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Accessibility

1. Summary

On June 1st, 2023, Canadian National Railway Company (CN) published our first Accessibility Plan under the Accessible Canada Act (“the Act”). The goal of this plan is to remove existing barriers to accessibility at CN and to prevent new ones from being created in the future. As part of this plan, we set 18 detailed goals for ourselves. They aim to improve accessibility across multiple areas of our organization. These detailed goals vary, such as changing the format we use to publish documents on our website to a more accessible format, and updating our equity statement in our job postings to better include the disability community. We set timelines for each goal to reflect the different nature of each project.

After we published our Accessibility Plan, CN leaders and team members from across the country started working toward these goals. To begin, we started tracking the projects that were in progress and those that had been completed. We determined who would lead the work in each area, and the indicators we would use to measure our progress. Actions like reviewing our policies, forming task forces, and conducting research on best practices were important first steps in working toward many of our goals. In March 2024, we distributed a survey to all our employees across Canada to get feedback on our progress in achieving our accessibility goals. This survey generated nearly 400 responses, many of which contained thoughtful and informative feedback that we will incorporate into our work.

CN is pleased to share our first annual Progress Report with the public. This report contains updates about the progress we have made in achieving our goals. It also outlines the work we plan to do going forward, and any takeaways we have learned along the way that will inform our progress.

Of our 18 accessibility goals, we are proud to have completed and/or made progress on several of them this year. We have also made significant progress toward many of our other goals, which will be outlined in this Progress Report.

2. General

2.1 CN’s Statement of Commitment

Diversity, equity, and inclusion are strongly held values at CN, and we are committed to being open and welcoming to everyone. We recognize that the nature of our industry can pose barriers for our employees and customers. We are dedicated to removing those barriers whenever possible. We are also committed to doing this work in consultation with people who have disabilities. We recognize that people with disabilities are the experts when it comes to accessibility and so we will listen to their feedback as we move forward with the goals outlined in this plan. We also recognize that accessibility is a process and does not have an end point.

When we developed our first Accessibility Plan, we proactively looked for accessibility barriers at our organization and made plans to remove the barriers that were discovered. We are also committed to making changes not outlined in this plan if new information about barriers becomes available. We will always try to do better and to improve accessibility across all aspects of CN.

Through our annual Progress Reports, like this one, we are sharing our progress in meeting our accessibility goals as we laid them out in our Accessibility Plan. These Progress Reports also help us to show our accountability to our employees and to the public for keeping up the work we have been doing to remove barriers to accessibility at CN.

2.2 Description of CN Rail

CN is a publicly-traded transportation and logistics company operating in Canada and the United States. We operate rail (trains), trucking, and marine (boat) transportation all over North America. CN works with its customers to ship goods on time and safely. CN does not transport people. We also educate our communities and the public on how to stay safe around the railway. Members of the public might interact with us through our website, through interactions with the CN police force, or through contacting us by e-mail or phone. CN has been operating trains in Canada for over 100 years. We have over 2,000 locations and more than 18,000 employees in Canada. Most of our employees work jobs that involve some physical work or work outdoors in a variety of weather conditions. This includes people who operate the trains, and work in our railyards. Many of the locations that we work out of are industrial in nature and would be difficult to make fully accessible for all people. For example, in our rail yards, employees must be able to step over the train tracks to move around and service the train. Some employees work in our corporate offices. Office employees are currently working in a hybrid model, doing some work from home and some work from our office spaces.

2.3 How to Contact Us or Provide Feedback

CN invites feedback from our employees, stakeholders, and members of the public about our accessibility and our progress in achieving our goals.

If you would like to share your feedback with us, you can contact the Manager, Equity and Reporting in the following ways:

  • by email at accessibility@cn.ca
  • by phone at 833-399-5979
  • by mail at the following address: 935 de La Gauchetière Street West, Montréal, Québec, H3B 2M9

We also accept feedback through our website, https://www.cn.ca/en/contact-us, and through our social media channels.

We will respond to let you know that we received your feedback. We will not respond to feedback that is submitted anonymously (without providing a name or contact information). We will store a copy of all the feedback we receive, in a central location, for at least 7 years. We will report on the feedback we receive in future years’ progress reports and will use the feedback to develop future accessibility plans.

2.4 How to Request Alternate Formats

This Progress Report and a description of our feedback process are available in alternative formats by request. To request a copy of this report in a different or more accessible format, you can contact the Manager, Equity and Reporting in the following ways:

  • by email at accessibility@cn.ca
  • by phone at 833-399-5979
  • by mail at the following address: 935 de La Gauchetière Street West, Montréal, Québec, H3B 2M9

We will respond to requests for other formats as soon as we are able. For each alternative format, CN commits to providing them within a certain number of days:

  • Print: available within 15 days of the initial request.
  • Large print (Increased font size): available within 15 days of the initial request.
  • Braille (a system of raised dots that people who are blind or who have low vision can read with their fingers): available within 45 days of the initial request.
  • Audio (a recording of someone reading the text out loud): available within 45 days of the initial request.

2.5 Definitions

The following definitions apply throughout this plan:

  • Disability: Any impairment, or difference in physical, mental, intellectual, cognitive, learning, or communication ability. Disabilities can be permanent, temporary, or can change over time.
  • Barrier: Anything that might hinder people with disabilities' full and equal participation. Barriers can be architectural, technological, attitudinal, based on information or communications, or can be the result of a policy or procedure.
  • Accessibility: The design of products, devices, services, environments, technologies, policies, and rules in a way that allows all people, including people with a variety of disabilities, to access them.

3. Areas Described under Section 5 of the ACA

3.1 Organization-Wide Initiatives

In our Accessibility Plan, we set two goals that apply broadly to CN as a whole company. These goals aim to increase knowledge about accessibility and disability across our organization. These goals are:

3.1.1 By June 2026, CN will launch an awareness campaign to all employees on accessibility.

3.1.2 By June 2026, CN will improve training for managers on disability management and accommodations.

These are both longer-term goals for our organization, and they will involve the input and hard work of people from across CN’s many departments and teams. We still aim to complete both these goals by June 2026. We look forward to providing more detailed updates about our progress as we get closer to our timeline for implementing these goals.

3.2 The Built Environment

We have committed to several goals relating to the built environment at CN. These involve diverse facilities like office buildings, railyards, and repair facilities. Our work to reduce barriers to accessibility within these facilities must therefore be diverse as well. Below are the goals that we have committed to that relate to the built environment, and updates on the progress we have made in achieving these goals.

3.2.1 Over the next 3 years, CN will review and update our emergency evacuation plans and share them with all employees. The updated procedures will include instructions for what people with disabilities should do in the event of an emergency.

We have revised the evacuation plan for our Montreal head office to make it more equitable for employees with reduced mobility. We have also updated our employee handouts and posters to reflect these new procedures, and we have placed copies in both English and French in the boardrooms and kitchens on every floor of the building.

The policy changes implemented at the Montreal office will be applied similarly to evacuation plans across our system, and other sites will be updated in similar ways. As we conduct our regular scheduled evacuation exercises this year, we will be training employees on these new procedures. Our upcoming Floor Warden training will pay special attention to these changes.

We are also working on a project to create portable evacuation kits to assist with the evacuation process. This project will include developing training videos to walk employees through the evacuation process, with a specific section on the new procedures for employees with reduced mobility. These videos will be included in our onboarding process and will also be uploaded to our My360 employee resource system so that employees visiting or transferring to other sites can learn the evacuation procedures specific to their new location.

3.2.2 Starting in June 2025, CN commits to making sure that all the new buildings we build, acquire, or lease will be as accessible as possible. We will consider accessibility through all stages of planning, procuring, designing, and building the new location. We will also make sure that accessibility is a primary consideration anytime we do a major renovation in one of our existing locations.

We received important feedback on this topic in the responses to this year’s employee survey, including information about barriers that exist in some office buildings, railyards, and other workspaces. We will be including this feedback as we begin to work on this goal in 2025.

3.3 Employment

CN is proud to be a major employer in Canada, and we have over 18,000 employees across the country. Around five percent of our employees self-identify as having a disability, and we are committed to making sure they feel safe and supported at work. We want to encourage more people with disabilities to become employees at CN, and we want to make the job application and hiring processes more accessible. Below are our goals that relate to employment at CN, and updates on the progress we have made in achieving these goals.

3.3.1 By the end of June 2023, CN will update our equity statement and make sure that it appears in all job postings.

We have updated our equity statement to better include the disability community and express our commitment to accessibility. We have added this equity statement to our external job posting website. We have also started including this equity statement in our job postings, along with a statement informing candidates how they can request an accommodation during the application process:

“If you require an accommodation for the recruitment process (including alternate formats of materials, accessible meeting rooms or other accommodations), please reach out to our team at cnrecruitment@cn.ca.”

Now, candidates seeking to apply at CN can more easily learn about our commitment to a diverse workforce, and how to get an accommodation if they need one.

3.3.2 By June 2024, CN will improve our process for employee self-identification and reporting. This is the process we use to find out how many people in our workforce have a disability. We will make improvements to this process by making sure employees know why we are asking these questions, telling employees what will be done with the information, and making sure employees know that their information is confidential. We will also make sure that we give opportunities for employees to self-identify multiple times.

We are committed to supporting our employees in disclosing their disabilities and making sure that they have a supportive process to do so. In June 2023, we launched our annual voluntary self-identification and disclosure (VSID) campaign to all employees, where employees can choose to disclose their disabilities through a survey along with other demographic categories. Through this campaign, we hope to learn more about our employees and how CN can best support them. Along with this voluntary survey, we have also distributed information to all our employees explaining our commitment to confidentiality and why these disclosures are important.

    3.3.3 We have plans to replace our careers website (where people can find and apply for jobs) with a new one. This is a big project that will take many years, and we do not have an exact timeline yet. When we redesign this website, we will consult with a digital accessibility expert to make sure that the new site is accessible.

This project will be complicated to complete. It will involve multiple departments including Communications, IT, and Human Resources. We have started the first stages of this process by determining who will be responsible for the different aspects of the project, and by starting to plan for how we will accomplish this task.

    3.3.4 Starting immediately, whenever we design or acquire new training material, CN will take steps to make sure the new materials are as accessible as possible.

As we planned, we have started to consider accessibility when we create or source training materials. For content that we design, we research best practices for accessibility and incorporate them into our training materials.

When we do not design training materials ourselves, we work with vendors to provide it. We communicate our commitment to accessibility to potential vendors, and we consider accessibility when we evaluate options for training materials. As part of achieving this goal, as well as others related to our programming and procurement, we are working on a plan to learn more about accessible procurement in general and how we can incorporate it into our sourcing of training materials.

    3.3.5 By June 2025, CN will conduct a review of our existing accommodation guidelines and processes for employees with disabilities. Based on this review, CN will make recommendations on how to improve our guidelines and processes.

We have started work on the first stages of this task. We are beginning by conducting a detailed review of our existing accommodation guidelines and processes for employees with disabilities. This will inform our recommendations for how we can improve. We are putting together a task force that will have members from multiple CN departments, including Human Resources, Labour Relations, Benefits, Safety, Operations, and Workers’ Compensation, to collaborate on this review. We expect to be on track to meet our goal by June 2025.

3.4 Information and Communications Technology (ICT)

At CN, we rely on many different technologies and digital systems to keep our company running. We have committed to considering accessibility when we buy or set up new technologies, and when we update our existing ones. Below are the goals that we have committed to that relate to ICT, and updates on the progress we have made in achieving these goals.

    3.4.1 Starting immediately, we will consider accessibility whenever we purchase a new Information & Technology (I&T) product. We will make sure that off-the-shelf products have built-in accessibility features and that anything we design in-house is built to be as accessible as possible.

Our I&T department has worked with our Procurement and Supply Management department to include accessibility in our procurement and purchasing processes. We now include accessibility requirements when we put out Requests for Proposals, and accessibility is part of our evaluation criteria when we are choosing software and vendors. We also communicate more clearly with our vendors to share our commitment to accessibility, and to assess how they plan to deliver products that meet our accessibility requirements.

    3.4.2 By June 2024, CN will roll out digital accessibility training for I&T staff that is specific to their job functions. For example, all I&T staff will receive digital accessibility awareness training, while Product Managers and User Experience (UX) Designers will receive more detailed training.

Our I&T department is working with our in-house User Experience specialists to develop documents and training materials about accessibility requirements for software development. We expect to complete this work by the end of June 2024.

Once these materials have been completed, we will roll out training sessions for our I&T staff. We will be scheduling training sessions for staff based on their job functions. We have already started providing some training opportunities, including a webinar about accessibility in dashboards that we hosted in March 2024. We anticipate that the remaining training sessions will take place by the second half of 2024.

    3.4.3 By June 2026, CN will redesign our public website with accessibility as a primary goal. We will prioritize accessibility throughout the entire design process, by including accessibility requirements in our procurement process and involving accessibility specialists in the project. We will also make sure we consult with people with disabilities, such as employees, to give feedback on the design.

This will be a long-term project because it will involve several steps and external vendors. In 2024, we allocated a budget to start working on this project. We anticipate that this project will take up to three years to complete. We have set accessibility requirements as one of the key priorities of this project.

3.5 Communication, Other than ICT

We are committed to making sure that all our communications are accessible, especially those that are aimed at the public. It is important to us that everyone can access and understand our content, especially because our content often contains important safety information about Canada’s railways. Below are our goals relating to communication other than ICT, and updates on the progress we have made in achieving these goals.

    3.5.1 Starting immediately, CN will publish documents in HTML format wherever possible. When we must publish documents in PDF format, we will take steps to make sure those PDF documents are accessible.

When we post content on our website, we are transitioning to use HTML files instead of PDF wherever possible. This is allowing us to decrease our use of the PDF file format, which can be harder to access with assistive technology.

    3.5.2 By June 2024, CN will add accessibility practices to the existing corporate branding guide to make sure that all communications include accessibility considerations. This will apply to both internal communications within CN and external communications like our social media posts. We will train our employees on these new guidelines and make sure that everyone who creates communications is aware of best practices for accessible communications.

We have added accessibility into the corporate branding guidelines for all CN’s communications channels, including social media. We have also added accessibility as one of our measures of performance that we use to assess the effectiveness of our communications. We have updated the training for the employees on our Communications team to ensure that they are up to date on these requirements.

    3.5.3 By June 2024, CN will review all diversity content on CN's public website and make sure our messaging is consistent and clearly includes people with disabilities.

We are making progress in including people with disabilities clearly in our public messaging. In 2023, we included an image of a person with a disability in the promotional materials for our CN Wellness Challenge. In addition, when ESDC (Employment and Social Development Canada) launched their new Pay Gap Reporting Tool, Equi’Vision, in 2024, we included an image of people with disabilities in our video and web story submissions.

Our Communications team is continuing the process of reviewing our public messaging to find more opportunities to align our messaging and public content with goals of accessibility and inclusion.

3.6 The Procurement of Goods, Services, and Facilities

Some of the goods and services that we procure, or buy, at CN do not require us to consider accessibility. These include goods like fuel, or utilities like water. For other purchases we make, like technology or office furniture, we need to do better in considering accessibility. Below is the goal we have set relating to procurement, and an update on the progress we have made in achieving it.

    3.6.1 By June 2024, CN's procurement team will learn about how accessibility should be considered in procurement. This will include learning about when and how accessibility should be considered in the procurement process. Once we have a good understanding of best practice related to accessible procurement, we will make changes to our procurement procedures and documentation to reflect those best practices.

We have started the work of establishing benchmarks for accessible procurement at CN. To do this, we are referencing best practices that have been established by third-party platforms and by our peers in the industry. For the rest of 2024, we plan to participate in webinars to learn more about accessible procurement. We will also seek expert advice on other ways we can incorporate accessibility considerations into our procurement processes.

3.7 The Design and Delivery of Programs and Services

In our Accessibility Plan, we set two goals related to the ways we design and deliver our services, especially those that are aimed at the public. We want to make sure that people with disabilities are included in our advertisements and on our website. This is part of our broader goal of making sure that people with disabilities feel welcome and included at CN. The goals we have set are:

    3.7.1 By June 2026, CN will seek opportunities to include representations of diverse people, including people with disabilities, in future advertising campaigns.

    3.7.2 By June 2026, CN will consider having a section of the new website that is clearly for the public. This section of the website will be written in plain language and will include important safety information, contact information, and any other information that the public might need to know. This section will be linked prominently from the home page.

These are both longer-term goals for our organization. They will require us to make progress on some of the other goals we have set, like redesigning our public website. They will also require action by many CN departments and teams. We aim to complete both these goals by June 2026. We look forward to providing more detailed updates about our progress as we get closer to our timeline for implementing these goals.

3.8 Transportation

We have not set specific accessibility goals for our organization that fall under the area of transportation. While we are a transportation company, we focus on transporting goods rather than people. We are not aware of any barriers to accessibility that exist in this area for our company, but we will continue to monitor feedback we receive from employees and from the public.

4. Consultations

In late March 2024, we sent out an anonymous online survey to all our employees across Canada. The survey was voluntary, and employees could choose to complete it in English or French. We asked questions about how employees view CN’s Accessibility Plan, their opinions on our progress in achieving our accessibility goals, and whether they had any other ideas for how we can make CN more accessible. Employees also had the opportunity to anonymously disclose whether they live with a disability, or whether they are close to someone in their lives who has a disability. We received 389 responses to our survey. They were thoughtful and provided helpful feedback. Employees shared examples of the accessibility-related progress that they have seen at their workplaces. We heard about things like workplace events organized by CN’s ADAPT employee resource group, and employees noticing more colleagues being open about their disabilities in the workplace. Employees also pointed out specific barriers and challenges that exist at their workplaces and throughout the organization. Examples included wheelchair lifts that are out of order and buildings that do not have automatic door openers. Finally, they submitted ideas and recommendations for how we can achieve our goal of making CN more accessible, above and beyond what we have already outlined in our Accessibility Plan. These included creating a way for employees to request accessibility equipment like braille keyboards, and reassessing how and when employees can work from home. We will incorporate this feedback as we continue to work toward our accessibility goals.

5. Feedback

We have not yet received any feedback about accessibility through our feedback mechanism. We imagine this is because the general public does not interact with us often, and so most of the feedback we receive related to accessibility comes from our employees. We will continue to invite employees and members of the public to submit feedback on our Accessibility Plan and on our Progress Report. More information about how to submit feedback is shared in section 2.5 of this report.

6. Conclusion

As a publicly-traded corporation and large employer in Canada, diversity, equity, and inclusion are very important to CN. Making our organization accessible to people with disabilities, whether they work for us or are members of the public, is a big part of ensuring that CN lives up to these values. CN is committed to identifying and removing barriers to accessibility across all areas of our organization. We are proud to have made great progress over the past year in meeting our accessibility goals. We have also learned a lot about how we can reduce or eliminate more barriers within our organization. We look forward to sharing further updates as we continue to work toward our goals.