Forced Labour in Canadian Supply Chains Annual Report

Bill S-211 Annual Report for Reynolds Consumer Products Canada Inc.

Reporting Year: January 1, 2025 through December 31, 2025

a. Structure, Activities, and Supply Chains

Reynolds Consumer Products Canada Inc. (“RCP Canada”) is a Canadian wholly-owned subsidiary of Reynolds Consumer Products Inc. RCP Canada manufactures and sells aluminum foil, parchment paper and other kitchen products, primarily under the Reynolds and Alcan brands. In addition to local manufacturing of kitchen products, RCP Canada resells imported products in the tableware and waste bags categories under the Hefty brand.

RCP Canada is based in Mississauga, Ontario, with a manufacturing facility located in Mississauga. The Mississauga plant provides substantial production capabilities, producing millions of pounds of aluminum foil products annually. Local Canadian manufacturing enables RCP Canada to offer customers a broad product assortment, including the ability to fulfill diverse product needs within a single order.

From an operational perspective, RCP Canada engages in both manufacturing and resale activities. Quality control for manufactured products is managed internally at the Toronto facility. RCP Canada's product distribution system is optimized through automated inventory and sales forecasting systems, facilitating efficient order placement and management.

In addition to manufacturing, RCP Canada also performs key administrative functions locally, including finance, sales and marketing and payroll, in compliance with Canadian regulatory requirements. Centralized IT services are provided by Reynolds Consumer Products LLC, which is also a subsidiary of Reynolds Consumer Products Inc. This structured integrated approach to operational and administrative structure supports RCP Canada's position in a competitive market, emphasizing efficiency, local production advantages, and customer service.

RCP Canada operates as part of a broader global enterprise and its activities represent a portion of the consolidated operations of Reynolds Consumer Products Inc. The disclosures in this report are limited to the activities of RCP Canada for purposes of compliance with the Act.

With respect to the processes contemplated by this report, different functional groups throughout RCP Canada are responsible for implementing the diligence processes and procedures required for compliance. Reynolds Global Quality team oversees quality monitoring, compliance enforcement, ethical and social standards, and employee safety with respect to outside manufacturers and suppliers. Reynolds Global Quality team collaborates with a cross-functional team including Social Compliance, Global Commercialization, Procurement, Legal, and Regulatory. Within this structure, Global Commercialization is responsible for identifying sourcing opportunities and developing contracts with manufacturers of finished goods, while Procurement is responsible for sourcing and developing contracts with manufacturers of materials and semi-finished goods. This includes both direct (tier one) suppliers and, where appropriate, indirect suppliers identified through risk-based due diligence.

b. Policies and Due Diligence Processes

Policies and Contracts: RCP Canada is committed to a work environment that is free from human trafficking and slavery, which includes forced labour and unlawful child labour. RCP Canada does not tolerate or condone human trafficking or slavery in any part of its global organization, activities, or supply chain. As part of its commitment, RCP Canada implements robust due diligence policies and procedures related to forced labour and child labour. Some of the policies and due diligence procedures implemented by RCP Canada involve:

1. Contractual requirements: RCP Canada implements contractual provisions with vendors and suppliers, which state expectations of suppliers to comply with Reynolds ethics policies. Reynolds maintains several policies related to supplier ethics, including its Anti Human Trafficking Policy, Human Rights Policy, and its Statement of Business Principles and Code of Conduct Policy. Contractual provisions with suppliers also include expectations that suppliers utilize only freely chosen employment, absent of discrimination, and free of bonded and child labour.
2. On-site visits: Reynolds Global Quality team in partnership with the Social Compliance team also perform due diligence through on-site audits of suppliers to verify and validate compliant practices with respect to forced labour and child labour.

RCP Canada also maintains the following due diligence procedures when necessary: Embedding responsible business conduct into policies and management systems; Identifying and assessing adverse impacts in operations, supply chains and business relationships; Ceasing, preventing, or mitigating adverse impacts; Tracking implementation and results; Communicating how impacts are addressed; and providing for or cooperating in remediation when appropriate.

c. Forced Labour and Child Labour Risks

RCP Canada and Reynolds Global Quality team regularly conducts risk assessments and reviews its supply chain to assess its activities to identify risk areas for forced labour or child labour, both in its own activities and the activities of its direct and indirect suppliers. Some of the risk factors identified during these assessments include: Locations of activities, operations, and factories; locations of tier one (direct) suppliers; use of outsourced, contracted, or subcontracted labour; and the use of migrant labour.

Based on these assessments, potential higher-risk areas include certain categories of imported finished goods sourced through third-party manufacturers and supply chains involving regions or sectors that are recognized as presenting elevated risks of forced labour or child labour. RCP Canada continues to monitor these risk areas through its due diligence processes.

d. Remediation Measures

As described above, RCP Canada and Reynolds Global Quality team regularly conducts risk assessments and reviews its supply chain to assess its activities to identify risk areas for forced labour or child labour both in its own activities and the activities of its direct and indirect suppliers. Based on the risk assessments and due diligence activities described above, RCP Canada did not identify any instances of forced labour or child labour.

e. Remediation of Loss of Income

As described above, neither forced labour nor child labour were identified in RCP Canada’s activities and supply chains. Therefore, there was no resulting loss of income or need for remediation of loss of income.

f. Training

RCP Canada has several mandatory employee trainings through its Navex compliance program which either directly or indirectly relate to forced labour and child labour and relevant risk factors. All employees are required to participate in training on the company’s Business Principles and Code of Conduct Policy. Modern Slavery and Human Trafficking training is mandatory for hourly employees, as well as employees making contracting or purchasing decisions and managing contracted manufacturers. The required training includes all elements of the ETI Base Code, the components of the company’s policies, and specific laws and regulations related to supplier ethical and social compliance. Training content is periodically updated to reflect evolving legal requirements and risk profiles.

g. Assessing Effectiveness

RCP Canada, Reynolds Global Quality and Social Compliance teams monitor and assess the effectiveness of the described policies and diligence processes in three ways:

1. Supplier Self-Assessments: An annual self-assessment is required from all outside manufacturers to communicate to RCP Canada the status and implementation of management systems which ensure proper mitigation against forced and child labour;
2. Third Party Ethical and Social Compliance Audits: Audits are required to be completed at least every 2 years at RCP Canada’s own site and any outside manufacturers used by RCP Canada in the production of finished goods. Audit performance is reviewed and includes a corrective action and remediation process for any deficits or issues identified. Depending on performance additional audits could be required to verify compliance.
3. On-site verification: In partnership with Reynolds Social Compliance team the Reynolds Global Quality team conducts its own audits and follow-up assessments to verify the implemented management practices of outside manufacturers are effective and to give correction where needed.

Effectiveness is further assessed through key indicators, including supplier audit completion rates, audit findings and corrective action closure rates, training completion rates, and escalation or remediation activity levels. These indicators are reviewed periodically to inform continuous improvement of the company’s due diligence program.

Approval and attestation

This report was approved by the Board of Directors of Reynolds Consumer Products Canada Inc.

In accordance with the requirements of the Fighting Against Forced Labour and Child Labour in Supply Chains Act (Act), and in particular section 11 thereof, I, in my capacity as Chief Legal Officer and Corporate Secretary, and as an officer authorized to bind the entity, attest that I have reviewed the information contained in the report on behalf of the governing body of the entity listed above. I have the legal authority to bind the entity. Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed within this report.

Jill E. Barnett

Chief Legal Officer & Corporate Secretary

Date: 5/22/2026