FINAL Toxics Substance Reduction Plan Summary for Chromium (CAS# ) and Nickel (CAS# ) th Line, Bradford, ON L3Z 2A5

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1 Toxics Substance Reduction Plan Summary for Chromium (CAS# ) and Nickel (CAS# ) th Line, Bradford, ON L3Z 2A5 Prepared for: Dortec Industries, Magna Closures th Line Bradford, ON, L3Z 2A5 Attn: Gina Redgrave Environmental, Health & Safety Specialist November 15, 2017 Pinchin File: Pinchin Ltd.

2 INTRODUCTION Facility Summary Dortec Bradford (Dortec) manufactures engineered metal products and assembles window regulators for the automotive industry using stamping and assembly processes. The manufacturing equipment employed onsite for metal parts machining primarily consists of stamping presses, and resistance, laser and metal inert gas ( MIG ) welders. Steel (hot rolled and stainless alloys) is received for use in coils. After forming and machining, parts are then sent to assembly. In addition, window regulators are assembled with pre-fabricated components such as motors, cables, fasteners, gears and rails. Finished products are packaged and stored onsite prior to transport. Dortec Bradford s Environmental Management System (EMS) has been certified to the ISO standard since 1998 and mostly recently recertified on August 11, Dortec Bradford is actively engaged in seeking environmentally sustainable opportunities, such as: Waste Diversion of 88% Electricity reduction Recycling of the Sodium Hydroxide used in the tumbler Magna International Inc. Magna International Inc. (Magna) is a leading global automotive supplier with 327 manufacturing operations and approximately 100 product development, engineering and sales centers in 29 countries. Magna has over 161,000 employees focused on delivering superior value to its customers through innovative products and processes, and world class manufacturing. Magna has complete vehicle engineering and contract manufacturing expertise, as well as product capabilities which include body, chassis, exterior, seating, powertrain, active driver assistance, vision, closure and roof systems and have electronic and software capabilities across many of these area. Its common shares trade on the Toronto Stock Exchange (MG) and the New York Stock Exchange (MGA). For further information about Magna, visit our website at Innovation has long been a key driver within Magna, focusing on internal process efficiencies and products. Magna's Health, Safety & Environmental Policy states that innovative design and engineering are to be utilized to reduce the environmental impact of Magna's products during vehicle operation and at end of life. It also states that Magna facilities are to improve the efficient 2017 Pinchin Ltd. Page i

3 use of natural resources (including energy); minimize waste streams and emissions; and implement effective recycling programs in its manufacturing operations. In addition, the majority of Magna s facilities in Ontario are ISO certified with site specific targets and objectives. Magna is committed to a variety of R&D activities, which include work on green and fuel efficient technologies Pinchin Ltd. Page ii

4 TABLE OF CONTENTS 1.0 BASIC FACILITY INFORMATION STATEMENT OF INTENT SUBSTANCES REQUIRING PLANS OBJECTIVES OF THE PLAN & ANY TARGETS OPTIONS TO BE IMPLEMENTED (OR STATEMENT THAT NONE ARE TO BE IMPLEMENTED) CONTENTS OF THIS PLAN SUMMARY REFLECTS PLAN TERMS AND LIMITATIONS... 3 APPENDICES APPENDIX I APPENDIX II APPENDIX III APPENDIX IV APPENDIX V Process Flow Diagrams Tracking & Quantifications Financial Accounting Planners Recommendation & Rationale Regulatory Requirements Plan Checklists 2017 Pinchin Ltd. Page iii

5 1.0 BASIC FACILITY INFORMATION Substance Information Name Chromium CAS # 74-3 Name Chromium CAS# Company Name Facility Address Site Coordinates (main entrance of site) th Line, Bradford, ON L3Z 2A E, N; Zone 17 NPRI ID MOE ID Number of Full-Time Employees in Digit NAICS Code 4-Digit NAICS Code 6-Digit NAICS Code N/A Manufacturing 3363 Motor Vehicle Parts Manufacturing Other Motor Vehicle Parts Manufacturing Parent Company Information Company Name Company Address Percent Ownership by Parent Company Magna International Inc. 337 Magna Drive, Aurora (Ontario) 100% Business Number Pinchin Ltd. Page 1 of 5

6 Facility Contact Information Public Contact Tracy Fuerst Director, Corporate Communications and Media Relations Phone: (248) Magna International Inc. 337 Magna Drive Aurora, ON L4G 7K1 2.0 STATEMENT OF INTENT In accordance with Magna s Corporate Health, Safety & Environmental (HSE) Policy ( and Dortec s ISO Environmental Policy, we are committed to an operating philosophy based on fairness and concern for employees, customers and the communities in which we operate. Magna s objective as expressed in the HSE Policy is to be an industry leader in health, safety and environmental practices in all of our operations with the intention, through technological innovation and process efficiencies, to minimize the impact of our operations on the environment and to provide safe and healthful working conditions. In keeping with Magna s decentralized organizational structure, facilities are responsible for setting site specific objectives and targets under their ISO system and to meet the objectives within the Magna HSE Policy to: improve the efficient use of natural resources, including energy; minimize waste streams and emissions; and implement effective recycling programs in our manufacturing operations, through the use of locally set continuous improvement targets. With reference to the Ontario Toxics Reduction Act, the reduction objectives are outlined in Section 4 of this Plan for the reportable substances (Chromium & Nickel) at Dortec. 3.0 SUBSTANCES REQUIRING PLANS The substances requiring plans are Chromium and Nickel is based on 2016 Toxics Reduction Act accounting information. Chromium and Nickel is contained in the metals and welding consumables used at the facility. 4.0 OBJECTIVES OF THE PLAN & ANY TARGETS No options have been identified, and as part of the continuous improvement practices at the facility, technical advances will be monitored for new opportunities to reduce the use of Chromium at the facility Pinchin Ltd. Page 2 of 5

7 5.0 OPTIONS TO BE IMPLEMENTED (OR STATEMENT THAT NONE ARE TO BE IMPLEMENTED) Due to the nature of the processes, the use of Chromium and Nickel as a component of metal is an inevitable part of the process of automotive parts manufacturing As such, no technically feasible options were identified or were applicable and therefore no options will be implemented at this time. The facility will continue to monitor areas for further improvement. 6.0 CONTENTS OF THIS PLAN SUMMARY REFLECTS PLAN This Plan Summary accurately reflects the Toxic Substance Reduction Plans dated November 15, 2017, prepared for the substances listed in Section 1.0 of this Summary. 7.0 TERMS AND LIMITATIONS This work was performed subject to the Terms and Limitations presented or referenced in the proposal for this project. Information provided by Pinchin is intended for Client use only. Pinchin will not provide results or information to any party unless disclosure by Pinchin is required by law. Any use by a third party of reports or documents authored by Pinchin or any reliance by a third party on or decisions made by a third party based on the findings described in said documents, is the sole responsibility of such third parties. Pinchin accepts no responsibility for damages suffered by any third party as a result of decisions made or actions conducted. No other warranties are implied or expressed Pinchin Ltd. Page 3 of 5

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9 CERTIFICATION BY LICENSED PLANNER As of [select date], I, Ajay Madan, TSRP#0010 certify that I am familiar with the processes at Dortec Industries, Magna Closures that use or create the toxic substances referred to below, that I agree with the estimates referred to in subparagraphs 7 iii, iv and v of subsection 4 (1) of the Toxics Reduction Act, 2009 that are set out in the toxic substance reduction plans referred to below for the toxic substances and that the plans comply with that Act and Ontario Regulation 455/09 (General) made under that Act. Chromium ( ) Nickel ( ) Planner: Ajay Madan, TSRP#0010 Senior Project Engineer amadan@pinchin.com J:\119000s\ MAGNAINTERNAT,375MagnaDrive,ENVNS,ENRPT\ MAGNAINTERNAT,3066Line8ON,ERC,ENRPT\Deliverables\ TRA Plan Summary th Line, Bradford Dortec Nov. 15, 2017.docx Template: Master Report for Toxics Substance Reduction Plan, ERC, June 27, Pinchin Ltd. Page 5 of 5