ARCELORMITTAL CANADA HOLDINGS INC. Fighting Against Forced Labour and Child Labour in Supply Chains Act
This statement is made by ArcelorMittal Canada Holdings Inc. (“AM Holdings”), a subsidiary of ArcelorMittal S.A., on behalf of itself and its subsidiaries ArcelorMittal Canada Inc., ArcelorMittal Long Products Canada G.P. (“Long Products Canada”) (collectively the “Subsidiaries” and together with AM Holdings, the “Company”) pursuant to the Fighting Against Forced Labour and Child Labour in Supply Chains Act, SC 2023, c 9 (the “Act”). This statement covers the 2025 reporting year and sets out the steps taken by the Company to prevent and reduce the risk that forced or child labour is used at any step of the production of goods in Canada or elsewhere or of goods imported into Canada by the Company. The Company is part of the ArcelorMittal group of companies (“ArcelorMittal Group”) and remains committed to taking meaningful action to prevent the use of forced or child labour within its business and supply chain.
General Policies and Approach to Forced and Child Labour
Our approach to preventing forced and child labour in our activities and supply chains remains grounded in the ArcelorMittal Human Rights Policy (which is derived from various International Human Rights Declarations including the United Nations’ Universal Declaration of Human Rights) and various ArcelorMittal Group policy documents (the “Policy Framework”), which is structured to ensure the ArcelorMittal Group operates with the highest level of integrity and in compliance with applicable laws. Through the Policy Framework, the ArcelorMittal Group asks its suppliers to have effective management systems in place to achieve the environmental, social, and governance objectives to which the Company is committed. The Company also seeks to influence its suppliers to work together to identify further opportunities to improve responsible business practices along the supply chain and develop ongoing performance improvements to the Policy Framework. The following are the main policies of the Policy Framework setting out the Company’s general approach to the risks of forced and child labour:
Code of Business Conduct: The Code of Business Conduct continues to articulate the fundamental legal and ethical principles that guide the Company’s conduct and prohibits the use of forced or child labour. It also reinforces our commitment to maintaining a work environment free of harassment and discrimination, promoting occupational health and safety and respecting the environment.
Human Rights Policy: This policy articulates the Company’s commitment and respect for all human rights in line with the United Nations Guiding Principles on Business and Human Rights. This policy affirms that the Company is opposed to the use of forced labour, child labour, human trafficking and all other forms of human rights violations known as forced labour, within the Company’s operations and supply chain.
Code for Responsible Sourcing (the “Code”): The Code, sets expectations for suppliers regarding human rights, labour, health and safety, the environment and anti-corruption, which includes ensuring that all work is freely chosen and without the use of forced or child labour. The Code is supplemented by a guidance document for the ArcelorMittal Group’s buyers and suppliers that details specific expectations in relation to forced and child labour. The Code supports the ArcelorMittal 10 Sustainable Development Outcomes which are aligned with the UN Sustainable Development Goals.
ARCELORMITTAL CANADA HOLDINGS INC.
AM Holdings is a federal corporation and does not produce goods in Canada or elsewhere nor does it import goods into Canada. AM Holdings controls the Subsidiaries that engage in these activities as highlighted in the following entity specific sections.
ARCELORMITTAL CANADA INC.
ArcelorMittal Canada Inc. is a federal corporation and does not produce goods in Canada or elsewhere nor does it import goods into Canada. ArcelorMittal Canada Inc. is a subsidiary of AM Holdings and is a direct controlling entity of ArcelorMittal Canada Inc. that engages in these activities as highlighted in the following specific sections.
ARCELORMITTAL LONG PRODUCTS CANADA G.P.
Structure, Activities and Supply Chains
Structure
Long Products Canada is a Canadian partnership domiciled in Quebec and ranks as the country’s fourth-largest steel producer. It is the only steelmaker in Canada that primarily uses internally produced direct reduced iron as its main metallic input.
We offer a broad range of high-quality steel products, primarily serving customers in Canada and the United States across the automotive, construction, and other industrial sectors.
Our main production facilities are located in and around Contrecoeur, Quebec. These include a bar mill in Longueuil, Quebec, as well as wire mills in Montreal, Quebec.
Activities
Long Products Canada employs approximately 1906 people across and operates with an annual budget of $1.5 billion. Our facilities have a total annual production capacity of approximately 2 million metric tons of steel.
Supply Chain
Long Products Canada supply chain generally includes the sourcing of a variety of raw materials, equipment and specialized services. The main raw material suppliers are located in North America (Canada, USA, Mexico). Some suppliers are located in China, India, Germany, and Austria.
Regarding equipment, the sources of supply are located in North America (Canada, USA, Mexico). Some suppliers are located in China, India, Turkey and Italy. Docusign Envelope ID: DA194F6F-DA1A-8C5D-8193-475920955D1D
The main service providers are located predominantly in North America (Canada, USA and Mexico). The procurement of goods and services at Long Products Canada is led by commercial teams with support from legal and tax professionals.
Steps Taken to Prevent and Reduce Risks
Risk Assessment and Mitigation
Long Products Canada conducts an annual risk assessment that includes the evaluation of human rights risks as part of its broader local risk management processes. Our Code of Conduct includes explicit commitments to responsible business practices, aligned with relevant industry standards.
We adopt a risk-based approach to supplier engagement, focusing our efforts on segments of the supply chain where the potential for non-compliance with our ethical standards is greatest. This targeted engagement allows us to uphold our commitment to sustainable and responsible sourcing.
Supply Chain Evaluation
As part of Long Products Canada’s supplier registration process, all suppliers are required to undergo a due diligence review and comply with our Supplier Code of Conduct, Code of Business Conduct, and Human Rights Policy.
To strengthen our risk assessment capabilities, we also utilize third-party due diligence software to evaluate and monitor new suppliers, helping to ensure they meet our ethical, legal, and operational standards from the outset.
Contractual Requirements
Long Products Canada acknowledges that certain jurisdictions from which it sources goods and services may be directly or indirectly associated with actual or potential risks of forced or child labour. These concerns are a key focus of our Human Rights Policy Framework.
Through our supply chain assessment, we have identified potential exposure primarily through indirect relationships with raw material and equipment suppliers. To mitigate these risks, we strive to engage with globally recognized and reputable organizations committed to responsible business practices.
According to our annual human rights risk assessment, the risk level associated with our service suppliers is considered low.
Forced Labour and Child Labour Risks
Long Products Canada recognizes that certain jurisdictions from which it sources goods and services may be directly or indirectly associated with actual or potential risks of forced or child labour. Addressing these risks is a central focus of our Human Rights Policy Framework.
Our supply chain assessment has identified that potential exposure may exist primarily through indirect relationships with raw material and equipment suppliers. To mitigate these risks, Long Products Canada is committed to sourcing from globally recognized and reputable organizations. Docusign Envelope ID: DA194F6F-DA1A-8C5D-8193-475920955D1D
Based on our annual human rights risk assessment, the level of risk associated with our service suppliers is currently assessed as low.
Remediation Measures
The Company and the ArcelorMittal Group continue to operate a confidential and, where requested, anonymous whistleblowing procedure on their website, in accordance with the Whistleblower Policy, as well as a Grievance Procedure through which stakeholders may report ethical concerns. These include complaints related to human rights abuses, harassment, discrimination, environmental violations, or any breaches of internal policies or applicable laws. Long Products Canada together with our global grievance committee, monitors the volume, type and response to such concerns. Long Products Canada is committed to ensuring that all grievances are investigated and addressed in a timely, fair, and transparent manner.
Remediation of Loss of Income
At this time, no specific measures have been taken to remediate loss of income within our operations or supply chains. However, Long Products Canada continues to monitor potential impacts as part of its broader risk management and supplier engagement processes.
Training Provided to Employees
All employees at Long Products Canada are required to complete training on the Code of Business Conduct, with mandatory refresher sessions every three years. In addition, managers, senior personnel, and individuals in relevant roles must complete specific human rights training, which is also refreshed on a three-year cycle.
Beyond mandatory training, the Human Rights Policy Framework is actively communicated to employees through multiple channels, including email communications, compliance videos, targeted local trainings, and awareness initiatives, reinforcing our commitment to ethical conduct.
Assessing effectiveness
ArcelorMittal Canada Holdings Inc. and its subsidiaries, including Long Products Canada., assess the effectiveness of their measures to prevent and reduce the risks of forced and child labor through a combination of internal reviews, due diligence processes, and ongoing monitoring mechanisms. Annual human rights risk assessments serve as a primary tool to identify and evaluate potential exposure across our supply chains, with findings used to adapt our mitigation strategies. We rely on supplier onboarding procedures, including mandatory compliance with our Code of Business Conduct, Human Rights Policy, and Supplier Code of Conduct, as well as third-party due diligence tools to vet and monitor suppliers. Effectiveness is further supported by our whistleblower and community grievance mechanisms, which provide accessible and confidential channels for raising concerns, including potential human rights violations. These reports are tracked and reviewed by our Global Assurance team to identify trends and assess responsiveness. In addition, employee training programs and awareness initiatives are regularly updated and deployed to reinforce our policies and ensure ongoing vigilance. While current assessments indicate a low level of risk among our service suppliers, we remain committed to continuously improving our practices and frameworks to uphold the highest standards of ethical sourcing and human rights protection. Docusign
Approval and Attestation
This report is approved and attested, in accordance with subsection 11(4) and subsection 11(5) of the Fighting Against Forced Labour and Child Labour in Supply Chains Act.