Bill S-211 Annual Report & Attestation

ANNUAL REPORT

Purpose

This annual report for the 2025 financial reporting year, has been created by Springwall Sleep Products Inc. (“Springwall” “our” or “we”) for the sole purpose of meeting its obligations and reporting requirements for entities pursuant to the Fighting Against Forced Labour and Child Labour in Supply Chains Act, SC 2023, c 9 (the “Act”). The report outlines the approach and initiatives taken by Springwall to identify and address the risks of forced labour and child labour in its business operations and supply chains in the 2025 financial reporting year.

Commitment  

Springwall recognizes that different cultural, legal, and ethical systems exist in countries in which it purchases merchandise and raw materials and is committed to preventing and reducing the risk that forced labour or child labour is used at any step in the production and importing of goods into Canada.

A- Its structure, activities and supply chains

Springwall is a multi-generational family owned and operated business that has been manufacturing in the bedding industry for over 75 years. Operations began with a single facility in New Brunswick, Canada, and have since expanded to include production facilities in Ontario and Alberta. The company maintains their head office in New Brunswick. Springwall sells exclusively in Canada.

Springwall is incorporated in the Province of New Brunswick. There are approximately 200 employees in Canada only.

Material used in the manufacturing process is sourced in Canada, the United States, China and Taiwan.

B- Its policies and due diligence processes in relation to forced labour and child labour

To prevent and reduce the risk that forced labour or child labour is used at any step of the production of goods in Canada or imported into Canada, Springwall is supported and bound by internal policies and procedures. These policies and procedures include:

1. Two (2) collective agreements, both of which contain provisions governing hours of work. These provisions mandate reasonable working hours and are aligned with applicable labour laws and regulations, ensuring compliance with industry standards and promoting fair working conditions for all employees.
2. A New Hire Employee Application Form that requires candidates to provide their date of birth. This helps ensure compliance with applicable employment standards and prevents the hiring of individuals who do not meet the minimum legal working age.
3. A Supplier Code of Conduct, updated in 2025, which sets forth Springwall’s fundamental ethical and business conduct requirements for its Suppliers. It includes clauses prohibiting suppliers from using forced labour or child labour, requiring all work to be voluntary and workers to meet applicable minimum age requirements.

The Supplier Code of Conduct was implemented in 2025 to significant raw material suppliers.  There will be a further roll out in 2026.

C -The parts of its business and supply chains that carry a risk of forced labour or child labour being used and the steps it has taken to assess and manage that risk

Springwall has started the process of identifying risks, but there are still gaps in its assessments. Springwall is aware that there may be higher risks associated with certain regions, goods, and industries, and intends to explore options for engaging with the risk identification process in subsequent reporting years, should it become applicable.

D- Any measures taken to remediate any forced labour or child labour

To date Springwall has not  received any complaints relating to forced or child labour in its operations or supply chain, and as such has not taken any remediation measures.

E – Any measures taken to remediate the loss of income to the most vulnerable families that results from any measure taken to eliminate the use of forced labour or child labour in its activities and supply chains

To date Springwall has not received any complaints relating to forced labour in its operations or supply chain, and as such has not taken measures to remediate loss of income to families as a result of forced or child labour.

F – The training provided to employees on forced labour and child labour

In the 2025 reporting year, Springwall did not provide training to its employees on forced labour or child labour. Moving forward, Springwall is considering implementing employee and management training on child and forced labour, for those employees who work directly or indirectly with suppliers.

G – How the entity assesses its effectiveness in ensuring that forced labour and child labour are not being used in its business and supply chains

Springwall does not currently have policies and procedures in place to assess its effectiveness in ensuring that forced labour and child labour are not used in its activities and supply chains.

Approval and Attestation

In accordance with the requirements of the Act, and in particular section 11(4)(a) thereof, I attest that I have reviewed the information contained in the report for the entity 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.

 

IN WITNESS WHEREOF the authorized signing officer(s) of Springwall Sleep Products Inc. have executed this report as of the effective date of the signatures set out below.

Dated in the City of Scoudouc, NB, this 8th day of July, 2026.