Safety Compliance Policy
Filed Pursuant to Section 11 of the Fighting Against Forced Labour and Child Labour in Supply Chains Act (Bill S-211)
Report Under the Fighting Against Forced Labour and Child Labour in Supply Chains Act (Bill S-211)
For the Financial Year Ending December 31, 2025
Filed: May 2026
Reporting Entity: NPLH Drilling Ltd.
1. Introduction
This report is submitted by NPLH Drilling Ltd. (“NPLH”) in accordance with the requirements of the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “Act”). The report describes the measures taken by NPLH during the 2025 financial year to prevent and reduce the risk of forced labour or child labour in its operations and supply chains. NPLH is committed to conducting its business responsibly, ethically, and in compliance with all applicable labour and human rights laws. This commitment extends to its employees, contractors, suppliers, and subcontractors.
2. Structure, Activities, and Supply Chains
Corporate Structure and Business Activities
NPLH Drilling Ltd. is an Ontario-incorporated company headquartered in Timmins, Ontario. NPLH operates as a diamond drilling contractor serving the mineral exploration and mining sector, providing:
- Surface diamond drilling
- Underground diamond drilling
- Reverse Circulation Drilling
- Water well drilling
During the reporting period, NPLH conducted operations primarily across Ontario, Québec, and Newfoundland and Labrador, supporting exploration and development projects in multiple regions of Canada.
As of December 31, 2025, NPLH employed approximately 250 employees in safety-sensitive operational and support roles.
Supply Chains
NPLH’s supply chain includes:
- Drilling equipment manufacturers and distributors
- Steel, tooling, and consumables suppliers
- Personal protective equipment (PPE) suppliers
- Fuel, transportation, and logistics providers
- Specialized subcontractors and service providers
The majority of NPLH’s Tier 1 suppliers are located within Canada. Certain equipment and manufactured components may originate from global supply chains, introducing limited multi-tier sourcing exposure.
3. Governance and Oversight
Oversight of forced labour and child labour risk is integrated into NPLH’s corporate governance framework. Corporate Social Responsibility (CSR) Committee NPLH maintains a Corporate Social Responsibility (CSR) Committee comprised of representatives from:
- Executive Management
- Human Resources
- Procurement
- Operations
- Compliance
The Committee reports directly to the President & CEO and meets regularly. Its responsibilities include:
- Oversight of ethical conduct and labour-related policies
- Review of supplier compliance and risk assessments
- Monitoring of training initiatives
- Escalation and review of any identified concerns
4. Policies and Due Diligence Processes
NPLH maintains internal policies and procedures designed to promote ethical business conduct and compliance with labour standards, including:
- Responsible Business Conduct (RBC) Policy
- Whistleblower and Ethical Supply Chain Reporting Policy
- Occupational Health and Safety policies
- Employment practices aligned with Canadian labour legislation
Supplier Due Diligence
Supplier due diligence measures include:
- Tier 1 supplier onboarding and attestation processes
- Supplier risk assessment questionnaires
- Contractual requirements for compliance with applicable labour laws
- Ongoing monitoring and review by management and the CSR Committee
Suppliers are expected to comply with all applicable laws and to prohibit forced labour, child labour, and related exploitative practices within their own operations and supply chains.
5. Risk Assessment
NPLH conducts periodic assessments of the risk of forced labour and child labour within its operations and supply chains.
Risk Factors Considered
- Geographic location of operations and suppliers
- Nature of goods, services, and equipment procured
- Use of subcontractors and third-party service providers
- Degree of visibility into upstream supply chains
Risk Summary
- Operational risk: Low
- Supply chain risk: Low to Medium
- Subcontractor oversight risk: Medium
NPLH’s operations are primarily conducted within Canada, including Ontario, Québec, and Newfoundland and Labrador, which are generally considered lower-risk jurisdictions for forced labour and child labour. Some inherent risk exists where manufactured goods or components are sourced through global supply chains.
No actual or suspected instances of forced labour or child labour were identified during the 2025 reporting period.
6. Measures Taken to Address Risks
During the reporting period, NPLH implemented and maintained the following measures:
Supply Chain Measures
- Prioritization of established, reputable suppliers
- Collection and review of supplier compliance attestations
- Risk-based screening of suppliers by geography and service type
Contractual Measures
- Inclusion of compliance expectations and lawful labour requirements in supplier and subcontractor agreements
- Ongoing review of contractual language to support ethical sourcing
Operational Measures
- Robust human resources practices aligned with Canadian labour standards
- Transparent payroll, scheduling, and overtime management
- Strong focus on worker safety, supported by comprehensive health and safety programs
7. Remediation and Grievance Mechanisms
No instances of forced labour or child labour were identified during the reporting period; therefore, no remediation measures were required.
NPLH maintains grievance mechanisms, including:
- Confidential reporting channels for employees and stakeholders
- Escalation processes managed by Human Resources and Compliance
- Supplier corrective action or disengagement procedures where non-compliance is identified
No remediation actions resulted in loss of income to vulnerable individuals.
8. Training
NPLH provides training to support awareness of ethical conduct and labour standards, including:
- General employee training on rights, responsibilities, and workplace conduct
- Health and safety training for all operational staff
- Targeted awareness for management, procurement, and supervisory personnel
Training participation is monitored internally and reinforced on an ongoing basis.
9. Assessing Effectiveness
NPLH monitors the effectiveness of its measures through:
- Supplier attestation completion rates
- Review of supplier risk assessments
- Employee training participation tracking
- CSR Committee oversight and reporting
These measures support continuous improvement and informed future reporting.
10. Approval and Attestation
This report was approved by the leadership of NPLH Drilling Ltd..
In accordance with section 11 of the Fighting Against Forced Labour and Child Labour in Supply Chains Act, I attest that I have reviewed the information contained in this report and, having exercised reasonable diligence, confirm that it is true, accurate, and complete in all material respects.
Name: Dana Blaquiere-Norkum
Title: President & CEO
Date: May 7 2026