Bill S-211

MODERN SLAVERY REPORT 2025

This Modern Slavery Report (the “Report”) addresses the period from January 1, 2025 to December 31, 2025 and has been prepared in compliance with Bill S-211, An Act to enact the Fighting Against Forced Labour and Child Labour in Supply Chains Act and to amend the Customs Tariff (Canada) (the “Act”). This Report is made on behalf of Ocean Brands and is not a joint report.

I. INTRODUCTION

Forced labour and child labour, each as defined in the Act, are crimes and serious violations of human rights. As a leading business in the food and beverage industry, Ocean Brands recognizes the important role we have in helping ensure that the supply chains supporting our operations and products adhere to high ethical standards, including the prevention and identification of forced labour and child labour.

This Report sets out the steps Ocean Brands has taken during the 2025 fiscal year 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 Ocean Brands, or of goods imported into Canada by Ocean Brands.

II. CORPORATE OVERVIEW AND SUPPLY CHAINS

Ocean Brands is a Canadian company specializing in the food and beverage industry, with a focus on ethical sourcing and sustainable business practices. Ocean Brands is a certified B Corp and is committed to helping achieve the United Nations Sustainable Development Goal 8.7, which focuses on eradicating forced labour, ending modern slavery and human trafficking, and securing the prohibition and elimination of the worst forms of child labour.

As part of our commitment to ethical business practices, Ocean Brands maintains a Supplier Code of Conduct that incorporates International Labour Organization Conventions and the UN Guiding Principles on Business and Human Rights. The Supplier Code of Conduct outlines clear expectations for responsible labour and business practices within our supply chain and explicitly prohibits forced labour, child labour, discrimination, and other human rights abuses.

Company Structure and Background Information

Ocean Brands, located at #100-3600 Lysander Lane, Richmond, British Columbia, Canada, has a corporate structure led by a President, Vice Presidents, a Chief Operating Officer, and Directors overseeing different departments within the business. The Director of Corporate Social Responsibility, the Vice President of Procurement, and the Vice President of Finance report directly to the President. This structure supports senior leadership oversight and accountability related to compliance with the Act, Ocean Brands’ Supplier Code of Conduct, and purchasing decisions made by Ocean Brands.

Company Activities & Supply Chain

Ocean Brands operates as a sustainable seafood and food products provider, with business operations focused on the sourcing, importing, marketing, and distribution of food products. The Corporate Social Responsibility and Procurement departments oversee the procurement process to support compliance with Ocean Brands’ ethical sourcing expectations.

Ocean Brands is a sales and marketing company that imports food products for resale under brands it owns. These brands include Ocean’s, Gold Seal, Club de Millionnaires, Matiz, Authentica, and Nonna Pia’s. Its assets are primarily limited to these food brands and the inventory sold under each brand. The exception is the manufacturing assets of Nonna Pia’s, a small food manufacturing facility located in Whistler, British Columbia, Canada. Ocean Brands does not own real estate and does not have an ownership stake in its suppliers.

The main categories of goods and services procured by Ocean Brands include food products, transportation, warehousing, and distribution services. Ocean Brands works with a diverse network of suppliers and service providers to support its operations and maintains relationships with customers and buyers across different geographic locations.

Ocean Brands’ supply chain includes seafood and other food products sourced from suppliers and processing facilities located in Canada and internationally. Ocean Brands recognizes that certain parts of global seafood supply chains, including overseas processing facilities and distant-water fishing vessels, may carry elevated human rights risks due to the complexity of supply chains, the use of migrant labour, recruitment practices, and the remote nature of fishing operations. These areas continue to be a focus of Ocean Brands’ human rights due diligence efforts.

III. POLICIES AND DUE DILIGENCE PROCESSES

Ocean Brands maintains a framework of policies and due diligence processes to help prevent and reduce the risk of forced labour and child labour in its operations and supply chain. These include the Supplier Code of Conduct, Employee Code of Ethics and Conduct, and Whistleblower Policy. Together, these policies outline Ocean Brands’ expectations for ethical labour practices, responsible business conduct, and mechanisms for raising concerns.

The Supplier Code of Conduct sets out Ocean Brands’ expectations for suppliers and processing facilities, including the prohibition of forced labour, child labour, discrimination, and other human rights abuses. The Code also includes responsible recruitment requirements, including an Employer Pays Policy that prohibits workers from paying recruitment fees. Ocean Brands requires suppliers and processing facilities to adhere to these standards and may request supporting documentation, audits, or assessments to verify compliance.

In 2025, Ocean Brands strengthened its due diligence process by requiring processing facilities to sign off on an updated and more robust Code of Conduct, provide third-party social assessment documentation, and complete a Self Assessment Questionnaire. These measures were intended to improve consistency in supplier expectations, increase visibility into labour practices, and support more informed supplier risk reviews.

Ocean Brands also began a Human Rights Due Diligence project in 2025 to gain a deeper understanding of its supply chain and identify opportunities to strengthen oversight, supplier engagement, and continuous improvement. This work supports Ocean Brands’ broader commitment to responsible sourcing and supply chain transparency.

Ocean Brands continues to participate in the Seafood Task Force, an industry-led collaboration focused on improving transparency, traceability, responsible recruitment, and accountability across seafood supply chains. This engagement allows Ocean Brands to remain connected to industry best practices and contribute to broader efforts to address forced labour and human trafficking risks in the seafood sector.

IV. RISK ASSESSMENT AND MANAGEMENT

Ocean Brands recognizes that certain parts of global food and seafood supply chains may carry elevated risks of forced labour and child labour. As in previous years, Ocean Brands identified overseas processing facilities and distant-water fishing vessels as higher-risk areas due to factors such as the use of migrant labour, recruitment practices, worker-paid recruitment fees, subcontracting, remote working conditions, and limited visibility beyond direct suppliers.

Ocean Brands manages these risks by applying a risk-based approach to supplier oversight, with greater attention placed on supply chain segments where visibility may be limited or where labour risks are generally understood to be higher. In 2025, this approach helped Ocean Brands prioritize follow-up with processing facilities and supply chain partners, strengthen its understanding of supplier practices, and identify areas where additional engagement or improvement may be needed.

The Human Rights Due Diligence project launched in 2025 further supports Ocean Brands’ risk management approach by improving supply chain visibility and helping identify potential gaps in oversight. This work will inform future due diligence priorities and support ongoing improvements to Ocean Brands’ supplier review process.

Ocean Brands also uses external collaboration to help manage risk. Through its participation in the Seafood Task Force and engagement with supply chain partners, Ocean Brands continues to support industry efforts aimed at strengthening responsible recruitment, transparency, traceability, and accountability across seafood supply chains.

V. MODERN SLAVERY REMEDIATION MEASURES

To the best of Ocean Brands’ knowledge, it has not identified instances of forced labour or child labour in its operations or supply chain during the reporting period.

In the event that forced labour or child labour is identified in Ocean Brands’ operations or supply chain, Ocean Brands is committed to taking prompt and appropriate remediation measures. These may include launching an internal investigation, engaging with the supplier or processing facility, requiring corrective action plans, monitoring implementation of corrective actions, engaging relevant stakeholders to address root causes, and, where remediation is not satisfactory or where a supplier refuses to cooperate, terminating the business relationship with the non-compliant supplier.

Ocean Brands recognizes that effective remediation should focus not only on addressing non-compliance, but also on preventing recurrence and supporting improved labour practices. Where appropriate, Ocean Brands would seek to work with suppliers and relevant stakeholders to support corrective action and continuous improvement.

VI. LOSS OF INCOME – REMEDIATION MEASURES

Ocean Brands recognizes that certain remediation measures, if not implemented carefully, may create unintended consequences for vulnerable workers and families, including potential loss of income. While Ocean Brands has not identified instances of forced labour or child labour requiring remediation during the reporting period, it remains mindful of the potential impact that corrective action or supplier disengagement may have on workers.

Ocean Brands does not currently have a formal remediation mechanism in place specifically for loss of income resulting from remediation measures. However, where a situation arises, Ocean Brands would seek to consider appropriate steps to support responsible remediation, including engagement with suppliers and relevant stakeholders to help mitigate negative impacts on affected individuals and communities.

VII. TRAINING

Ocean Brands provides training and awareness to relevant employees and key stakeholders to support understanding of forced labour and child labour risks. Training and awareness topics may include identifying indicators of exploitation, understanding Ocean Brands’ ethical sourcing expectations, supplier due diligence requirements, reporting mechanisms, and the standards set out in Ocean Brands’ Supplier Code of Conduct.

In 2025, Ocean Brands’ human rights due diligence activities helped reinforce awareness of human rights risks within relevant business functions. The Company continues to recognize the importance of cross-functional understanding and will continue working to strengthen training for employees involved in sourcing, supplier management, and supply chain oversight.

VIII. ASSESSING EFFECTIVENESS

Ocean Brands assesses the effectiveness of its policies, processes, and practices through ongoing review of supplier documentation, third-party social assessment information, supplier engagement, internal risk mapping, participation in industry initiatives, and review of its policies and procedures.

In 2025, Ocean Brands strengthened its approach by requiring processing facilities to sign off on an updated Code of Conduct, provide third-party social assessment documentation, and complete a Self Assessment Questionnaire. These actions improved Ocean Brands’ ability to gather information from suppliers, assess risk, and identify opportunities for further engagement.

Ocean Brands’ Human Rights Due Diligence project also supports the Company’s assessment of effectiveness by helping identify gaps in supply chain visibility and areas where additional due diligence may be required. Ocean Brands will continue to review and update its policies, procedures, and due diligence practices to ensure they remain aligned with international standards, ethical business practices, and evolving regulatory expectations.

Through proactive measures and ongoing collaboration, Ocean Brands strives to contribute to the global effort to address forced labour and child labour. Ocean Brands remains committed to continuous improvement, responsible sourcing, and creating supply chains where human rights are respected and all individuals are treated with dignity.

IX. APPROVAL AND ATTESTATION

This Report was approved pursuant to paragraph 4(a) of the Act by Ian Ricketts on [insert approval date] and has been submitted to the Minister of Public Safety and Emergency Preparedness in Canada. This Report is also available on Ocean Brands’ company website at www.oceanbrands.com.

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 Ocean Brands. Based on my knowledge, and having exercised reasonable diligence, I attest that the information in this Report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above.

Ian Ricketts on behalf of Ocean Brands

President, May 22, 2025

I have the authority to bind Ocean Brands