Statement on Fighting Against Forced Labour and Child Labour
This statement is made on behalf of the leadership of Cactus Restaurants Ltd. (“Cactus”) with regards to the Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act (Modern Slavery). This statement covers Cactus’ reporting following the 2024 financial year period (January 2024 to January 2025) and articulates the Group’s policies and practices around recognizing and preventing Modern Slavery in the global supply chain.
About Cactus
Cactus Restaurants Ltd. is a private Canadian incorporated business and is the owner and operator of CACTUS CLUB CAFE. Cactus employs more than 6,025 business partners across North America and operates 35 Cactus Club Cafe restaurants. Cactus operates with a centralized supply chain that extends to international suppliers of goods including agricultural and manufactured products and equipment, and other related goods and services.
Our policies and values
Cactus recognizes its responsibility to assess actual and potential human rights impacts across its operations and supply chain and is committed to working with a supply chain free from forced labour and child labour. Cactus seeks to work with value-aligned partners and suppliers and expects suppliers working on its behalf to reflect Cactus’ commitment to acting ethically and with integrity in all business relationships. Cactus expects suppliers to implement and enforce systems and controls to ensure Modern Slavery is not taking place anywhere in their supply chains. The Group has commenced the process of integrating this Business Code of Ethics standard of business conduct into its contracts for all new and existing suppliers in its supply chain.
Cactus’ business practices include the following core values which we also require from our suppliers:
- Employment is freely chosen
- Freedom of Association is respected
- Working Conditions are safe and hygienic
- Child labour is not used
- Working hours are not excessive
- No discrimination is permitted
- No harsh or inhumane treatment is permitted
Due diligence, risk assessment and training
Cactus launched in-depth supplier reviews in 2023 as a key component of its supply chain risk management, designed to proactively identify various risks with a strong focus on human rights.
Building on the work of 2023 and continuing this commitment, Cactus further integrated risk assessments into its processes in 2024, placing a strong emphasis on supplier engagement and strengthened contractual obligations to ensure a high standard of due diligence against Modern Slavery.
Recognizing the critical role of ongoing education, Cactus remains dedicated to continually reviewing and enhancing employee training. This ensures that staff in procurement, supply chain, and related functions are well-equipped to identify, prevent, and address instances of Modern Slavery. By prioritizing education and awareness, Cactus is dedicated to fostering a corporate culture deeply rooted in ethical practices.
Assessment of effectiveness in preventing Modern Slavery
Cactus will continue to keep under review new risks as they emerge and carefully monitor both existing and new suppliers and business activities with a robust verification program in place to confirm our suppliers’ compliance with Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act. This is achieved through robust contract terms and expectations, regular supplier visits, communications and reviews. We believe in continuous improvement in the prevention of Modern Slavery and we will continue to review our ethical trading programme annually to ensure it reflects best practices.
This statement was approved by the Executive Leadership of Cactus Restaurants Ltd. on September 19th, 2025.
Andrew Latchford, President
