services in Canada, the Company sources a portion of its goods and services
from third parties located outside of Canada. These suppliers are typically large, multinational companies
that have published procedures and policies related to forced and child labour that align with the
Company’s. The Company noted that the risk of forced and child labour in connection with its business
activities is mitigated through the due diligence procedures outlined in this report. We therefore are of the
belief that the overall risk of forced labour or child labour in connection with our business activities and
supply chain as being low.
Remediation measures
During the year ended September 30, 2023, the Company did not identify forced labour or child labour in
its supply chain. Therefore, remediation measures were not taken. We appreciate that there may be
unintended consequences contributing to a loss of income for vulnerable families resulting from efforts to
prevent and reduce the risk of forced labour and child labour. As the Company has not undertaken any
such remedial measures, its activities have not impacted or otherwise resulted in loss of income for such
families.
Training
Senior management and the board of directors of the Company have been informed of their responsibilities
related to supply chain assessment for forced labour and child labour. In addition, all employees of the
Company have been trained on, have access to and must comply with the Company’s health & safety
protocols and core values.
Assessing effectiveness
The Company has not yet taken steps to assess the effectiveness of the procedures outlined above.
However, going forward the Company is considering establishing appropriate assessments of effectiveness
on an annual basis.
Attestation
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.
Dated this 23rd day of May, 2024.
___________________________
Kirk Hamilton
Chair of the Board of Directors
I have the authority to bind Resolute Health Corporation Limited.
May 23, 2024
Canada enacted its Fighting Against Forced Labour and Child Labour in Supply Chains Act and amended
its Customs Tariff (the “Act” or the “Canadian Modern Slavery Act”) in May 2023. Under the Act, companies
meeting specific criteria, including Resolute Health Corporation Limited (“Resolute”) and its wholly owned
subsidiaries listed below (together referred to as the “Company”) are required to prepare and file an annual
report with the Minister of Public Safety and Emergency Preparedness of Canada. This report describes
the risks within the Company’s supply chain, as well as the risk mitigation measures and diligence
procedures implemented to address such risks.
Steps to prevent and reduce risks of forced labour and child labour
The Company is committed to reducing the risks of forced labour and child labour in its supply chain and
endeavours to continuously improve its diligence, risk assessment and remediation processes. Steps taken
to date to reduce the risks of forced labour and child labour have consisted of conducting an internal
assessment of risks in the organization’s own activities and its supply chains. In addition, the development
and implementation of due diligence policies and processes for identifying, addressing and prohibiting the
use of forced labour and child labour in the organization’s activities and supply chains. These measures
are described in further detail below.
Structure, activities and supply chains
This joint report is prepared by Resolute, and on behalf of the following entities, all of which are wholly
owned subsidiaries of Resolute, for the reporting period from October 1, 2022 to September 30, 2023:
- The Snore Shop Atlantic Inc.;
- Advacare Inc.;
- Sleep Management Group Limited;
- Complete Respiratory Care Inc.;
- Coastal Sleep Homecare Services Inc.;
- Oxylife Respiratory Services Ltd.;
- Island CPAP Services and Supplies Ltd.
- Archer Respiratory Care Inc.; and
- Clinical Sleep Solutions Inc.
The Company operates sleep apnea clinics across Canada, with the corporate head office located in
Bedford, Nova Scotia.
This report outlines the Company’s business activities in Canada with respect to the sale of goods and
services. During the reporting period, the Company only operated in Canada and did not produce or
manufacture goods. The Company may from time to time import goods which would be considered to be
very minor dealings.
The Company sells goods and services directly to its patients through its websites across Canada and clinic
operations located in Nova Scotia, New Brunswick, Prince Edward Island, Quebec, Ontario and British
Columbia.
The goods sold by the Company are purchased primarily from companies in Canada, the United States
and New Zealand. The Company is very rarely the importer of record for purposes of Customs Canada.
The categories and range of suppliers is not broad as the Company operates in the specific market of sleep
apnea treatment with the majority of the goods sold being medical equipment which is approved by Health
Canada prior to the Company’s sale to consumers. The Company typically stocks inventory at the clinic
locations across Canada, and may use third-party warehousing locations. It is rare that equipment is
custom-ordered and shipped directly to a patient.
In addition to goods sold, the Company also sources services through its supply chain from third parties for
items such as software, professional services, advertising, rented clinic space and communications.
Due diligence in relation to forced labour and child labour
During the reporting period, the Company performed an assessment of its suppliers based on spend and
reviewed the policies and procedures associated with forced labour and child labour on its top suppliers
from a volume perspective of goods and services, representing over 50% of it’s annual total spend and over
90% of it’s cost of goods sold in Canada.
This assessment included a review of the suppliers’ policies and procedures as it relates to such items as
supply chain management, code of conduct and child labour. In addition, the Company from time to time
conducts due diligence on its major vendors in the context of forced labour, child labour and modern slavery
by reviewing publicly available documents and purchasing published reports by third party agencies that
provide commercial data and inights to assist in identifying potential risks.
Policies and due diligence processes
During the reporting period, the Company operated solely in Canada. Providing the Company’s employees
with a high standard of health and safety throughout the organization is one of the Company’s core values
and a top priority for the board of directors and senior management. The Company endeavours to engage
with suppliers that uphold similar high standards of health and safety for their employees. The Company
strives to engage with reputable and ethical companies in sourcing all its good and services. To accomplish
this, the Company may complete an internal review process of new suppliers’ public information. When
public information is not available, the Company may purchase third-party reports and enquire directly with
the supplier. In addition, the Company ensures that all medical equipment products sold are approved by
Health Canada.
Based on our review of policies and procedures, for selected vendors, through publicly available information
and third-party reports, the Company did not identify any risks in its supply chain related to forced labour or
child labour and further investigation or termination of supplier relationships was not deemed necessary.
The Company will continue to engage with vendors throughout the relationship with the vendor for future
reporting periods. In addition, the analysis prior to onboarding of new suppliers, includes the due diligence
procedures as outlined above.
Areas of Risk
As a provider of healthcare services in Canada, the Company sources a portion of its goods and services
from third parties located outside of Canada. These suppliers are typically large, multinational companies
that have published procedures and policies related to forced and child labour that align with the
Company’s. The Company noted that the risk of forced and child labour in connection with its business
activities is mitigated through the due diligence procedures outlined in this report. We therefore are of the
belief that the overall risk of forced labour or child labour in connection with our business activities and
supply chain as being low.
Remediation measures
During the year ended September 30, 2023, the Company did not identify forced labour or child labour in
its supply chain. Therefore, remediation measures were not taken. We appreciate that there may be
unintended consequences contributing to a loss of income for vulnerable families resulting from efforts to
prevent and reduce the risk of forced labour and child labour. As the Company has not undertaken any
such remedial measures, its activities have not impacted or otherwise resulted in loss of income for such
families.
Training
Senior management and the board of directors of the Company have been informed of their responsibilities
related to supply chain assessment for forced labour and child labour. In addition, all employees of the
Company have been trained on, have access to and must comply with the Company’s health & safety
protocols and core values.
Assessing effectiveness
The Company has not yet taken steps to assess the effectiveness of the procedures outlined above.
However, going forward the Company is considering establishing appropriate assessments of effectiveness
on an annual basis.
Attestation
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.
Dated this 23rd day of May, 2024.
___________________________
Kirk Hamilton
Chair of the Board of Directors
I have the authority to bind Resolute Health Corporation Limited.