Report Pursuant to the Fighting Against Forced Labour and Child Labour in Supply Chains Act, SC 2023, C.9 For the Reporting Year January 1, 2024 to December 31, 2024

This Report is filed on behalf of the following entities: Sterling Ridge Group Inc.

Sterling Ridge Group Inc. is the parent Company of 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 and Global Electric Lighting Inc. Sterling Ridge Group Inc. itself does not carry on any active business. It owns the shares in the listed Companies. All the following Companies are Divisions of Sterling Ridge Group Inc., and each performs work in construction-based or related activities that are not at risk for the use of forced or child labour or use goods resulting from forced labour or child labour. Each company carries on succinct business activities and has a chain of command organizational structure with a common Executive Team overseeing all the Divisions.

Sterling Ridge Infrastructure Inc. (Infrastructure) is an Ontario corporation performing construction related activities including infrastructure, power, and industrial work for the most part in Ontario but always in Canada. Most of its' employees are Unionized. Whether Unionized or not, all employees are either Canadian Citizens or have the right to work in Canada. Sterling Ridge Infrastructure employee numbers range from 150 in the off season to a high of approximately 246 employees.

  • Infrastructure predominantly performs Heavy Civil Infrastructure Projects, sewer and watermain and servicing work, earthworks, excavation, road and bridge construction and rehabilitation. All pipe comes from Quebec where it is manufactured. Labour/Operators are Unionized.

  • Power focusses on large projects such as projects for electricity transmission and distribution services providers. For these projects, it creates the duct banks using Labour which is Unionized, and Canadian made material or material supplied by the Owners. Operators are also Unionized.

  • Industrial work focusses on retooling of Plants/Factories or implementing communication lines. The workforce is Unionized, and predominantly Electricians. Some unionized labourers work on Industrial projects. In most instances products are supplied for installation. Where we are required to source, our major suppliers who are all Ontario based.

Additionally, all Suppliers are required to follow our Supplier Code of Conduct which include provisions to protect against forced and child labour.


Sterling Ridge Architectural Systems Inc. (Architectural Systems) is a corporation incorporated under the laws of Ontario. All employees are Canadian citizens or have the right to work in Canada. Work is carried on in Ontario.

Architectural Systems specializes in building envelope systems, manufactures and installs Glazing Systems, Aluminum Composite Wall Panels, Prefinished Metal Siding and Composite Wall Cladding. Major suppliers of inputs are all from Ontario. Architectural Systems averaged 18 employees. Suppliers are required to follow our Supplier Code of Conduct which includes provision against forced and child labour.

Sterling Ridge General Contracting Inc. is a General Contractor which generally oversees subcontractors performing ICI work, Lump Sum Bid, Time and Material and Construction Management Contracts in Ontario and predominantly in Essex County. All employees working for General Contracting are Canadian or have the right to work in Canada. All subcontractors are vetted and are obligated to follow Sterling Ridge Group Inc. Policies and Procedures which include the Supplier's Code of Conduct. Many of its workers are Unionized. General Contracting averaged 27 employees.

Sterling Ridge Utilities Inc. is an Ontario Company that participates in water and sewer infrastructure, dry utilities, open excavation, directional drilling pipe installation, and underground utilities surveying. It carries on business in Ontario. Pipe comes from Quebec and is manufactured in Quebec. Equipment is purchased form Ontario providers and is North American made. Most employees are Unionized. All other employees are Canadian or are authorized to work in Canada. Sterling Ridge Utilities averaged 25 employees.

Erie Sand and Gravel Limited is an Ontario corporation that mines aggregates such as sand, clear Granular and Round Aggregates, performs Extraction, and supplies aggregate. Erie owns and/or controls all properties in Essex County with Granular B sand reserves. The employees are Canadian or eligible to work in Canada. Equipment is purchased from Ontario dealers. Employee numbers averaged 49.

Smith Contracting Inc. is an Ontario company that claims and recycles aggregate material. The aggregate material comes form locations in Essex County, Ontario. The Equipment is purchased/Leased from large Ontario dealers. The employees are Operating Engineers and members of the relevant Union. Smith sells to Companies in and around Essex County. Smith Contracting averaged 5 employees.

Sterling Ridge Logistics Inc. is an Ontario company that provides trucking and logistic services for aggregate transportation, heavy equipment transportation, and General Third-Party Trucking Services, for the most part in and around Essex County but always in Ontario. Equipment is purchased/leased from Ontario Dealers. Aggregate trucked is mined from Erie Sand and Gravel. Employees are Canadian Citizens or eligible to work in Canada. Sterling Ridge Logistics averages 27 Drivers.

Global Electric and Lighting Inc. is an Ontario Corporation carrying on electrical works and maintenance in the GTA. Its employees are unionized. Equipment/parts come from Ontario providers. Global electric averaged 3 employees. The business ceased operating in or around October 2024.

Policies, Procedures and Due Diligence

We have a Policy on Forced and Child Labour, and the Supplier Code of Conduct is included in our Purchase Orders. We also use a Supplier Declaration Form in circumstances where we are unfamiliar with the Supplier.

Given that our work is in Canada, that most of our employees are Unionized, and products purchased and used are Canadian made or purchased from large Canadian businesses who themselves must ward against supply chains which carry a risk of child/forced labour there is little risk that parts of our business and supply chains carry a risk of forced labour or child labour. The businesses we engage in are also not businesses which traditionally carry an increased risk of child or forced labour such as clothing manufacturing or farming.

We have not identified any forced labour or child labour in our supply chain, so we have not taken any measures to remediate forced labour or child labour.

We have not identified any measure resulting in loss of income to the most vulnerable families, so we have not taken any steps to ameliorate this loss.

Training provided includes training to our Executive Team and to those who oversee the Divisions about what is forced labour and child labour and the procedures we implement to guard against this. Training is approximately one hour in length. Employees receiving/received the training number 17.

We have not undertaken assessment of the effectiveness of these actions in in ensuring that forced labour and child labour are not being used in our business and supply chains.

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 entities listed above. Based on my knowledge, and having exercised reasonable diligence, I attest that the information contained in the Report is true, accurate and complete in al material respects for the purposes of the Act, for the reporting year listed above.

This Report is approved pursuant to subparagraph (4)(b)(i) of the Fighting Against Forced Labour and Child Labour in Supply Chains Act, SC 2023, c.9 this 26th day of May 2025, City of Windsor, County of Essex, Province of Ontario.

Sterling Ridge Group Inc.

 

J. Randall Koop, President

(I have authority to bind the Company)

Blue, cursive signature of J. Randall Koop above a horizontal line.
The logo features a four-part diamond shape with blue and green segments to the left, followed by the text Sterling Ridge Group Inc. in bold, grey uppercase letters.

STRONGERTOGETHER

A vertical black line with a minimalist design, serving as a decorative separator.
A vertical black line with a minimalist design, serving as a decorative separator.

Office Locations

Sterling Ridge Group Inc. 6260 Westar Dr., LaSalle, ON N9J 0B5

Architectural Systems 2751 Temple Dr., Windsor, ON N8W 5E5

415 Talbot St. West, Leamington ON N8H 4E1

Logistics Inc.

T: 519 - 978 - 3111

E: info@sterlingridgegroup.com

Contact