Bill S-211
Annual Report for Financial Year ending July 31, 2024
Fighting Against Forced Labour and Child Labour in Supply Chains Act
Introduction
Alpine Aerotech Limited Partnership (the “Limited Partnership”) prepares this report in compliance with the Fighting Against Forced Labour and Child Labour in Supply Chains Act, S.C. 2023, c.9 (the “Act”) on behalf of itself and Alpine Aerotech GP Ltd., in its capacity as general partner (the “General Partnership”). For the purposes of this joint report (the “Joint Report”), the Limited Partnership and the General Partnership may collectively be referred to as “Alpine Aerotech”.
A. STRUCTURE, ACTIVITIES AND SUPPLY CHAINS
The Limited Partnership is a British Columbia limited partnership. Our general partner is the General Partnership. Our operations are in Kelowna, British Columbia. We have at least $20 million in assets, import goods into Canada that are produced outside of Canada and have less than 250 employees.
The Limited Partnership is structured in different teams, including the executive team, the management team, the sales and procurement team, the planning department and other administrative teams.
The business numbers are as follows:
- Limited Partnership: 80900 8733 BC 0001
- General Partnership: 80654 7642 RC 0001
We are a Transport Canada and Bell helicopter approved customer service facility, performing, among other things, maintenance, repair and overhaul services of and to helicopters, periodic inspections of helicopters and rewiring and refurbishing helicopters. We operate in the transport equipment manufacturing industry, which includes repairing and maintaining helicopters.
The Limited Partnership imports aircraft parts into Canada from manufacturers and distributors in the United States with a de minimis amount from other countries. Our suppliers are primarily aircraft OEMs (original equipment manufacturers) and their licensed/approved suppliers holding applicable OEM approvals and government aviation regulatory authorities’ approvals in Canada and the United States, among others.
We employ persons pursuant to the Canada Labour Code employment laws and regulations, the Canadian Human Rights Act, provincial workers compensation and insurance statutes, and in accordance with federal immigration, citizenship, permanent resident and worker permit laws, regulations, and requirements. Persons who are employed as maintenance technicians are also required to hold applicable Transport Canada licenses and certificates.
Alpine Aerotech has no reporting obligations in other jurisdictions.
B. STEPS TO PREVENT AND REDUCE RISKS OF FORCED LABOUR AND CHILD LABOUR
Alpine Aerotech is committed to taking effective steps to assess, prevent and mitigate the risk of forced labour and child labour in our operations and supply chains. We recognize the correlation between the risk of forced labour and child labour in supply chains and certain other geographic, sector and product specific factors. We have incorporated these considerations into our assessment.
Given that the vast majority of our suppliers are located in Canada and the United States, regions known for fair labour laws and standards, Alpine Aerotech has evaluated the risk of forced labour and child labour in our activities and supply chains as low.
Currently, Alpine Aerotech conducts recruitment locally, with trained HR professionals, who conduct multiple interviews and background checks to ensure standard and appropriate recruitment practices take place for all hiring. Alpine Aerotech workers and employees have access to the Anonymous Employee Reporting Hotline to report suspected violations of law or company policy.
Despite our low-risk evaluation, we are (i) gathering information on Alpine Aerotech’s worker recruitment and maintaining internal controls to ensure that all workers are recruited voluntarily, and (ii) developing and implementing additional grievance mechanisms to address complaints in the workplace.
C. POLICIES AND DUE DILIGENCE PROCESSES
Given our low-risk assessment, we have not developed specific policies or due diligence processes focused on forced labour and child labour over the past fiscal year. Nevertheless, Alpine Aerotech has embedded responsible business conduct into policies and management systems, including, but not limited to, establishing processes and procedures governing how candidate interviews are conducted, how candidate references are verified and how job offers are extended.
D. FORCED LABOUR AND CHILD LABOUR RISKS
The risk of forced labour or child labour within our supply chains is determined to be low given the highly regulated nature of our industry and large concentration of our suppliers located in Canada and the United States, countries recognized as being low risk for forced labour and child labour. Despite the low risk, Alpine Aerotech acknowledges that our risk profile may change and commits to evolving our risk management practices and policies on an as needed basis.
E. REMEDIATION MEASURES
To date, Alpine Aerotech has not uncovered any cases of forced labour or child labour within our operations or supply chains. Therefore, no corrective action is necessary at this time.
F. REMEDIATION OF LOSS OF INCOME
Alpine Aerotech has not identified any loss of income to vulnerable families resulting from measures taken to eliminate the use of forced labour or child labour as no such labour practices have been identified in our activities and supply chains.
G. TRAINING
In the previous fiscal year, Alpine Aerotech did not conduct specific training for employees on forced labour or child labour, because our assessment indicates that such risks are minimal in our operations. Nonetheless, Alpine Aerotech remains alert and is prepared to adjust our employee training programs as needed should our risk profile evolve.
H. ASSESSING EFFECTIVENESS
Alpine Aerotech did not perform a formal effectiveness assessment of our prevention strategies for forced labour and child labour during the past fiscal year. However, we will continue to evaluate our risk profile. Should the risk of forced labour or child labour increase, we are prepared to implement mechanisms to assess the effectiveness of our initiatives more formally.
APPROVAL AND ATTESTATION
In accordance with the requirements of the Fighting Against Forced Labour and Child Labour in Supply Chains Act, and in particular section 11 thereof, I, on behalf of Alpine Aerotech Limited Partnership and Alpine Aerotech GP Ltd., its general partner, in the capacity of President of Alpine Aerotech GP Ltd., attest that I have reviewed the information contained in the report on behalf of Alpine Aerotech. 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 within this report.
Jeff Denomme
President
May 30, 2025