Read more about our efforts to combat and prevent forced and child labour in our operations and supply chain.
Crossroads Statement
Fiscal Year Ending December 31, 2023
At Crossroads, we are committed to respecting and upholding the human rights of all individuals within our operations and supply chain. This statement describes our efforts to combat and prevent forced and child labour in our operations and supply chain for fiscal year ending December 31, 2023.
Crossroads C&I Distributors, Inc. is a British Columbia, Canada corporation, Incorporation Number BC1281842 (“Crossroads”). Crossroads’ sole shareholder is Specialty Distribution Group, LLC, a Virginia limited liability company (“SDG”), which is a wholly owned indirect subsidiary of TopBuild Corp., a Delaware corporation listed on the New York Stock Exchange under ticker symbol BLD.
In 2023, GlassCell Isofab Inc., a British Columbia, Canada corporation, Incorporation Number BC0974400 (“GlassCell”), was a wholly owned subsidiary of Crossroads. Effective January 1, 2024, GlassCell was amalgamated into Crossroads.
This statement is published on behalf of Crossroads and GlassCell, and the terms “Crossroads”, “we”, and “our” when used herein refer to both companies, together.
Crossroads is a distributor and fabricator of industrial, commercial and marine insulation products, serving Canada’s industrial and commercial insulation contractors and buyers. We only operate in Canada and have approximately 300 employees, all residing in Canada.
We do not manufacture products. Rather, we source insulation products from third party manufacturers, such as Johns Manville, 3M, Armacell, Owens Corning, CertainTeed, Promat, Nutec, Rockwool, NVENT Thermal, Nu Fiber, and others. The list of manufacturers from whom we purchase varies little from year to year.
Approximately 90% of the products we purchase are manufactured in the United States and Canada, with the remaining products sourced from various countries, including countries in the European Union, Mexico, and China. Crossroads is typically several tiers away from the original source of the raw materials used in the manufacturing of the products. While we recognize that we cannot directly control the actions of the manufacturers, we have implemented the policies and procedures described in this statement to mitigate risk and promote ethical practices in our supply chain.
Our Code of Business Ethics, Human Rights Policy and Supplier Business Practices Policy reflect our commitment to combatting and preventing forced and child labour in our operations and supply chain:
Our Human Rights Policy applies to all company operations, including our suppliers. We offer our suppliers transparency and resources as to how we as an organization drive human rights practices in accordance with the UNGP on Business and Human Rights. Further, we maintain a toll-free hotline and website for reporting any questions or concerns relating to our Human Rights Policy.
Crossroads’ due diligence process for identifying and addressing risks of forced and child labour in our supply chain include:
Our suppliers are generally multinational corporations with established programs and management systems for preventing forced and child labour in their operations and supply chain consistent with Crossroads’ expectations. For these suppliers, our diligence process includes reviewing their codes of conduct and published compliance statements. We also continually monitor our suppliers for reports of identified risks or wrongdoing.
In 2023, we onboarded a new supplier with manufacturing operations in China. For this supplier, we obtained a declaration of compliance with our human rights policies and conducted an onsite visit to assess their operations.
Crossroads’ operations are solely in Canada and we have policies and practices in place to comply with all federal, provincial and local labour and employment laws and regulations. We have not identified a risk of forced or child labour in our operations.
We have assessed the overall risk of forced or child labour in our supply chain based on the place of manufacture of the products we purchase. As discussed above, where there is a heightened risk of non-compliance with our policies based on the place of manufacture, we will conduct enhanced due diligence of the supplier and its policies, compliance programs, and facilities.
We did not encounter a violation of human rights in our operations or supply chain in 2023, and therefore did not take measures to remediate any forced or child labour abuses, or the loss of income to vulnerable families resulting from measures taken to eliminate labour abuses.
As a condition of employment, we require all employees to review and comply with our Code of Business Ethics, and all employees, other than direct labour, complete ethics training annually. We track employee completion of this training and follow up directly with any employees that do not complete the training.
For questions regarding our Code of Business Ethics, Human Rights Policy, or Supplier Business Practices Policy, or our efforts to combat and prevent forced and child labour in our operations and supply chain, we provide direct guidance and training from our legal department.
Crossroads is committed to measuring and continuously improving the effectiveness of our program by continuing to:
In 2023 and beyond, Crossroads will continue to train and empower our employees to identify and raise human rights concerns. For our suppliers, we will continue to evaluate our portfolio to identify risks and conduct appropriate due diligence.
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