REPORT PURSUANT TO THE FIGHTING AGAINST FORCED LABOUR AND CHILD LABOUR IN SUPPLY CHAINS ACT

Reporting Year: January 1, 2025 to December 31, 2025

This report is made pursuant to section 11 of the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the "Act") and constitutes a joint report for the following entities:

•            Sterling Ridge Group Inc.

•            Sterling Ridge Infrastructure Inc.

•            Sterling Ridge General Contracting Inc.

•            Sterling Ridge Architectural Systems Inc.

•            Smith Contracting Inc.

•            Sterling Ridge Logistics Inc.

•            Erie Sand and Gravel Limited

•            Sterling Ridge Utilities Inc.

Structure, Activities and Supply Chains

Corporate Structure

Sterling Ridge Group Inc. is the parent company of the reporting entities listed above. Sterling Ridge Group Inc. itself does not carry on active operations but owns the shares of the subsidiary entities identified in this report. The reporting entities operate under common executive leadership and maintain centralized oversight regarding governance, procurement policies, labour practices, and compliance procedures.

The entities primarily conduct construction, infrastructure, aggregate, utility, transportation, and electrical services operations within Ontario, Canada. The reporting entities generally procure materials, equipment, and services from Canadian suppliers, with a significant proportion sourced from Ontario and Quebec.

Sterling Ridge Infrastructure Inc.

Sterling Ridge Infrastructure Inc. is an Ontario corporation engaged in construction-related activities including heavy civil infrastructure, power, and industrial work primarily within Ontario and exclusively within Canada.

Its activities include:

•            sewer and watermain installation;

•            earthworks and excavation;

•            road and bridge construction and rehabilitation;

•            electrical transmission and distribution infrastructure;

•            industrial plant and communications infrastructure work.

Most employees are unionized. All employees are either Canadian citizens or legally authorized to work in Canada. Employee levels ranged from approximately 150 to 246 employees during the reporting period.

Materials used in operations, including pipe and related products, are primarily manufactured in Quebec or sourced through Canadian suppliers. Equipment and materials are generally obtained from established North American suppliers.

Sterling Ridge Architectural Systems Inc.

Sterling Ridge Architectural Systems Inc. specialized in building envelope systems including glazing systems, aluminum composite wall panels, prefinished metal siding, and composite wall cladding.

Operations were conducted in Ontario, Canada. Major suppliers were located in Ontario. The company averaged approximately 18 employees during the reporting year. All employees were Canadian citizens or legally authorized to work in Canada.

Sterling Ridge Architectural Systems Inc. ceased operations effective December 31, 2025.

Sterling Ridge General Contracting Inc.

Sterling Ridge General Contracting Inc. acts as a general contractor overseeing industrial, commercial and institutional construction projects in Ontario, primarily within Essex County.

The company engages subcontractors for various construction activities and performs work under lump sum, time and material, and construction management contracts.

All employees are Canadian citizens or legally authorized to work in Canada. Many workers are unionized. The company averaged approximately 27 employees during the reporting year.

Sterling Ridge Utilities Inc.

Sterling Ridge Utilities Inc. performs water and sewer infrastructure work, dry utility installation, directional drilling, underground utility surveying, and related excavation services in Ontario.

Pipe and related materials are sourced primarily from Quebec manufacturers. Equipment is purchased from Ontario-based dealers and consists primarily of North American manufactured equipment.

Most employees are unionized. All remaining employees are legally authorized to work in Canada. The company averaged approximately 25 employees during the reporting year.

Erie Sand and Gravel Limited

Erie Sand and Gravel Limited is an Ontario corporation engaged in the extraction, processing, and supply of aggregate materials including sand and granular products.

Operations are located within Essex County, Ontario. Equipment is purchased through Ontario-based dealers and suppliers.

Employees are Canadian citizens or legally authorized to work in Canada. The company averaged approximately 49 employees during the reporting year.

Smith Contracting Inc.

Smith Contracting Inc. processes and recycles aggregate materials sourced from locations within Essex County, Ontario.

Equipment is purchased or leased through Ontario-based dealers. Employees are members of applicable operating engineer unions.

The company averaged approximately 5 employees during the reporting year.

Sterling Ridge Logistics Inc.

Sterling Ridge Logistics Inc. provides aggregate transportation, heavy equipment transportation, and third-party trucking services primarily within Essex County and Ontario.

Equipment is purchased or leased through Ontario-based suppliers and dealers. Aggregate materials transported are sourced primarily from Erie Sand and Gravel Limited.

Employees are Canadian citizens or legally authorized to work in Canada. The company averaged approximately 27 drivers during the reporting year.

Policies and Due Diligence Processes

The reporting entities maintain policies and procedures intended to prevent and reduce the risk of forced labour and child labour within their business activities and supply chains.

These measures include:

•            a Forced and Child Labour Policy;

•            a Supplier Code of Conduct incorporated into purchase orders and supplier engagement processes;

•            supplier declaration forms for new or unfamiliar suppliers;

•            procurement practices favouring established Canadian and North American suppliers;

•            verification that employees are legally entitled to work in Canada;

•            oversight by executive management and operational leadership.

Suppliers and subcontractors are expected to comply with applicable labour and employment laws and with the Supplier Code of Conduct, which prohibits the use of forced labour and child labour.

Risk Assessment and Risk Management

The reporting entities have assessed the nature of their operations and supply chains to identify areas presenting potential risks of forced labour or child labour.

Based on the assessment conducted during the reporting year, the entities consider the overall risk to be low for the following reasons:

•            operations are conducted exclusively within Canada;

•            the workforce is predominantly unionized;

•            employees are Canadian citizens or legally authorized to work in Canada;

•            materials and equipment are sourced primarily from Canadian or North American suppliers;

•            the entities operate in industries not generally associated with elevated risks of forced or child labour;

•            suppliers and subcontractors are subject to contractual obligations and procurement controls.

The entities recognize that certain globally sourced construction materials and manufactured products may present indirect supply-chain risks. To address this, the entities continue to prioritize sourcing from reputable suppliers and require adherence to the Supplier Code of Conduct.

No instances of forced labour or child labour were identified during the reporting period.

Remediation Measures

The reporting entities did not identify any instances of forced labour or child labour in their activities or supply chains during the reporting period.

Accordingly, no remediation measures were required or implemented.

Measures to Remediate Loss of Income

The reporting entities did not identify any loss of income to vulnerable families resulting from measures taken to eliminate forced labour or child labour in their activities or supply chains.

Accordingly, no remediation measures relating to loss of income were required during the reporting period.

Training

Training regarding forced labour and child labour was provided to members of the executive team and individuals responsible for oversight of the reporting entities and their operations.

The training included:

•            identification of forced labour and child labour risks;

•            overview of obligations under the Act;

•            supplier compliance expectations;

•            reporting and escalation procedures.

Approximately 12 employees received training during the reporting year. Training sessions were approximately one hour in duration.

Assessing Effectiveness

The reporting entities assess the effectiveness of their measures through:

•            executive oversight of procurement and supplier practices;

•            review of supplier onboarding procedures;

•            monitoring compliance with the Supplier Code of Conduct;

•            ongoing evaluation of procurement sources and subcontractor relationships;

•            periodic review of internal policies and procedures.

During the reporting year, no complaints, reports, or identified incidents relating to forced labour or child labour were received.

The reporting entities intend to continue reviewing and enhancing their due diligence and risk assessment processes as part of ongoing compliance efforts.

Approval and Attestation

This report was approved pursuant to subparagraph 11(4)(b)(i) of the Fighting Against Forced Labour and Child Labour in Supply Chains Act on the 26th day of May, 2026, in the Town of LaSalle, County of Essex, Province of Ontario.

In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in this report for the entities listed above. Based on my knowledge, and having exercised reasonable diligence, I attest that the information contained in this report is true, accurate and complete in all material respects for the purposes of the Act for the reporting year identified above.

Claudio Martini                         
Chief Executive Officer
I have authority to bind the Corporation