Legal
Privacy Policy
Altas Corporation, its subsidiaries, and affiliates (together, “Altas”, “we”, “us”, or “our”) are committed to protecting the privacy and security of your personal information.
This Privacy Policy (“Privacy Policy”) describes our privacy practices and policies relating to this website (“Website”). Our Privacy Policy has been designed to comply with Canada’s Personal Information Protection and Electronic Documents Act and the other applicable federal and provincial privacy laws relating to the protection of personal information (collectively, "Privacy Legislation").
BY ACCESSING OUR WEBSITE, YOU ACCEPT THE TERMS OF THIS PRIVACY POLICY AND CONSENT TO OUR COLLECTION, USE, DISCLOSURE, AND RETENTION OF YOUR PERSONAL INFORMATION AS DESCRIBED HEREIN.
PERSONAL INFORMATION
In this Privacy Policy, “personal information” means any information about an identifiable individual as defined in applicable Privacy Legislation and may include information such as name, contact information and information on how you access and use our Website.
HOW WE COLLECT PERSONAL INFORMATION
Altas collects and uses personal information only as necessary in connection with the operation of the Website and the operation of its business, including to develop, assess, and improve our Website. We only collect personal information if non-identifying information will not suffice. We minimize our collection and use of personal information to what is needed for these purposes.
- We collect information regarding the areas of the Website you visit, the websites you previously visited, the websites you link to when you leave our Website, and the information and data you request, view, and download from or through the Website. We also collect information you provide through the Website; and
- We may also collect information from you through the use of “cookies” as further described in the Cookies and Similar Technologies section.
USING AND DISCLOSING PERSONAL INFORMATION
- We use the information we collect from you to verify your identity and protect against error and fraud, comply with legal and regulatory requirements, send information to you and for our other legitimate business interests as may, from time to time, be permitted by law. We use and disclose your personal information only for the purposes for which it was collected, except with your consent or as required by law. We do not sell, trade or otherwise transfer your personally identifiable information to any third parties except as permitted hereunder. This does not include our affiliated entities or third party service providers who assist us in operating our Website, conducting our business or servicing you, so long as those parties agree to keep this information confidential. If you provide us with personal data about another person, you represent that you have all necessary authority and/or have obtained all necessary consents from that individual to enable us to collect, use, and disclose that personal data. If you exchange emails with Altas personnel, our systems will retain a record of all email communications.
We may share aggregated demographic information about our users with our business associates, but this information cannot be used to identify any particular individual. We may also disclose your information when we believe it is appropriate to comply with the law, enforce our site policies, protect ours or others’ rights, property or safety, prevent other harm or loss or in connection with an investigation of suspected or actual fraudulent or illegal activity.
We strive to limit collection, use, and disclosure of personal data in the course of transactions. However, where reasonably necessary for business transactions, we may collect personal data from, or disclose personal data to third parties.
Altas may disclose personal information to third parties and to Altas subsidiaries and affiliates, including for:
- Background checks (including criminal and credit checks);
- Proposed or actual purchase, sale, financing, investment or other type of transactions;
- Regulatory, tax or other government authorities and agencies;
- Our affiliates (i.e., companies related to us by common ownership or control) for various purposes permitted by law;
- Other individuals or entities, when we believe that disclosure is necessary to detect, prevent or report suspicious activities, prevent physical harm, financial loss or violations of our agreements and policies; and
- For specific products or services, when you have given your consent.
At times we may use third parties outside of Canada, including in the United States, to perform services for us involving some of your personal information. This may require transfer of information to those third parties. This information is subject to both the laws of Canada and the laws of the third party's jurisdiction, including laws with respect to disclosure of such information, and may be accessible by regulatory authorities in other jurisdictions. When we transfer personal information to third parties, we ensure by contractual means that the transferred personal information is protected to the same degree as if it were in our possession. Altas does not sell or lease personal information to third parties nor does it share personal information with third parties for their marketing purposes.
We may also be required by law to disclose information to government regulatory authorities which collect, use, and disclose such personal information for regulatory purposes, including trading surveillance, audits, investigations, maintenance of regulatory databases and enforcement proceedings.
Altas may be involved in the sale, transfer or reorganization of some or all of its business at some time in the future. As part of that sale, transfer or reorganization, Altas may disclose your personal information to the acquiring organization, however, we will require the acquiring organization to agree to protect the privacy of your personal information in a manner that is consistent with this Privacy Policy.
HOW WE OBTAIN YOUR CONSENT TO THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION
By continuing to do business with us, or accessing the Website, you are consenting to the collection, use, and disclosure of your personal information for the purposes identified in this Privacy Policy. Altas will not, as a condition to your access and use of the Website, require you to consent to the collection, use or disclosure of your personal information beyond that required to fulfill those purposes.
WITHDRAWING YOUR CONSENT
You may withdraw all or part of your consent for us to collect, use or disclose your personal information in accordance with this Privacy Policy at any time upon reasonable notice to Altas in writing, subject to legal or contractual restrictions. The withdrawal of your consent may affect our ability to continue to provide you with the services that you have or would like to receive.
You may also opt out of receiving promotional emails from Altas by following the instructions in those emails. If you opt out, we may still send you non-promotional communications, such as messages about your account or our ongoing business relations.
HOW WE LIMIT DISCLOSURE OF YOUR INFORMATION
Confidentiality of personal information is a fundamental principle of Altas. To that end, we restrict access to personal information about you to those employees and other persons who need to know the information to enable us to provide services to you. Each employee of Altas and any related parties is responsible for ensuring the confidentiality of all personal information they may access. To maintain awareness of our policies and practices in this regard, at least annually we have all of our employees sign a code of conduct containing policies on the protection of personal information and affirming their undertaking to faithfully abide by these practices.
SAFEGUARDS
Altas maintains physical, electronic and procedural controls consistent with regulatory standards to safeguard personal information in its possession. Reasonable measures (such as systems access security controls, safeguards to detect and prevent security system failures, restricted access and employee training) have been implemented to help protect personal information from loss, misuse, unauthorized access or disclosure.
DISCLAIMER TO SECURITY
By accepting the terms of this Privacy Policy, you acknowledge and agree that no data transmission over the Internet is completely secure. We cannot guarantee or warrant the security of any information you provide to us and you transmit such information to us at your own risk.
RETAINING AND DISPOSING OF INFORMATION
Your personal information is maintained on our networks or on the networks of our service providers. Your information may also be stored in a secure off-site storage facility. We retain personal information only as long as it is needed to fulfill the identified purposes or as may be required to comply with applicable laws. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements To satisfy regulatory requirements, certain personal information may be retained for at least seven years (unless there are legal requirements that require its further retention) after which all documentation will be destroyed in a manner commensurate with its sensitivity.
Terms of Use
Thank you for visiting the website of Altas Corporation and its subsidiaries and affiliates (together, “Altas”, “we” or “us”). By accessing this website (“Website”), you acknowledge and agree to accept the following terms of use (“Terms of Use”) pertaining to your access and use of the Website, which constitute a legal agreement between you and Altas.
Your visit to this Website is subject to these Terms of Use and our Privacy Policy. By accessing or using the Website, you agree to these Terms of Use and our Privacy Policy, which may be updated by us at any time. We reserve the right to change the Terms of Use from time to time without notice or liability to you by posting revised Terms of Use on the Website. Your continued use of the Website will constitute acceptance of the revised Terms of Use so please check back regularly to read the most recent version. If you do not agree with the Terms of Use, you must not access or use this Website.
USE OF OUR WEBSITE AND INFORMATION
All information, opinions, advice or other content on the Website (collectively, “Information”) and all trademarks, logos, copyrights and other intellectual property displayed on the Website, is owned by Altas or their respective owners. The Information is protected by Canadian and international copyright law and treaty provisions, trademarks laws, and other proprietary rights laws. Unauthorized use of this Website and/or the Information may violate applicable copyright, trademark or other intellectual property laws or other laws. By visiting this Website you agree to the following with respect to the Information on the Website.
- Altas grants you a limited, revocable, nonexclusive and non-transferable right to view, store, bookmark, and print pages from the Website solely for your personal and non-commercial use only.
- Unless you receive our permission in advance, you may not exploit commercially, reproduce, post, transmit, display, perform, distribute, modify, republish, license or create derivative works of the Information or any part of it, forward it as a mass distribution, post it on another site, or otherwise copy, distribute or modify any portion of the Website. If you want to reproduce any of the Information, please send us a request at contact@altas.com. We may approve or deny any such request in our sole discretion.
- You may download one copy of the Information for your personal, non-commercial viewing only, provided that you do not remove or obscure any copyright or other notices or legends contained in any such Information. You may not alter or modify the Information in your copies.
- You may not use any trademark, service mark or logo of Altas or any third party that appears on the Website without our prior written consent.
- You agree not to engage in “spidering,” “screen scraping,” “database scraping,” harvesting of e-mail addresses or other personal information, or any other automatic or unauthorized means of accessing, logging-in or registering on this Website, or obtaining lists of users or other information from or through this Website including, without limitation, any information residing on any server or database connected to this Website.
- You may not link to this Website nor display this Website as “framed” within another website.
- You may not (and may not encourage or assist others to) violate the intellectual property or contractual rights of others, or attempt to violate the security of this Website or use or gain access to the identities, information or computers of others through this Website.
- You may not obtain or attempt to obtain any materials or information through any means not intentionally made available or provided for through the Website.
- You agree not take any action that imposes an unreasonable load on the Website’s infrastructure. You may not use any device, software or routine to interfere or attempt to interfere with the proper working of this Website or any activity being conducted on this Website.
- You may not delete, decompose, decompile, reverse engineer, disassemble or otherwise deconstruct all or any portion of this Website.
- You may not transmit any virus, worm, time bomb or similar system interference or corruptant through this Website.
- As a condition of your use of the Website, you warrant to Altas that you will not use (and will not encourage or assist others to use) the Website for any purpose that is unlawful or prohibited by these Terms of Use (including any terms incorporated by reference) and any notices.
Altas has the right (but not the obligation) to monitor this Website for any unauthorized or objectionable conduct and to take all appropriate actions in response, without notice to you. In our sole discretion, in addition to any other rights or remedies available to us and without any liability whatsoever, we at any time and without notice or liability to you may terminate or restrict your access to any component of this Website. In the event of such termination or restriction, these Terms of Use shall continue to apply and be binding upon you with respect to your prior use of the Website and of the Information.
Altas may investigate any complaint regarding or suspected violation of these Terms of Use, and may report any activity relating to this Website to regulators, law enforcement officials or other persons or entities that it deems appropriate.
INTERNATIONAL USE
The Website is directed to those individuals and entities located in Canada but may be hosted outside of Canada. It is not directed to any person or entity in any jurisdiction where (by reason of nationality, residence, citizenship or otherwise) the publication or availability of the Website and its Information, including its products and services, are unavailable or otherwise contrary to local laws or regulations or would subject any person or entity, including Altas, to any registration or licensing requirements in that jurisdiction. If this applies to you, you are not authorized to access or use any of the Information on this Website. We make no representation that the Information is appropriate outside of Canada. This Website may describe products, programs and services that are not available or are prohibited in some countries. These descriptions do not imply that we intend to make those products, programs or services available in every country, or that those products, programs and services may be used lawfully in your country. Those who choose to access this Website from other locations do so at their own risk and are responsible for compliance with applicable local laws.
INVESTMENT DISCLAIMERS
This Website is for general informational purposes only. Nothing contained in this Website constitutes investment, legal, accounting, tax or other professional advice. This Website and the Information contained on this Website does not constitute or imply any solicitation, offer or recommendation by Altas to buy or sell any securities, financial instruments, investments or other services, including any securities of any fund or other entity managed or advised, directly or indirectly, by Altas. Dated content speaks only as of the date indicated. Decisions based on information contained on this Website are your sole responsibility. You agree that Altas is not liable for any action you take or decision you make in reliance on any Information. Altas will not treat users of the Website as its partners, clients, customers or investors by virtue of their accessing the Website.
PAST PERFORMANCE IS NOT INDICATIVE OF FUTURE RESULTS. The Website may include information as to past or current circumstances, events, financial results or performance and statements about possible, assumed or expected circumstances, events, financial results or performance that are forward-looking in nature and subject to risks and uncertainties. Altas cautions that no such statement is a guarantee as to future matters and that actual circumstances, events, results and performance will be affected by a number of factors, many of which are beyond the control, and may be materially different from what Altas currently anticipate.
The Website contains forward-looking statements, which reflect our current views with respect to, among other things, the operations and performance of our businesses. You can identify these forward-looking statements by the use of words such as “outlook,” “believe,” “expect,” “potential,” “continue,” “may,” “should,” “seek,” “approximately,” “predict,” “intend,” “will,” “plan,” “estimate,” “anticipate” or the negative version of these words or other comparable words. Forward-looking statements are subject to various risks and uncertainties. Accordingly, there are or will be important factors that could cause actual outcomes or results to differ materially from those indicated in these statements. We undertake no obligation to publicly update or review any forward-looking statement, whether as a result of new information, future developments or otherwise.
Any transactions described on the Website as having been engaged in by Altas are included as representative transactions for illustrative purposes only, and may not be representative of all transactions engaged in by Altas.
LINKED WEBSITES
For your convenience, we may provide links to various other Websites that may be of interest to you and for your convenience only. Altas does not review or monitor any websites linked from or to the Website and is not responsible for the content of any such websites, or any products or services contained on or accessible through such other websites, their terms of use or privacy policies. We do not endorse the content contained in any third party website. We do not make any representation, warranty or condition, express, implied or statutory of any kind regarding any third party website, including without limitation any representation or warranty regarding the legality, accuracy, reliability, quality, completeness, timeliness, non infringement, security, or suitability of any content on a third party website. We do not make any representation or warranty regarding the merchantability and fitness for a particular purpose of any content, goods or services on or made available through any third party websites. Nor do we make any representation, warranty or condition, express, implied or statutory that the operation of any third party website will be uninterrupted, free of error, viruses or any other harmful components. All links are provided for your convenience only and if you choose to access any third party website, you do so entirely at your own risk. You are advised to review the terms of use and privacy policies of any website that you visit. Altas disclaims responsibility for the privacy policies and customer information practices of third-party internet websites linked from the Website.
SECURITY
While we endeavor to protect the security and integrity of the information we may collect from you via the Website, as described in our Privacy Policy, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that any information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers. A third party could view the information you send in transit by electronic means. We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission.
NO WARRANTIES AND LIMITATION OF LIABILITY
TO THE FULLEST EXTENT ALLOWED BY LAW, THE WEBSITE AND ANY INFORMATION, ARE PROVIDED TO YOU ON AN “AS IS,” “AS AVAILABLE” BASIS WITHOUT WARRANTY OF ANY KIND WHETHER EXPRESS, STATUTORY OR IMPLIED, INCLUDING BUT NOT LIMITED TO ANY IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, QUIET ENJOYMENT, SYSTEMS INTEGRATION, ACCURACY, AND NON-INFRINGEMENT, ALL OF WHICH WE EXPRESSLY DISCLAIM. ALTAS, ITS SUBSIDIARIES, AFFILIATES AND THEIR RESPECTIVE OFFICERS, DIRECTORS, MANAGERS, PARTNERS, MEMBERS, SHAREHOLDERS, EMPLOYEES, AFFILIATES AND AGENTS (COLLECTIVELY “RELATED PERSONS”) DO NOT ENDORSE AND MAKE NO WARRANTY AS TO THE ACCURACY, COMPLETENESS, CURRENCY, OR RELIABILITY OF THE WEBSITE AND INFORMATION, AND WE WILL NOT BE LIABLE OR OTHERWISE RESPONSIBLE FOR ANY FAILURE OR DELAY IN UPDATING THE WEBSITE OR ANY INFORMATION. WE HAVE NO DUTY TO UPDATE THE WEBSITE OR ANY INFORMATION. WE MAKE NO REPRESENTATIONS OR WARRANTIES THAT USE OF THE INFORMATION WILL BE UNINTERRUPTED OR ERROR-FREE. YOU ARE RESPONSIBLE FOR ANY RESULTS OR OTHER CONSEQUENCES OF ACCESSING THE WEBSITE AND USING THE INFORMATION, AND FOR TAKING ALL NECESSARY PRECAUTIONS TO ENSURE THAT ANY INFORMATION YOU MAY ACCESS, DOWNLOAD OR OTHERWISE OBTAIN IS FREE OF VIRUSES OR ANY OTHER HARMFUL COMPONENTS.
Your use of the Information is at your own risk. Altas, its subsidiaries, its affiliates and Related Persons shall not be liable to any party for any claims, liabilities, losses, costs, expenses or damages (“Losses”), whether based in contract, tort, negligence, strict liability or otherwise, for any direct, indirect, incidental, punitive, consequential, or special damages arising out of or in any way connected with access to, use of or reliance on the Information (even if we have been advised of the possibility of such damages) or that arise in connection with mistakes or omissions in, or delays in transmission of, information to or from the user, any failure of performance, error, omission, interruption, deletion, defect, delay in operation or transmission or delivery, computer virus, communication line failure, theft or destruction or unauthorized access to, alteration of, or use of records, programs or files, interruptions in telecommunications connections to the Website or viruses whether caused in whole or in part by negligence, acts of God, telecommunications failure, theft or destruction of, or unauthorized access to the Website or the Information. If notwithstanding the foregoing, we should be found liable for any Losses which arise out of or is in any way connected with any of the services or uses of the Website or the Information, our total liability for all damages, losses and causes of action, whether contract, tort, negligence, strict liability or otherwise, shall in no event exceed in the aggregate $100 CAD or the amount paid by you for accessing the Website, if any, whichever is greater.
As consideration for access to the Website, you agree to indemnify and save harmless Altas, its subsidiaries, affiliates and Related Persons from and against any claim, cause of action or demand, including without limitation reasonable legal, accounting and other professional fees, resulting from or related to (a) your breach of any of these Terms of Use (including any terms incorporated by reference); (b) your access to or use of this Website; or (c) your use or reliance on, publication, communication or distribution of anything on or from this Website.
RELATIONSHIP OF THE PARTIES
Neither of us nor any of our respective officers, agents or employees will be held or construed to be partners, joint ventures, fiduciaries, employees or agents of the other as a result of these Terms of Use or your use of the Website.
GOVERNING LAW
These Terms of Use shall be governed in all respects by the laws of the Province of Ontario, Canada, without reference to its choice of law rules. If an applicable law is in conflict with any part of the Terms of Use, the Terms of Use will be deemed modified to conform to the law. The other provisions will not be affected by any such modification.
GENERAL
These Terms of Use, together with those incorporated by reference, constitute the entire agreement between us and you pertaining to your use of the Website and may not be modified except by us as stated above. We may assign these Terms of Use, in whole or in part, at any time. Our failure to insist upon or enforce strict performance of any right or provision of the Terms of Use shall not constitute or be construed as a waiver of any right or provision. Certain portions of these Terms of Use may be superseded by terms of other contracts between you and us. If any part of these Terms of Use is unlawful, void or unenforceable, then that part is severable and will not affect the validity and enforceability of the remaining disclaimers, terms and conditions. We reserve the right at any time to change or discontinue any feature of the Website or begin charging for access to the Website.
QUESTIONS
If you have any questions, complaints, or claims, relating to the Website, please contact us at contact@altas.com. We will do our best to address your concerns.
Modern Slavery Statement
Statement of the Prevention of Modern Slavery and Human Trafficking for the financial year ended December 31, 2023
Introduction
This statement is prepared in accordance with Bill S-211, Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “Act”), which came into effect on January 1, 2024 on behalf of Altas Partners (“Altas” or the “Firm”). This statement addresses (i) Altas’ structure; (ii) assessment of forced labour and child labour risks in existing operations; and (iii) remediation measures put in place, if applicable.
Altas’ Structure
Altas is a North American private equity firm focused on selectively acquiring significant interests in high-quality businesses with meaningful growth potential. The Firm was founded in 2012 and manages approximately US $10 billion on behalf of leading institutional and family office investors from around the world. The Firm operates through Altas Corporation, a corporation formed in the province of Ontario, and its subsidiaries. The Firm employs 66 individuals from its offices in Toronto and New York.
The Firm manages investments in 8 portfolio companies in financial, business, and healthcare services. All portfolio companies are headquartered in the United States and collectively employ approximately 34,000 employees, predominantly in the United States, with select portfolio companies having a presence in Canada.
The Firm qualifies as an “entity” under the Act as it has met the asset and revenue-related thresholds for its two most recent financial years. This statement addresses reporting requirements solely for the Firm and not its portfolio companies.
In addition, the Firm has identified one portfolio company that meets the criteria of (i) producing, selling, or distributing goods in Canada or elsewhere, or (ii) importing into Canada goods produced outside of Canada, where there is a reporting requirement under the Act. This portfolio company, DuBois Chemicals, Inc. (“DuBois”), is submitting its own report.
Assessment of Forced Labour and Child Labour Risk
The Firm's Executive Committee is responsible for overall governance at Altas. This includes setting the strategy, designing the organization, fostering culture and implementing policies to ensure that the Firm upholds the highest standards of legal and ethical conduct. The Firm’s policies are reviewed annually, and appropriate updates are made as required.
Assessment of Risk Related to Employees
The Firm employs professionals and administrative staff who carry out the day-to-day responsibilities of stewarding our investors’ capital. All the staff are employed and based in our offices in Toronto and/or New York.
The Firm offers a comprehensive compensation and benefits package for all employees and regularly benchmarks its compensation and benefits practices against peer firms in North America. Employee compensation and benefits represent the largest expenditure for the Firm.
In addition to a competitive compensation package, the Firm has implemented comprehensive policies regarding the code of ethics, diversity and inclusion, respect in the workplace, conflict of interest, discrimination, occupational health and safety and protecting whistleblowers. The policies are contained in the Firm’s Compliance Manual and Employee Handbook, and regular training is provided to remind employees of their obligations under the Compliance Manual. Employees are encouraged to report any violations against the policies to the Head of Talent, Chief Operating Officer or CEO, as appropriate.
The Firm also conducts regular employee surveys to help identify any issues or concerns that employees may have.
As a result of the measures the Firm has taken, we assess that there are no risks related to forced labour or child labour regarding the Firm’s employees.
Assessment of Risk Related to Suppliers
As an asset manager, the Firm’s supply chain consists predominantly of purchasing North American-based professional services (such as lawyers, accountants, and other consultants) and local business supplies (such as IT service providers, office supplies and equipment, travel-related services, and office maintenance services).
Given the nature of the services the Firm purchases and the location of service providers, we view the risk related to forced labour or child labour to be low.
Assessment of Risk Related to Portfolio Companies
The Firm is committed to being a responsible owner and steward of businesses it acquires on behalf of its partners. This philosophy is integrated into the processes we follow from (i) the identification of industries and businesses that we target; (ii) the diligence process we undertake to understand the opportunities and risks of any business; and (iii) the engaged approach to ownership that includes promotion of sustainable and appropriate environmental, social, and governance practices.
As a signatory to the United Nations-supported Principles of Responsible Investment and the Institutional Limited Partners Association Diversity in Action, the Firm uses its control or influence through governance rights to promote responsible investment practices through (i) the adherence to high standards of conduct and compliance with applicable and relevant laws and regulations in the countries in which the portfolio company operates; (ii) the implementation of defined and documented corporate governance structures with clear responsibilities and procedures, appropriate internal control mechanisms, and risk management policies; (iii) the promotion of policies to build sustainable supply chains in material areas such as modern slavery, business continuity, and environmental footprint and employee safety; and (iv) the respecting of employee’s rights to safe working conditions.
Altas has one portfolio investment, DuBois, that is preparing its own report as it meets the reporting criteria under the Act.
DuBois is a leading provider of mission-critical specialty chemicals solutions to over 20,000 customers. The company is headquartered in Sharonville, Ohio, and employs 1,400 individuals, of which approximately 13% are in Canada. The majority, 65%, are based in the US, with Europe, Asia, Australia, and Mexico employing 9%, 6%, 4%, and 3%, respectively.
In reviewing its supply chain, DuBois has completed a number of steps to prevent and reduce the risk that forced labour or child labour is used at any step in the production of goods in Canada or elsewhere by the company or of goods imported into Canada including: (i) mapping activities; (ii) mapping supply chains; (iii) conducting internal assessment of risks of forced labour and/or child labour in the organization’s activities and supply chains; (iv) developing and implementing an action plan for addressing forced labour and/or child labour; (v) gathering information on worker recruitment and maintaining internal controls to ensure that all workers are recruited voluntarily; (vi) developing and implementing due diligence policies and processes for identifying, addressing and prohibiting the use of forced labour and/or child labour in the organization’s activities and supply chains; (vii) requiring suppliers to have in place policies and procedures for identifying and prohibiting the use of forced labour and/or child labour in activities and supply chains; (viii) developing and maintaining anti-forced labour and/or child labour contractual clauses; (ix) monitoring suppliers; (x) enacting measures to provide for, or corporate in, remediation of forced labour and/or child labour; (xi) developing and implementing grievance mechanisms; and (xii) developing and implementing training and awareness materials on forced labour and/or child labour.
The Firm is not aware of any forced labour, child labour or human trafficking incidents in our portfolio companies and, in particular, at DuBois.
Remediation Measures
As the Firm is not aware of any child or forced labour in its own supply chain or that of its portfolio company that is required to report under the Act, no steps were taken to eliminate the use of forced or child labour. As a result, the Firm has not identified any loss of income to the most vulnerable families resulting from any measure taken to eliminate the use of forced or child labour.
The Firm will continue to monitor its supply chain and that of its portfolio investments through diligence steps embedded into the investment review process.
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 this 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.
I have the authority to bind Altas Corporation.
Paul Nicoletti
Partner, Chief Operating Officer
Altas Corporation
