Safety Compliance Policy
Filed Pursuant to Section 11 of the Fighting Against Forced Labour and Child Labour in Supply Chains Act (Bill S-211)
Reporting Entity: Daniel and Anita Blaquiere Family Trust
Covered Entities: NPLH Drilling and Hydraulics Plus
Reporting Period: January 1, 2024 – December 31, 2024
Filing Date: May 31, 2025
Authorized Signatory: Dana Blaquiere-Norkum, President & CEO
Executive Summary
This report outlines the actions taken in 2024 by NPLH Drilling and Hydraulics Plus to prevent the use of forced labour or child labour in their operations and supply chains. It represents a follow-up to the 2024 submission (covering the 2023 period) and demonstrates compliance with planned milestones, including the creation of a CSR Committee, the rollout of policies, and the beginning of training and supplier engagement.
1. Entity Overview
Business and Registration Numbers:
NPLH Drilling
- Business Number: 230347437
- Ontario Corporation No.: 2355291 Ontario Inc.
Hydraulics Plus
- Business Number: 17470
- Ontario Corporation No.: 1169366 Ontario Inc.
NPLH Drilling and Hydraulics Plus are both Ontario-incorporated entities controlled by the Daniel and Anita Blaquiere Family Trust. NPLH Drilling provides resource-sector drilling services. Hydraulics Plus specializes in the repair of hydraulic components. Both companies are based in Timmins, Ontario, and share administrative infrastructure, including procurement, HR, and compliance.
As of December 31, 2024:
- NPLH Drilling employed approximately 211 staff across Ontario and Quebec.
- Hydraulics Plus employed approximately 11 staff in Ontario.
2. Governance and Oversight
As committed in our 2024 statement, the Corporate Social Responsibility (CSR) Committee was planned and approved in late 2024 and formally launched in Q1 2025.
- The Committee includes representatives from Legal, HR, Procurement, Operations, and Executive Management.
- The Committee reports to the President & CEO and holds quarterly meetings with documented deliverables.
3. Actions Taken in 2024
Governance Implementation
- CSR Committee formed in Q1 2025 with full mandate and reporting structure.
Policy Development
- The Responsible Business Conduct (RBC) Policy was finalized in Q3 2024 and disseminated to all employees.
- The Whistleblower and Grievance Reporting Policy was completed in Q4 2024.
Training Rollout
- Mandatory employee training on ethical conduct and supply chain risk launched in Q4 2024.
- Completion rate by filing date: 81% (target of 100% by July 2025).
Supplier Engagement
- Supplier onboarding process and attestation checklist implemented in Q4 2024.
- 94% of Tier 1 suppliers completed the attestation form.
- All attested suppliers classified as low-risk as of May 2025.
4. Risk Identification
Based on our 2024 due diligence, internal audits, and supplier attestations, no actual or potential risks of forced labour or child labour were identified in our operations or supply chains.
In addition to internal assessments, we continue to maintain collaborative relationships with Indigenous communities such as Taykwa Tagamou Nation, Moose Cree First Nation, Apitipi Anicinapek First Nations, Mattagami First Nation and Flying Post First Nation, as well as NGOs focused on ethical labour practices and human rights. These partnerships support community-based oversight and proactive engagement in responsible sourcing and social accountability.
Our supply chain remains limited in scope, with the vast majority of Tier 1 vendors located within Ontario. Hydraulics Plus operates exclusively within Timmins and sources parts from verified Canadian suppliers. NPLH Drilling’s subcontractors are similarly subject to onboarding and attestation protocols.
We reference tools such as the Walk Free Index and U.S. Department of Labor reports, which continue to indicate low geographic and commodity-based risk exposure. We remain committed to ongoing vigilance through continued monitoring and scheduled reassessment.
5. Remediation and Grievance
No remediation was required in 2024. However, grievance systems are now in place:
- Confidential reporting email established
- Escalation protocols managed by Legal and HR
Non-compliance with supplier declarations will trigger formal review and potential disengagement.
6. Progress on 2024 Commitments
2024 Commitment | Status (as of May 2025) |
|---|---|
Establish CSR Committee | Completed Q1 2025 |
Finalize RBC and Whistleblower Policies | Completed Q3–Q4 2024 |
Launch Mandatory Training | Initiated Q4 2024 (81% complete) |
Implement Supplier Onboarding & Attestations | Completed Q4 2024 |
7. Future Actions (2025–2026)
- Reach 100% employee training completion by July 2025
- Extend due diligence to Tier 2 suppliers by Q4 2025
- Conduct internal audit of grievance system by Q1 2026
- Review existing contracts for clause alignment by December 2025
- Evaluate third-party auditor engagement by 2026
8. Approval and Certification
This report was approved by the Board of Directors and signed by an authorized officer.
Signed on May 28, 2025 | Dana Blaquiere-Norkum | President & CEO