Our Forced Labour Report

At The Cadillac Fairview Corporation Limited (“CF”), we support and respect the protection of human rights and stand against any instance of forced or child labour, modern slavery or human trafficking (collectively, “modern slavery”).  As an organization, we work to create a diverse and inclusive environment and hold ourselves to high standards of integrity throughout our business.  In doing so, we ensure that CF complies with applicable laws and regulations in each jurisdiction in which we operate.

This statement applies to the 2023 calendar year in compliance with the Fighting Against Modern slavery and Child Labour in Supply Chains Act (Canada).

CF is wholly-owned by Ontario Teachers’ Pension Plan Board (“OTPP”).  CF and its affiliates develop, own, operate and manage OTPP’s real estate assets in Canada.  CF has approximately 1400 employees located in offices in Toronto, Vancouver, Calgary and Montreal, as well as at our retail, office, industrial and residential properties across the country.  

The majority of goods required to support CF’s operating needs as a developer, owner, operator and manager of real estate in Canada are provided by and, where appropriate, imported by our general contractors, trades and service providers.  As such, CF is not the importer of record with respect to such goods.  CF will from time to time directly import goods to address various operating needs within its business.

At CF, we have internal policies, procedures and guidelines which serve as a framework for our conduct:

CF’s Code of Conduct

CF’s Code of Conduct sets out requirements and expectations for employees to ensure that everyone at CF acts ethically and with the highest level of integrity.  Our Code of Conduct guides decision-making for all employees and establishes clear parameters for business conduct.  It also serves as our roadmap for creating an inclusive environment that is free of discrimination, harassment and workplace violence, and one where employees can speak up without fear of retaliation.  CF’s Code of Conduct applies to all employees and everyone who works on behalf of CF and is reviewed on an annual basis by all key stakeholders within our organization.  As part of our 2024 review, CF will include provisions requiring CF employees to identify, prevent and remediate any adverse human rights risks arising within our business activities, relationships and supply chains, including modern slavery risks.  To support this, CF maintains an anonymous reporting hotline so that employees can report concerns (including any concerns relating to modern slavery) within CF’s business.  

OTPP Policies and Guidelines

As a wholly-owned portfolio company of OTPP, CF is governed by and subject to certain OTPP policies and guidelines.  These include OTPP’s Responsible Investing Guidelines, which outline key environmental, social and governance (“ESG”) practices and processes that support a clear focus on long-term value creation and a systematic assessment of risks and opportunities posed by ESG considerations.  

Supplier Modern Slavery Compliance Requirements

During 2024, CF will enhance supplier compliance provisions within certain of its contract forms to  require certain suppliers to have policies and guidelines in place with respect to working hours and compensation, forced or child labour, and human trafficking.

Suppliers

Commencing in 2024, CF will risk assess new suppliers to identify those located in high risk industry sectors or high risk jurisdictions (on the basis of the Global Slavery Index).  New suppliers may be required to enter into contracts with enhanced compliance provisions that specifically require them to have policies and guidelines in place with respect to working hours and compensation, forced or child labour, and human trafficking.  Where instances of material non-compliance occur, CF will take appropriate action to address such non-compliance.

Investments

Prior to completing an investment or selecting a business partner, CF’s Legal and Investments teams complete comprehensive due diligence with respect to our prospective counterparty.  This due diligence includes a review of the counterparty’s legal, regulatory and compliance history and an assessment of any instances of past non-compliance, including in the area of modern slavery.

As an institutional investor, the majority of CF’s workforce consists of skilled and experienced individuals.  With robust policies and procedures in place, we consider the overall risk of instances of Modern slavery occurring within our business to be low.  However, with suppliers located in other jurisdictions, we recognize that there may be an indirect risk of Modern slavery.  

We therefore work diligently to monitor and address the risk of Modern slavery in our supply chain.  In this regard, CF undertook a comprehensive review of all goods that it imported into Canada in 2023, and identified no instances of suppliers in high risk industry sectors or located in high risk jurisdictions (on the basis of the Global Slavery Index).

No instances of Modern slavery were identified by CF or reported to CF in 2023. As a result, no remediation measures were required. To the extent that any such issues arise in the future, we will review appropriate remediation measures as needed.

In 2024, CF will complete training with relevant employees to ensure that they understand our responsibilities with respect to Modern slavery compliance, and can identify and address risks of Modern slavery within our business and supply chain. This training will be mandatory for relevant employees on a regular basis thereafter.

CF is committed to supporting and respecting the protection of human rights. While we are proud of our 2023 efforts with respect to Modern slavery, we will continue to review our policies, processes and practices to identify opportunities to enhance compliance in this area across our business.

This report was approved pursuant to subparagraph 11(4)(a) of the Fighting Against Forced Labour and Child Labour in Supply Chains Act (Canada) by the Board of Directors of CF.