A.) Sleeman’s structure, activities and supply chains

Sleeman Breweries is Canada’s third-largest brewer, known for its diverse portfolio of beers and its rich history in the Canadian brewing industry. 

History: 

Sleeman Breweries was founded in 1834 by John H. Sleeman in Guelph, Ontario, Canada. The company has a long and storied history, including periods of growth, setbacks, and acquisitions. During Prohibition in Canada, Sleeman continued brewing beer, which led to legal challenges and the eventual shutdown of the brewery. In 1988, John W. Sleeman, a descendant of the founder, revived the family business by re-establishing the brewery. In 2006, Sleeman Breweries was acquired by Sapporo Breweries, a world-renowned Japanese brewing company. Sleeman continues to operate as a distinct entity within the Sapporo Group, maintaining its brand identity and autonomy in brewing operations.

Products & Ingredients:

Sleeman has built an incredible portfolio of beer brands in Canada; great Canadian brands such as Sleeman, Okanagan Spring, Unibroue, and Wild Rose, combined with world-class beers such as Sapporo, Old Milwaukee and Pabst Blue Ribbon.

Sleeman produces a wide range of alcoholic and non-alcoholic beverages including beers and premixed ready-to-drink options. Its line of beers includes lagers, ales, and specialty brews. Some of its popular brands include Sleeman Original Canadian Lager, Sleeman Honey Brown Lager, Sleeman Cream Ale, and Sleeman Clear 2.0 Premium Light Lager. It also offers seasonal and limited-edition releases, experimenting with various flavors and styles to cater to evolving consumer preferences.

Sleeman sources its ingredients and materials from various suppliers. This list includes packaging materials such as glass bottles and aluminum cans, and ingredients such as malted barley, and corn syrup. Ingredients are globally sourced across Canada, the United States, and Europe.

Operations:

Sleeman operates multiple breweries across Canada, including facilities in Guelph, Ontario; Vernon, British Columbia; Calgary, Alberta; and Chambly, Quebec. Additionally, Sleeman's distribution network spans across Canada, with its products available in various retail outlets, bars, restaurants, and through online channels.

Today, Sleeman Breweries is frequently recognized as a local top employer and as one of Canada’s Greenest Employers. The company’s commitment to Better Beer, Better People, Getting Better has established it as a trusted organization and an employer of choice.

Sleeman Breweries holds a significant place in Canada's brewing landscape, combining its rich heritage with innovation to offer a diverse range of high-quality beers to consumers across the country.

B.) Sleeman’s policies and its due diligence processes in relation to forced labour and child labour

As a member of the Sapporo Group, Sleeman has adopted the following policies which can be found on the Sapporo Holdings website. Additionally, ethical sourcing and human rights are included in the Sleeman Corporate Purchasing Policy.

- Sapporo Group Basic Procurement Policy https://www.sapporoholdings.jp/en/sustainability/society/supplychain/policy/

- Sapporo Group Supplier Sustainability Procurement Guidelinehttps://www.sapporoholdings.jp/en/sustainability/society/supplychain/policy/pdf/procure_guideline_2023_04.pdf

- Sapporo Group Human Rights Policy Sapporo Group Human Rights Policy|Success of Human Resources|Sapporo Holdings

Sleeman is part of the Sapporo Group and contributes to the Global Sustainability Team, helping to implement and advance group-wide sustainability frameworks, targets, and reporting across core environmental and social impact areas.

Sleeman is committed to upholding and respecting the human rights of all individuals involved in its business operations. The company prohibits discrimination based on any grounds including race, ethnicity, nationality, creed, gender, religion, disability, sexual orientation, and gender identity or any other prohibited grounds as enumerated under the Canadian Charter of Rights and Freedoms and is committed to removing discriminatory barriers. As part of Sapporo Group, Sleeman has implemented and continues to strengthen its human rights due diligence process in alignment with the UN Guiding Principles on Business and Human Rights. Sleeman actively promotes awareness and understanding of human rights principles throughout the entire supply chain by engaging collaboratively with suppliers and reinforcing responsible business practices. 

Sapporo Group companies (which include Sleeman) are members of Sedex (Supplier Ethical Data Exchange), an online platform that supports responsible and sustainable supply chain practices. Through Sedex, Sleeman has the ability to conduct risk assessments on its suppliers, giving the company greater visibility into ethical, environmental, and compliance-related risks across its supply network

Sleeman provides an Ethics Hotline that is available to all employees to report concerns or potential violations of applicable laws, regulations, or company policies. As part of the Sapporo Group, Sleeman operates in accordance with the Sapporo Group Corporate Ethics Hotline Regulations, which establish whistleblowing contact points for employees and external stakeholders to report or consult on actual or suspected misconduct. Reports can be made in good faith and without fear of retaliation.

Further, the Sapporo Group Supplier Sustainability Procurement Guidelines promote mutual understanding and cooperation from our suppliers outlining that:

No work shall be performed against the will of individuals. In addition, children under the age of employment according to the laws and regulations of each country are not allowed to work. It is important that Sleeman and its “Main Vendors” (as defied below) comply with all laws and regulations of each country and region.

C.) Parts of Sleeman’s business and supply chains that carry a risk of forced labour or child labour being used and the steps it has taken to assess and manage that risk

Sleeman views itself to be at low risk for supporting forced labour and child labour. As an organization, we have not undertaken a full mapping of our supply chain; however, based on the long-standing nature our relationships with many of our suppliers as well as the straightforwardness of our supply chain, we assess the risk as relatively low.  Vendors are monitored on a regular basis through the Sedex to monitor ongoing risk and to ensure sustainable human rights practices are being maintained. 

Sleeman provides the above-noted Sapporo Group policies to its “Main Vendors” on an annual basis. “Main Vendors” are expected to adhere to this policy and guidelines.

The term “Main Vendor” is defined as:

- Current supply agreement or contract exists between vendor and Sleeman

- Vendor supplies direct spend raw materials to Sleeman on an ongoing basis

- Vendor managed by Sleeman National Procurement

Compliance to Modern Slavery Laws are included in the Terms and Conditions for all purchasing transactions completed in Sleeman’s operating system.  Sleeman’s system generates a Purchase Order and Standard Terms and Conditions that are electronically sent to the vendors.  Purchase Order contracts are executed with vendors upon the vendors’ acceptance of the Purchase Order and Sleeman’s Standard Terms and Conditions. 

D.) Measures taken to remediate any forced labour or child labour

We are not aware of any forced labour or child labour in our supply chain, so no corrective measures have been taken in 2025. To the extent we become aware of something we will investigate and remediate on a case-by-case basis. Sleeman will take appropriate and effective measures to prevent, mitigate and remediate any identified human rights reported violations.

E.) Measures taken to remediate the loss of income to the most vulnerable families that results from any measure taken to eliminate the use of forced labour or child labour in its activities and supply chains;

Sleeman has not taken any corrective measures in 2025 since we are unaware of any forced labour or child labour in our supply chain.

F.) Whether any training has been provided to employees on forced labour and child labour

Sleeman has developed policy training materials in 2025 and implemented a mandatory self-directed online training for all employees with access to Sleeman’s ERP (Enterprise Resource Planning) system. In addition to this mandatory training, further in person training sessions were delivered to multiple departments, with ongoing plans to extend training to additional teams and provide subject specific content to ensure continued compliance and best practices. Sleeman provides annual refresher training to employees, as well as onboarding training for new employees, to ensure consistent understanding and application of the Purchasing Policy.

Sleeman’s Modern Slavery Report is communicated across the organization to raise awareness through internal channels, ensuring employees understand the company’s commitments, risks, and responsibilities related to modern slavery and human rights

G.) How Sleeman assesses its effectiveness in ensuring that forced labour and child labour are not being used in its business and supply chains.

To our knowledge, our main vendors have not been cited for any forced labour or child labour violations. Thus, in 2025 we had no formal process to audit effectiveness.

Sleeman assesses its effectiveness in addressing the risks of forced labour and child labour through its supplier oversight practices, policy, and ongoing risk monitoring activities. As part of the Sapporo Group, Sleeman’s main vendors are subject to expectations set out in the Sapporo Group Supplier Sustainability Procurement Guidelines and are monitored through tools such as Sedex, which provides visibility into supplier risk indicators and reported compliance matters.

In 2025, Sleeman was not aware of any forced labour or child labour violations involving its main vendors. While no standalone audit of effectiveness was conducted during the reporting period, Sleeman continues to review supplier risk information, maintain long-standing supplier relationships, and monitor compliance through existing procurement and governance processes. 

This report has been approved by Sleeman Breweries’ board of directors.