This Modern Slavery Report (the “Report”) is made by Parrish & Heimbecker, Limited on its own behalf and on behalf of our operating divisions P&H Milling Group and New-Life Mills (collectively, “P&H”, the “Company”, “we” or “our”) under the Fighting Against Forced Labour and Child Labour in in Supply Chains Act (the “Act”) for the period May 1, 2025 to April 30, 2026.
P&H is a privately held Canadian agri-business incorporated pursuant to the laws of Canada with diversified interests in grain procurement and merchandising, flour milling, animal nutrition and Canadian real estate, as well as egg grading and processing.
P&H Milling Group and New-Life Mills are both operating divisions of P&H and are included in this Statement. P&H Foods Inc. (“P&H Foods”) is a new operating division of P&H formed through the 2025 acquisition of the egg grading, distribution and processing operations of L. H. Gray & Son. All of our divisions described below under “Operations”, as well as P&H Foods, are included under the single legal entity Parrish & Heimbecker, Limited. However, P&H Foods will continue reporting separately while the Company continues to integrate operations and given that the information historically provided in its legacy Modern Slavery reporting is not considered to generally apply to all other entities covered within this report.
Grain: The P&H National Grain Asset Network comprises approximately 45 locations that span from coast to coast across Canada. Our facilities are strategically located to match producer grain with the needs of both domestic and export end users in terms of quantity, quality and logistical requirements. The P&H National Grain Asset Network includes grain elevators, rail sidings, inland terminals and specialized export terminals.
P&H trades virtually any grain or legume produced in Canada, including: corn, feed barley, malt barley, milling wheat, oats, soybeans and canola.
P&H also sources grain to supply flour milling, food, animal nutrition and ethanol industries. Additionally, in Eastern Canada (Ontario) we service the feed ingredient industry, including wheat shorts, Non-GMO soybeans, soymeal, distillers’ grains (“DDGs”), and a variety of other by-products.
Crop Inputs: P&H offers crop input products including crop nutrition, crop protection and seed, as well as agronomic services at locations across Canada.
Flour Milling: Through its P&H Milling Group division, P&H sources wheat from Western Canada, Ontario, Quebec and Atlantic Canada to produce quality flour, cereal, durum, and pea products. The lineup includes hard red spring wheat flour for breads and other bakery products, soft winter wheat flour for cakes and cookies, as well as semolina flour for pasta, organic flour, and atta flour for chapati. In our specialty milling operation in Saskatoon, we also mill pea fractions.
From its mills in Halifax, Nova Scotia; Acton, Hanover, Hamilton and Cambridge, Ontario; and Lethbridge, Alberta, the P&H Milling Group supplies flour to customers throughout Canada, the United States, the Caribbean, the Middle East, Iceland and Pacific Rim countries.
Feed Mills and Farms: Through its New-Life Mills division, P&H has been a manufacturer of livestock nutrition since 1964. With five production facilities and a dedicated team of experts in species management, nutrition and production, our commitment to the best possible inputs, feed, and services for broiler chickens, eggs, turkey, beef, dairy, and swine, is the driving force behind our success.
Company-owned farms facilitate responsible nutrition and species management research, and a strict quality assurance/quality control program supports our FeedAssure® certification.
P&H procures goods from a large network of suppliers the vast majority of which are located Canada.
The main goods and services we source are:
| Type of Good Purchased | Description |
| Commodities including grains, oilseeds and by-products | Sourced from Canadian farmers and agribusinesses |
| Crop input products for resale | Purchased from third-party suppliers located primarily in Canada |
| Flour Enrichments and Additives | Purchased from third-party suppliers located primarily in Canada |
| Grain handling and flour/feed manufacturing and storage equipment | Purchased from third-party suppliers located primarily in North America |
| Packaging | Purchased from third-party suppliers located primarily in Canada |
| Logistics (third-party trucking, and rail services). | Purchased from third-party suppliers located primarily in Canada |
| Office supplies | Furniture, computers and equipment, and software, etc. purchased primarily in Canada |
P&H is committed to respecting human rights principles and is guided by codes of conduct which set expectations for behaviour and decision-making. Conducting our business with strong ethics and integrity is a critical part of our success.
We have a comprehensive risk assessment and due diligence program in place for suppliers and have close working relationships with most of our large suppliers.
P&H is evaluating ways to build on existing policies and procedures specific to forced labour and child labour matters, and imbed responsible business conduct into our various policies and management systems. For example, P&H Milling Group implemented a “Supplier Code of Conduct” which specifically identifies labour and human rights concerns.
Through our organizational and governance policies we communicate our values and expectations, setting a high bar for ourselves, our suppliers, and our selling partners, and make it clear that we do not tolerate any forms of forced labour or child labour. We are committed to consistently evolving and improving our approach. We do not tolerate child, forced or bonded labour in any of our operations or by suppliers working for us. We make every effort, including through carrying out due diligence and audits to monitor the performance of our suppliers, to prevent our activities having a negative impact on human rights.
We are committed to conducting our business in a lawful and ethical manner. Our Code of Ethics provides the foundation of our Company policies and sets out guiding principles on professional conduct and responsibilities. We also operate an Ethics Line to allow customers, suppliers and employees to raise any potential concerns. The Ethics Line is operated by a third-party vendor, providing a secure and confidential method for reporting issues or raising concerns.
P&H engages in various activities to identify, assess, and manage supplier risk. In assessing the risk of forced and child labour in our business and supply chains, we refer to external data sources, map supply chains and conduct risk assessments.
Based on our review and mapping of our supply chain, we consider the risk of any part of the business or its supply chain carrying a risk of forced labour or child labour to be low. The vast majority of P&H’s operations and suppliers are located in countries that have modern slavery or similar regulations in place.
No instances of forced labour or child labour were identified in our operations supply chains during the reporting period. Consequently, no remediation measures were taken. Should an instance be identified in the future, remediation plans would be put in place.
As noted above, no instances were identified of forced or child labour in our supply chains during the reporting period. Consequently, no remediation measures were required. Should an instance be identified in the future, remediation plans would be put in place.
We consider the ethical conduct of our employees to be a critical success factor. All employees must have documented acknowledgement of the code of conduct specific to their division. No other training relating to forced or child labour was carried out during the reporting period.
P&H is actively working to assess our environmental, social, and governance (“ESG”) performance, and identify priority areas, including with respect to forced and child labour. To prepare this Report, individuals with oversight of operations, procurement and risk management are consulted and asked to provide feedback.
P&H intends to continue to monitor for indicators of forced labour and child labour in our business and supply chains. As part of our ESG assessment, we will continue to examine various policies, processes and procedures needed to address critical business risk, including forced and child labour.
As part of our governance processes, we monitor compliance with our policies on an ongoing basis. We also review any concerns raised through our Ethics Line and other informal mechanisms of employee feedback. To date no significant concerns or complaints have been identified.
This Report has been approved by the Board of Directors of Parrish & Heimbecker, Limited in accordance with paragraph 11(4)(b)(ii) of the Act.
On behalf of the board of directors of Parrish & Heimbecker, Limited and not on my own personal behalf, and in accordance with the requirements of the Act, I attest that I have reviewed the information contained in the Report for the entities listed above. 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.
I have authority to bind Parrish & Heimbecker, Limited
John Heimbecker, Chief Executive Officer
Kevin L. Klippenstein, Chief Financial Officer
May 31, 2026
