Introduction

Our Commitment

* In 2025, certain Great Canadian Entertainment Reporting Entities entered into definitive agreements to sell such entities, and/or all or substantially all of their assets, to various local First Nations. It is anticipated that these transactions will close in 2026, subject to all regulatory and customary closing conditions, upon which successful closing these entities will cease to be Great Canadian Entertainment “Reporting Entities”. For the purposes of this 2025 report, prior to such closings these remain included as Reporting Entities. More information on these transactions can be found at:  greatcanadian.com/news

As a corporation with a place of business and assets in Canada, with at least C$20 million in assets, at least C$40 million in revenue, and an average of at least 250 team members in at least two of the last two financial years, Great Canadian Entertainment fulfils the requisite tests of qualifying as a covered entity under the Supply Chains Act. As a covered entity, Great Canadian Entertainment is required to file this disclosure under the Act as it fills the requisite requirements of producing, selling, or distributing goods in Canada, importing goods into Canada that were produced outside of Canada, and/or controlling subsidiaries that are engaged in the foregoing.

In this disclosure, we set out the steps taken by Great Canadian Entertainment during the calendar year ended December 31, 2025, and describe the steps taken during 2025 to ensure our business was not knowingly involved in forced or child labour, as well as the actions we will continue to take to make sure we do not knowingly undertake business with any supplier involved in this fundamental human rights violation and exploitation of the vulnerable.

Our Required Disclosure

This disclosure details the steps taken by Great Canadian Entertainment during its 2025 calendar year to reduce and prevent the risk that child or forced labour was part of Great Canadian Entertainment’s supply chain, including Great Canadian Entertainment’s:

• Business, structure, and supply chains;
• Supplier policies and due diligence processes;
• Team member policies, training and management;
• Risk of using forced and child labour,
• Supply chain risk assessment;
• Supply chain risk management; and
• Remediation management, if required.

Our Business, Structure and Supply Chains

Our Business

Great Canadian Entertainment is Canada’s leading gaming and entertainment company with the largest and most diversified collection of gaming and hospitality destinations across the country. As of December 31, 2025, our twenty-three destinations in Ontario, British Columbia, Nova Scotia, and New Brunswick offer slot machines, live and electronic table games, restaurants, concert venues, racetracks, and hotels. Our company was established in 1982 as Great Canadian Casino Company with two charity casinos on the grounds of Vancouver’s Pacific National Exhibition. Since those humble beginnings, we remain steadfast in our commitment to provide exceptional entertainment experiences for our guests, rewarding opportunities for our team members, meaningful support for the communities where we live and work, and a commitment to responsible and ethical business operations. Our commitment to excellence informs everything we do. At the root of this legacy of exceptional service are over 7,600 team members who embody our values, operate with integrity, and possess an undeniable passion for fun and excitement.

Our Structure

Great Canadian Gaming Corporation is a British Columbia corporation, with multiple operating, holding and structural subsidiaries formed in jurisdictions in which we operate. One Toronto Gaming is an Ontario limited partnership formed between subsidiary entities of our parent, Apollo Global Management, and Brookfield Asset Management. As of December 31, 2025, Great Canadian Entertainment employs approximately 7,600 full time and part team members, who together serve all the Reporting Entities. All such team members are based in Canada. Our team members work in our headquarters located in North York, Ontario, both hybrid and remotely, as well as on site throughout our twenty-three destinations in the four provinces in which we operate.

Our Supply Chains

Great Canadian Entertainment has both domestic and international supply chains. Of our aggregate suppliers, 95% are Canadian, while only 5% are international. Of those goods that we source internationally, our non-Canadian supply chains include suppliers of:

• Regulated gaming equipment, including slot machines, electronic table games, table games, card shufflers, casino management system technology, casino cash management technology, and ancillary equipment;
• Non-gaming equipment related information technology hardware and licensed software; and
• Office supplies, promotional materials, uniforms, development equipment, and other equipment.

Regulated gaming equipment manufacturers, suppliers, and distributors comprised a significant portion of our aggregate supply chain in calendar year 2025, which are imported from:

• United States of America: 85%
• Malta: 15%

Such suppliers are highly regulated in their jurisdictions of operation, manufacture, distribution and supply by federal, state, provincial, other governmental, and quasi-governmental regulatory authorities with jurisdiction over such suppliers that undertake significant compliance and regulatory due diligence investigations of the corporate entities, directors, officers, and key employees prior to granting the privileged licenses, registrations and approvals required for their operations, manufacture, distribution and supply. Such regulatory authorities require ongoing affirmative disclosure by all such entities and individuals on a regular cadence, as well as strict adherence to regulatory compliance requirements governing the operation, manufacture, distribution, and supply of their goods. The balance of our supply chain is comprised of non-gaming related information technology related hardware and software, development, general equipment and food and beverage, which is imported from:

• United States of America: 96%
• Philippines: 2%
• Spain: 1%
• Other: <1%

Almost all such suppliers are required to take steps to prevent modern slavery and human trafficking, including forced and child labour, in their own businesses and supply chains, under applicable regulatory requirements in their resident and supply jurisdictions, including but not limited to those under the requirements of the United States Department of Health and Human Services, Administration for Children and Families, Office on Trafficking in Persons and the United Kingdom Modern Slavery Act 2015, among others.

In addition, Great Canadian Entertainment’s internal Environmental, Social and Governance (“ESG”) program collaborates with operational teams on everything from sustainability to social supply chain to community philanthropy initiatives. Ultimately overseen by senior management and the Board of Directors, we view ESG as a multidisciplinary risk mitigant, a solutions-oriented problem-solving team and an important component of our core values of integrity, service excellence, and connection to communities. Engaging in ethical and responsible procurement practices and improving social supply chain considerations has been identified as a material topic within our ESG framework.

We also promote supplier diversity, through memberships in organizations like Women Business Enterprise Council Canada (WBE Canada) and the Canadian Aboriginal and Minority Supplier Council (CAMSC), thereby amplifying our social impact. For example, One Toronto Gaming recently transitioned its hotel bulk amenities program to Mother Earth Essentials, a Canadian Indigenous-owned brand. This transition reinforces commitment to community investment and sustainable social procurement. Mother Earth’s founder comes from a long line of Cree Medicine women, and the brand reflects a strong connection to healing traditions and cultural heritage. Products are made with natural ingredients and inspired by traditional Indigenous teachings and plant knowledge, bringing a meaningful Canadian story into the guest experience.

In parallel, the company is advancing environmental sustainability and circularity through additional sustainable procurement transitions, including shifting select product categories to more sustainable paper product lines. Looking ahead, Great Canadian Entertainment will continue to evaluate opportunities across its properties and Reporting Entities to strengthen supply chain alignment with ESG-focused partners.

Our Supplier Policies and Due Diligence Process

We have zero tolerance of forced or child labour in any part of our business or in our supply chains. Great Canadian Entertainment regularly updates its supplier policies and due diligence processes to meet our commitment of ensuring there is no forced or child labour in our supply chains and operations.

Our Supplier Policies

Key criteria for doing business with Great Canadian Entertainment includes providing the best value in price and quality, understanding our industry, being financially stable, and being transparent about ethical business practices.

Service Provider Code of Conduct

In 2025, we increased supply chain transparency by presenting our Service Provider Code of Conduct online for vendors, the public and any other interested stakeholders at greatcanadian.com/service-provider-code-of-conduct. Our Service Provider Code of Conduct ensures a controlled, transparent, auditable, and compliant procurement service, which is approved by members of Senior Management. Under the Service Provider Code of Conduct, all suppliers, service providers, consultants, contractors, and licensees are required to undertake the following on their own behalf and on behalf of their subcontractors, agents, representatives, personnel, team members, and licensees:

• Adhere to all federal, provincial and other applicable laws;
• Maintain a workplace free from all forms of prohibited conduct, including harassment, and treat its personnel with dignity and respect;
• Ensure that no forced, child or involuntary labour, including bonded, indentured, involuntary prison labour or slave labour is used in its supply chain;
• Promote responsible sourcing practices throughout its supply chain;
• Uphold fair business standards in advertising, sales, and competition, including, without limitation, compliance antitrust and competition applicable laws;
• Neither engage in nor tolerate association with any form of corruption, bribery, extortion, or embezzlement;
• Report all conflicts of interest;
• Deliver all required certifications, including those regarding diversity, certificates of insurance, and in some instances, complete registrations with the applicable gaming regulatory authority; and
• Maintain Great Canadian Entertainment’s confidential information, among others.

Our Due Diligence Process

Our Procurement team recognizes the importance of strong supplier management and performance. To ensure all those in our supply chain comply with our values, we have a rigorous supply chain compliance program in place. Decisions on potential suppliers are taken based not only on price and delivery times, but other factors including the supplier’s privileged licenses in the jurisdictions in which it does business, the results of our due diligence investigations, the ability to perform its obligations while maintaining compliance with applicable laws, and, where the supplier has previously been engaged by us, and its prior attornment with our requirements. We are continually seeking to work with suppliers that meet all our values, which allows us to build strategic, long-term relationships.

Our Procurement team has implemented a Responsible Vendor Scorecard as part of our vendor pre-qualification process. As part of this Scorecard, vendors are assessed on various factors including whether: (i) they have policies in place addressing forced and child labour, modern slavery, and human trafficking, (ii) their sub-suppliers are also subject to this policy, and (iii) they have appropriate reporting mechanisms and training programs in place.

By the end of 2025, all vendors providing services to the Reporting Entities have been screened using the Responsible Vendor Scorecard. By working with Great Canadian Entertainment, suppliers must also comply with the Service Provider Code of Conduct as more particularly set forth above.

Our Procurement team works closely with our Legal, Compliance and Cybersecurity teams, to complete appropriate due diligence analyses to ensure that prospective suppliers are qualified to conduct business with Great Canadian Entertainment, which includes:

• A fulsome independent third-party background check of the supplier, as necessary;
• An assessment of potential operational risks that may be posed by the supplier;
• Validation that the supplier maintains appropriate insurance coverage; and
• Such other due diligence as necessitated by the regulatory, technological, financial, or geographic operations, provisions, or sourcing requirements of the supplier.
• On a periodic basis, our Internal Audit Department completes independent assessments related to such due diligence analysis and Great Canadian Entertainment’s adherence to its requirements.

Purchases from suppliers are generally made using either standardized contract forms or a standard set of purchase order terms and conditions, which typically include:

• An obligation on the supplier to comply with applicable laws;
• Audit rights for Great Canadian Entertainment or an independent third-party
  representative to verify the supplier’s compliance with the terms;
• A representation and warranty from the supplier that neither it nor any employee has been convicted of any forced or child labour offence, nor been the subject of any investigation into any alleged forced or child labour offence;
• A requirement to meet its compliance obligations as set out in our Supplier Code of Conduct; and
• The right for Great Canadian Entertainment to immediately terminate the agreement if the supplier breaches its compliance obligations, applicable laws, or the agreement.

Any supply agreements made on the supplier’s terms are reviewed and negotiated by our Procurement and Legal teams to ensure that the supplier is obliged to comply with all applicable laws and to include our required standard contractual provisions.

Our Team Member Policies, Training and Management

Our Team Member Policies

Our commitment to human rights is outlined and enforced in our team member policies and training, which collectively requires Great Canadian Entertainment’s team members to uphold the human rights of all persons. We do not knowingly conduct business with any individual or company that participates in the exploitation of children, including child labour, physical punishment, forced labour, or human trafficking.

Relevant corporate polices, approved by members of our senior management and applicable to all team members across Great Canadian Entertainment, reflect and enforce our commitment to conduct our business in a responsible and ethical manner.

They include:

• Corporate Team Member Handbook;
• Corporate Ethics and Conduct Manual;
• Human Trafficking Policy;
• Anti-Bribery and Corruption Policy;
• Anti-Discrimination Policy;
• Anti-Money Laundering Policy;
• Respectful Workplace Policy;
• Responsible Gaming Policy;
• Information Security Policy;
• Privacy and Privacy Breach Policy; and
• Whistleblower Policy.

Our policies, including links to educational and training resources where applicable, are available to all team members on our organization’s intranet site.

These policies and training programs express Great Canadian Entertainment’s commitment to a work environment that is safe and free from any kind of discrimination, harassment, intimidation and to conduct business in an ethical and honest manner. A breach of these policies may result in disciplinary action, including termination of employment.

The Whistleblower Policy encourages team members to report instances of actual or suspected unethical, illegal, or fraudulent conduct by our team members or third parties, which may include, without limitation, non-compliance with the Human Trafficking Policy, the Service Provider Code of Conduct, or other suspected or alleged instances of human trafficking or child or forced labour.

In 2025, Great Canadian Entertainment onboarded a new independent third-party vendor to manage and implement an updated whistleblower program for most sites, including an updated Whistleblower Hotline, to further extend Great Canadian
Entertainment’s commitment to an anonymous, secure, confidential way to report serious misconduct, compliance or unethical behaviour. We are also exploring new tools and technology to enhance reporting, specifically related to human trafficking, in our hospitality operations.

Our Team Member Training and Management

Great Canadian Entertainment has an established training program in place for our team members to build knowledge and apply understanding on all our policies. Each of our policies has specific related training and testing that must be successfully completed; new team members complete training within 30-days of hire and then annually.

Given Great Canadian Entertainment’s operations within the hospitality space, we have taken strides in recent years to increase our anti-human trafficking awareness. Our mandatory Human Trafficking Policy and Preventing Human Trafficking training module works enterprise-wide to support upskilling our team members to recognize and respond to potential signs of human trafficking, which includes training on child and forced labour particularly in our hospitality venues. All incumbent team members were required to complete this training within 90-days and are required to complete the refresher module on an annual basis. In 2025, our team members across Canada completed 1,946 hours of Human Trafficking Policy training representing a significant year-over-year increase.

Our commitment to operating ethically and in alignment with our policies, such as the Whistleblower Hotline, Human Trafficking Policy and related training, are further reinforced through our Corporate Ethics & Conduct Manual, which is reviewed annually and updated as needed. Team members review and acknowledge their understanding each Spring. This manual details team members’ commitment to working in alignment with our polices and their obligation to report behaviour that is in contravention of policy or law.

Great Canadian Entertainment is continually reviewing its team member policies and trainings, including those that relate to responsible and ethical sourcing or forced labour, to ensure that we are providing our team members with the skills, training and information that represents our organization’s fundamental values.

Our Risk of Using Child and Forced Labour

We are aware that our global supply chain, as well as the industry in which we operate, presents a risk of child and forced labour.

Great Canadian Entertainment maintains a robust Compliance team, led by our General Counsel & Chief Administrative Officer, with Compliance team members located regionally. These team members, together with our Procurement, Legal and Cybersecurity teams ensure new business initiative analysis is undertaken and suppliers to such initiatives undergo appropriate robust due diligence analysis, including risks regarding child and forced labour, to ensure that prospective suppliers are qualified to conduct business with Great Canadian Entertainment.

Purchases from suppliers are generally made using either standardized contract forms or a standard set of purchase order terms and conditions, both of which include an obligation on the supplier to comply with applicable laws, audit rights for Great Canadian Entertainment or an independent third-party representative to verify the supplier’s compliance with the terms of such contract or purchase order, and the right of Great Canadian Entertainment to terminate such agreement in the event of non-compliance. Please also refer to our Service Provider Code of Conduct section above.

In the aggregate, our compliance, due diligence, contractual, audit, and termination requirements mitigate the opportunity for and risk of child and forced labour existing in our supply chain.

Our Supply Chain Risk Management

As set forth through the measures outlined above, Great Canadian Entertainment is committed to working with its suppliers to evaluate, monitor and strengthen compliance with applicable laws regarding forced labour in supply chains and to evaluate opportunities for risk elimination. Our Procurement, Legal, Compliance and Operations teams are vigilant in their communications with our suppliers, as well as representatives in the industry, to remain aware of our suppliers’ conduct. Our suppliers are required to monitor and report their own non-compliance or violations in accordance with the Service Provider Code of Conduct, which will be escalated to both the Compliance and Legal teams as necessary.

In addition, Great Canadian Entertainment encourages the reporting of any activity inconsistent with our policies by our team member or third parties, including our Corporate Ethics and Conduct Manual, and any incidents of suspected child and forced labour or human trafficking.

Our updated Whistleblower Hotline is available twenty-four hours a day, seven days a week to all team members. Reporters to the Whistleblower Hotline may call a toll-free number, use an online, secure web portal, or scan an easy-to-use QR Code, available to all team members to quickly and easily log into the platform from a mobile device, to report any misconduct or inappropriate behaviour. Reporters may elect to remain anonymous or provide contact information; in both cases the improved whistleblower platform provides the reporter with a ‘key’ that will provide access to relevant updates throughout the investigation to the reporter. In all instances, we will protect anyone suspected of being victims of or witnesses to prohibited activities. Great Canadian Entertainment has a zero-tolerance policy against retaliation. Any team member who violates this policy will be subject to appropriate discipline or termination of employment.

We will also cooperate fully with any child and forced labour or trafficking-related audits and investigations by any regulatory authority, including providing reasonable access to our facilities and staff.

Our Supply Chain Risk Assessment

Our assessment of our operational and supply chain risk falls within a broader enterprise-wide risk management framework, which is reviewed by our Chief Executive Officer and our Senior Management on a quarterly basis. This process is designed to assist our organization in appropriate risk management through a systematic approach for evaluating, measuring, and monitoring key risks, including regulatory compliance, prioritize risk management activities, and develop a risk-based internal audit plan.

In addition, we are continually reviewing our pillars of governance, policy accountability, compliance and due diligence obligations, team member engagement, enterprise risk management, auditing, and investigation mechanisms to determine appropriate improvements to organizational obligations and requirements to limit risks within our supply chain.

Managing Remediation

To date, Great Canadian Entertainment has faced no known situations of forced labour or child labour in its business or supply chains and therefore has not had to remedy or rectify such situations internally, with our suppliers, or remediate vulnerable families’ loss of income resulting from the elimination of labour abuses in its supply chains. In the event that Great Canadian Entertainment faces such situations in the future:

• With our team members, we will take all appropriate conduct available under policy and applicable law, with may include, without limitation, discipline up to and including termination, and reporting to and enforcement by applicable regulatory or other governmental authority;
• With our suppliers, we will consider all courses of action available under the Service Provider Code of Conduct, contract, and applicable law, which may include, without limitation, termination of all contractual arrangements with such supplier, pursuit of all remedies available at law or equity, including injunctive relief and damages, and reporting to and enforcement by applicable regulatory or other governmental authority; and
• If impacting vulnerable families’ loss of income resulting from the elimination of labour abuses in supply chains, we will consider all appropriate conduct to materially remediate such loss of income.

Board Approval and Attestation

Board Approval

This disclosure has been approved by the board of directors of Raptor Parent Corp. and Great Canadian Gaming Corporation, on behalf of its subsidiaries and affiliated operating entities, and the board of directors of 2569129 Ontario Inc. in its capacity as General Partner of Ontario Gaming GTA Limited Partnership.

Attestation

In accordance with the requirements of the Act, and in particular Section 11 thereof, I attest that I have reviewed the information contained in this disclosure for Great Canadian Gaming Corporation, on behalf of the Reporting Entities. 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 2025 reporting year, as of February 10, 2026.

Signed by Jordan Banks
Executive Chairman of the Board Raptor Parent Corp.
Date: 03/26/2026

Signed by Matthew Anfinson
Chief Executive Officer & Director Great Canadian Gaming Corporation
Date: 03/26/2026

Signed by David Nowak
Chairman of the Board 2569129 Ontario Inc. in its capacity as General Partner of Ontario Gaming GTA Limited Partnership
Date: 03/26/2026