Regarding Modern Slavery

1. Structure, Activities and Supply Chain

Structure

Homes Alive Pets is an Alberta-based, 100% Canadian-owned company specializing in pet food, treats, accessories, and expert advice for pet owners across Western Canada. The Company was incorporated in 2007 and operates as Homes Alive Ltd.

As of the end of the reporting period, the Company operated 9 retail stores across Alberta, British Columbia, and Manitoba — 8 large-format stores and 1 small-format store — together with an e-commerce platform serving customers throughout Canada. The Company employs over 200 individuals.

Activities

The Company’s principal activity is the retail sale of pet products through its physical stores and online channel. The majority of the goods the Company sells are produced by third-party manufacturers and brand owners; the Company does not itself operate manufacturing facilities.

In addition, the Company purchases finished goods that are sold under its own private-label brands, Eldon’s and Value Pack. These private-label products are pet treats and chews. For these goods, the Company acts as the brand owner: it does not manufacture the products itself, but contracts for their production and places its own brand on the finished goods. The Company sources these private-label goods through two channels — through an agent or distributor, and as a direct importer from the manufacturer.

The Company’s reporting obligations under the Act arise from its activity of importing into Canada, and distributing and selling in Canada, goods produced outside Canada — including both third-party branded goods and the Company’s private-label goods.

Supply Chain

The Company’s supply chain is complex, reflecting the wide variety of products offered, the international nature of sourcing, and the involvement of suppliers at multiple tiers. The majority of the Company’s primary (Tier 1) suppliers are located in Canada and the United States. The Company also sources from suppliers in Europe, South America, and Asia. The Company’s direct relationships are predominantly with brand owners, distributors, and importers rather than with the manufacturing facilities and raw-material producers that sit further down the chain.

For its private-label treats and chews (Eldon’s and Value Pack), some finished goods are manufactured overseas, including in Asia, Europe, and South America. Because the Company is the brand owner for these goods, responsibility for understanding the underlying manufacturing and raw-material supply chain rests more directly with the Company than is the case for third-party branded products, and the Company treats these private-label supply chains as a priority area for due diligence.

2.Policies and Due Diligence Processes

Policies

During the reporting period, the Company advanced from considering a dedicated supplier policy to formalizing one. The Company finalized and adopted a Supplier Code of Conduct (the “Supplier Code”), which sets out the minimum standards and expectations for suppliers regarding labour practices and ethical conduct, interpreted consistently with the Act. This represents a key step forward from the prior reporting period, in which such a policy was only under consideration.

The Supplier Code applies to all suppliers, distributors, manufacturers, and agents that provide goods or services to the Company, as well as to any subcontractors or facilities used by those suppliers. Among other things, the Supplier Code requires suppliers to:

• comply with all applicable laws and regulations, including those relating to employment, labour standards, human rights, and occupational health and safety;
• refrain from using any form of forced labour, including prison labour (except where permitted by law and internationally recognized standards), bonded or debt labour, involuntary labour, human trafficking, the retention of identity documents, and unreasonable restrictions on freedom of movement;
• refrain from employing children below the minimum legal working age, or below 15 years of age, whichever is higher, and ensure any legally employed young workers are not engaged in work that interferes with education or is hazardous;
• provide a safe and healthy working environment and lawful wages, benefits, and working hours;
• maintain records demonstrating compliance, cooperate with reasonable requests for information, and promptly notify the Company of any forced labour or child labour identified in their operations or supply chain; and
• ensure workers can raise concerns without fear of retaliation.

The Supplier Code includes a supplier Acknowledgement, by which suppliers confirm they have received, read, and understood the Supplier Code, and that they do not knowingly use forced labour or child labour in their operations or in the production of goods supplied to the Company. The Company is incorporating the Acknowledgement into its supplier onboarding and renewal processes.

The Company also maintains an internal code of conduct requiring employees to comply with applicable laws and to act with integrity.

Due Diligence Processes

The Company continued to work with its partner, Group Legault Ltd. (Quebec), to strengthen its due diligence approach. During the reporting period, work continued on a supplier survey designed to gather information on supplier working conditions, supply-chain auditing practices, and responses to non-compliance. The data collected through the survey is intended to be aggregated to assign each supplier a performance score, enabling the Company to better understand its supply chain and to identify and prioritize risk among lower-tier suppliers.

The Company’s due diligence remains focused on embedding its labour-standards expectations into supplier relationships through the Supplier Code and Acknowledgement, and on building the information base needed to assess supplier practices on a risk basis over time.

3. Risks of Forced Labour and Child Labour, and Steps Taken to Assess and Manage Them

The Company recognizes that visibility beyond its first tier of suppliers is limited, and that the greatest risk of forced labour and child labour lies with lower-tier suppliers (Tier 3 and beyond), where complete traceability, monitoring, and control are most difficult to achieve. Risk varies by sourcing geography: some suppliers operate in jurisdictions with strong labour regulation and enforcement, while others operate where regulatory frameworks and enforcement are weaker, increasing risk.

The Company has identified its private-label treats and chews (Eldon’s and Value Pack) as an area warranting particular attention. Some of these finished goods are manufactured overseas, including in regions with weaker labour-regulation enforcement, and the Company’s role as brand owner means it carries greater responsibility for the conditions under which these goods are produced. The Company sources these private-label goods through two channels: through an agent or distributor, and as a direct importer from the manufacturer. Where goods are sourced through an agent or distributor rather than imported directly from the manufacturer, the additional intermediary can further reduce visibility into manufacturing conditions. During the reporting period, the Company took the following steps to assess and manage these risks:

• adopted the Supplier Code, establishing clear, enforceable expectations on forced labour and child labour across all tiers of the supply chain, applicable to both third-party and private-label suppliers;
• prioritized obtaining the Supplier Code Acknowledgement from suppliers of its private-label goods as it integrates the Code into onboarding and renewal;
• continued development of the supplier survey and scoring methodology with Group Legault Ltd. to support risk-based identification of higher-risk suppliers;
• reserved the contractual right, directly or through a third party, to conduct reasonable, risk-based and proportionate assessments of supplier compliance, including document reviews and questionnaires; and
• continued to prioritize Canadian-made products and responsible procurement, which reduces exposure to higher-risk sourcing geographies.

The Company has not identified any specific incident of forced labour or child labour in its supply chain during the reporting period; the risks described above are assessed risks rather than identified instances.

4. Remediation Measures

As of the date of this report, the Company has not identified any instances of forced labour or child labour in its activities or supply chains. Consequently, the Company has not been required to take any remediation measures during the reporting period.

Where non-compliance with the Supplier Code is identified in the future, the Company’s framework provides for requesting corrective actions, working with the supplier to address the root cause and prevent recurrence within agreed timelines, and, where appropriate, suspending or terminating the business relationship.

5. Remediation of Loss of Income to Vulnerable Families

Because the Company has not identified any instances of forced labour or child labour, and has therefore not taken any measures to eliminate such labour, no loss of income to vulnerable families has resulted from any such measures. Accordingly, the Company has not been required to take any measures to remediate the loss of income to vulnerable families during the reporting period.

6. Training Provided to Employees

The Company’s employees are required to adhere to an internal code of conduct that demands ethical behaviour, integrity, and compliance with applicable laws. With the adoption of the Supplier Code during the reporting period, the Company is integrating awareness of forced labour and child labour risks, and of the Supplier Code requirements, into the work of staff involved in procurement and supplier management, including team members at its partner Group Legault Ltd. The Company intends to continue developing and formalizing targeted training for relevant employees in future reporting periods as its due diligence program matures.

7. Assessing Effectivenes

The Company has implemented several measures to prevent and mitigate the risks of forced labour and child labour within its Tier 1 supply chain and is committed to strengthening these measures wherever needs or weaknesses are identified. During the reporting period, the principal measure of progress was the finalization and adoption of the Supplier Code and Acknowledgement, which gives the Company a concrete instrument against which supplier commitments can be obtained and assessed.

Once fully implemented, the supplier survey and scoring methodology will provide the Company with quantitative information against which it can measure supplier practices and track improvement over time. The Company will evaluate its policies and processes, as they relate to this report, on an annual basis.

See Report

Last Revised May 29th, 2026