North American Construction Group (NOA) details 2025 forced labour risk review

Rhea-AI Filing Summary

North American Construction Group Ltd. filed a Form 6-K furnishing its 2025 Supply Chains Report under Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act. The report explains that NACG operates mining and heavy civil construction services in Canada, the United States and Australia, with suppliers also located in those countries.

The company describes its Code of Conduct and Ethics Policy, which includes an anti-slavery commitment, annual employee attestations, anonymous reporting channels, and contractual clauses requiring suppliers to comply with laws on forced and child labour. After assessing its operations and long‑term supplier relationships, NACG concludes it does not identify a calculable risk of forced or child labour in its business or supply chains and therefore has not implemented specific remediation measures.

The report highlights mandatory orientation training covering awareness of forced and child labour risks and ongoing monitoring of policies. It is approved by the Board of Directors and formally attested and signed by President and Chief Executive Officer Barry Palmer, and it also covers two related partnerships listed in an appendix.

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM 6-K

Report of Foreign Private Issuer

Pursuant to Rule 13a-16 or 15d-16

under the Securities Exchange Act of 1934

For the month of March 2026

Commission File Number 001-33161

NORTH AMERICAN CONSTRUCTION GROUP LTD.

27287 - 100 Avenue

Acheson, Alberta T7X 6H8

(780) 960-7171

(Address of principal executive offices)

Indicate by check mark whether the registrant files or will file annual reports under cover of Form 20-F or Form 40-F.

Form 20-F  o            Form 40-F  ý

Indicate by check mark if the registrant is submitting the Form 6-K in paper as permitted by Regulation S-T Rule 101(b)(1):  o

Indicate by check mark if the registrant is submitting the Form 6-K in paper as permitted by Regulation S-T Rule 101(b)(7):  o

Indicate by check mark whether by furnishing the information contained in this Form, the registrant is also thereby furnishing the information to the Commission pursuant to Rule 12g3-2(b) under the Securities Exchange Act of 1934.

Yes  o                 No  ý

If “Yes” is marked, indicate below the file number assigned to the registrant in connection with Rule 12g3-2(b): 82-                

Documents Included as Part of this Report

No.						News Release
99.1						2025 Anti-Slavery Report

SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

NORTH AMERICAN CONSTRUCTION GROUP LTD.
By:			/s/ Barry Palmer
Name:			Barry Palmer
Title:			President & Chief Executive Officer

Date: March 11, 2026

Exhibit 99.1

NORTH AMERICAN CONSTRUCTION GROUP LTD.

SUPPLY CHAINS REPORT

March 11, 2026

REPORT PURSUANT TO THE

FIGHTING AGAINST FORCED LABOUR AND CHILD LABOUR IN SUPPLY CHAINS ACT

January 1, 2025 – December 31, 2025

Introduction

North American Construction Group Ltd. (“NACG”) is committed to acting ethically and with integrity in all of our business dealings and relationships and, as part of that, to working collaboratively with our suppliers and contractors to identify and reduce the risk of forced labour or child labour occurring anywhere within our supply chains.

NACG expects our suppliers and contractors to operate in accordance with all applicable anti-slavery laws, including those prohibiting human slavery and slavery-like practices, human trafficking, forced labour and child labour, and particularly including Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “Act”).

Structure, Activities and Supply Chains

NACG is incorporated pursuant to the Canada Business Corporations Act, with our head office located in Acheson, Alberta and our registered office located in Edmonton, Alberta. Our shares are publicly traded on the Toronto Stock Exchange (NOA.TO) and on the New York Stock Exchange (NOA). Our business is primarily carried out through our subsidiaries.

NACG provides a wide range of mining and heavy civil construction services to customers in the resource development and industrial construction sectors within Australia, Canada, and the United States. A significant portion of our services are focused on supporting the construction and operation of surface mines. We are considered to be a "first-in, last-out" service provider because we provide services through the entire lifecycle of projects. Our work typically begins with the initial consulting services provided during the planning phase, including a review of constructability, engineering and budgeting. This leads into the construction phase during which we provide an expanded range of services, including clearing, road construction, site preparation, underground utility installation and mine infrastructure construction, including construction of tailings ponds, access roads, stabilized earth walls and earth dams. As our mining customers move into

Since 1953 • Heavy Construction & Mining

27287 – 100 Avenue Acheson, Alberta, Canada T7X 6H8 Phone 780.960.7171 Fax 780.969.5599

www.nacg.ca

production, we support the long-term operation of the mine by providing ongoing site maintenance and upgrading, equipment and labour supply, overburden removal, material hauling and land reclamation.

As at December 31, 2025, including our subsidiaries, NACG had approximately 1,431 salary or hourly employees in our Canadian and U.S. operations and approximately 1,532 salary or hourly employees in our Australian operations. Our hourly workforce fluctuates according to the seasonality of our business and the staging and timing of projects by our customers.

As of December 31, 2025, we directly operated a heavy equipment fleet of 938 units; approximately 82% were owned, 17% were leased and 1% were rented. This fleet is supported by over 1,100 pieces of ancillary equipment. In addition to this, the joint ventures we operate owned and leased fleets totaling 230 heavy equipment units for a combined total, excluding rented equipment, of 1,155 heavy equipment units.

Almost all of NACG’s procurement relates to purchases of mining and construction equipment or parts and supplies related to such mining and construction equipment. NACG deals with reputable, well-established suppliers of such equipment, parts and supplies and has forged long term relationships with our most important suppliers. All of our suppliers are located in Canada, the United States or Australia. NACG continues to engage collaboratively and diligently with all of our suppliers with respect to recognizing and reporting any risk of forced labour or child labour that may arise within our supply chain.

Policies and Due Diligence Processes related to Forced Labour and Child Labour

NACG’s Code of Conduct and Ethics Policy (the “Code”) sets out the ethical standards that each and every NACG employee, officer, director, agent and representative is bound to follow and comply with. It also contains NACG’s anti-slavery policy, which states:

“NACG strives to promote the highest standards of ethical conduct throughout its supply chain. We are committed to mitigating the risk that forced labour or child labour is used at any step of the production of goods imported by us into Canada. We adhere to, and takes steps to ensure our suppliers and contractors adhere to, the most stringent of prevailing national laws and recognized

Since 1953 • Heavy Construction & Mining

27287 – 100 Avenue Acheson, Alberta, Canada T7X 6H8 Phone 780.960.7171 Fax 780.969.5599

www.nacg.ca

international standards relating to modern slavery and human trafficking. NACG will not knowingly use forced labour in the provision of any of our services nor will we knowingly accept products or services from vendors or contractors that employ or utilize forced labour.”

The Code is posted to our internal and external corporate websites for easy access. Our internal and external websites also provide links that allow anyone to anonymously report behavior in contravention of the Code. NACG requires all salaried and non-union hourly employees to reaffirm their compliance with, and understanding of, the Code on an annual basis.

NACG requires all of our suppliers and contractors to adhere to NACG’s standards relating to compliance with laws and ethics as a contractual term in each of NACG’s purchase orders. Such standards require NACG’s suppliers and contractors to:

(a)be in, and at all times remain in, full compliance with all applicable laws, including laws related to child labour, forced labour and human trafficking;

(b)confirm that they have not and will not engage in any activity, practice, or conduct that would constitute an offense under any such laws; and

(c)have in place policies and procedures adequate to ensure compliance with all such laws by its officers, employees, agents and any other third parties or persons associated with the supplier or contractor in the provision of goods or performance of services.

Such obligation of compliance imposed by NACG on our suppliers and contractors is applicable in all jurisdictions in which NACG or the suppliers and contractors operate. If NACG receives credible evidence that any supplier or contractor has not complied with its obligations in that regard, by the terms of NACG’s purchase orders, NACG may: (i) terminate any services; (ii) refuse to take delivery of any goods or services; and (iii) return any goods already delivered, with reimbursement.

Since 1953 • Heavy Construction & Mining

27287 – 100 Avenue Acheson, Alberta, Canada T7X 6H8 Phone 780.960.7171 Fax 780.969.5599

www.nacg.ca

The Risk of Forced Labour and Child Labour in our Business and Supply Chains

NACG has undertaken an assessment of potential forced labour and child labour in our operations and supply chains. Key factors of the assessment included risks related to the geographic areas from where we purchase heavy equipment parts and supplies for importation into Canada. From our assessment, and in light of the long-term ongoing relationships that NACG has with our equipment and parts suppliers, as well as the nature of the processes required to produce such heavy equipment, parts and supplies, NACG has concluded that we do not believe there to be a calculable risk of forced labour or child labour within our business or supply chains.

Remediation Measures

As a result of the determination by NACG that there is no identifiable risk in our operations, business or supply chains of forced labour or child labour. NACG has not taken any special measures to remediate any issues of forced labour or child labour or any measures to remediate the loss of income to vulnerable families that may result from any measure taken to eliminate the use of forced labour or child labour.

Training of NACG Employees

NACG provides mandatory orientation training to all employees upon their hire or rehire. This mandatory formal training for our new employees is presented in an online format containing slides and information related to awareness and identification of the possibility of the use of forced labour and child labour. In addition, NACG’s new employee training emphasizes every employee’s awareness of, adherence to and compliance with the Code.

Organization Assessment of Effectiveness of Policies Related to Forced labour and Child Labour

NACG continually monitors and improves where necessary all employee and organizational policies as any deficiencies are discovered.

Since 1953 • Heavy Construction & Mining

27287 – 100 Avenue Acheson, Alberta, Canada T7X 6H8 Phone 780.960.7171 Fax 780.969.5599

www.nacg.ca

Approval and Attestation

This Report has been approved by the Board of Directors of North American Construction Group Ltd.

In accordance with the requirements of the Act, and in particular Section 11 thereof, I attest that I have reviewed the information contained in the Report for North American Construction Group Ltd. and on behalf of the wholly owned subsidiary and partnerships listed in Appendix A attached hereto. 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 aspects for the purposes of the Act, for the reporting year January 1, 2025 to December 31, 2025.

Signed this 11th day of March, 2026, by Barry Palmer, Director, President & Chief Executive Officer of North American Construction Group Ltd.

/s/ Barry Palmer

Name: Barry Palmer

Title: Chief Executive Officer

I have the authority to bind North American Construction Group Ltd.

Since 1953 • Heavy Construction & Mining

27287 – 100 Avenue Acheson, Alberta, Canada T7X 6H8 Phone 780.960.7171 Fax 780.969.5599

www.nacg.ca

APPENDIX A

In accordance with the provisions of The Fighting Against Forced Labour and Child Labour in Supply Chains Act, North American Construction Group Ltd. submits this Report on its own behalf and jointly with the following entities, as that term is defined in the Act:

1.ML Northern Services Limited Partnership

2.North American Enterprises Limited Partnership

Since 1953 • Heavy Construction & Mining

27287 – 100 Avenue Acheson, Alberta, Canada T7X 6H8 Phone 780.960.7171 Fax 780.969.5599

www.nacg.ca

FAQ

What does North American Construction Group (NOA) disclose in its 2025 supply chain report?

North American Construction Group details its 2025 assessment of forced and child labour risks in its operations and supply chains. It outlines governance, supplier standards, employee training, and concludes it does not identify a calculable risk under Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act.

Which operations and suppliers are covered in NOA’s forced labour and child labour report?

The report covers North American Construction Group’s mining and heavy civil construction operations in Canada, the United States and Australia. It states that almost all procurement involves equipment, parts and supplies sourced from reputable suppliers located in these three countries, with long-term commercial relationships.

What policies does North American Construction Group (NOA) use to address forced and child labour risk?

North American Construction Group relies on its Code of Conduct and Ethics Policy, which includes an anti-slavery commitment. Employees annually reaffirm compliance, and supplier contracts require adherence to all applicable laws on child labour, forced labour and human trafficking, with rights to terminate or reject non‑compliant goods or services.

How does NOA train employees on forced labour and child labour issues in its supply chains?

North American Construction Group provides mandatory online orientation training for all new or rehired employees. This training covers awareness and identification of possible forced and child labour, and reinforces employees’ obligations to follow the Code of Conduct and Ethics Policy throughout the organization.

What conclusion does North American Construction Group reach about forced labour risk in 2025?

After assessing supplier locations, relationships and production processes, North American Construction Group states it does not believe there is a calculable or identifiable risk of forced or child labour in its operations or supply chains for 2025. Consequently, it reports no special remediation measures taken during the period.

Who approved and signed North American Construction Group’s 2025 supply chain report?

The Board of Directors of North American Construction Group approved the report. President and Chief Executive Officer Barry Palmer formally attested that, based on his knowledge and reasonable diligence, the information for January 1, 2025 to December 31, 2025 is true, accurate and complete for purposes of the Act.

Filing Exhibits & Attachments

1 document

Press Releases

• EX-99.1 EX-99.1 32.2 KB