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Governance

The Governance, Sustainability and Safety Committee of the Board of Directors oversees the Company’s strategic government advocacy, corporate memberships, and political contributions. It receives an update annually that provides information on our lobbying activities, a detailed list of our corporate memberships, including industry associations and policy organizations, and a list of our corporate political contributions. CN prides itself on being a company that our stakeholders can count on to make the right choices and do the right thing.

CN has several policies pertaining to lobbying activities and political contributions, each of which applies to all directors, officers, and employees as well as contractors, as summarized in the following:

Anti-Corruption Policy

CN prohibits the payment of bribes and kickbacks, or provision to government officials of gifts, entertainment, or something of value, in order to improperly influence a government official’s decisions or actions in the performance of his or her duties. CN also prohibits the offer or provisions of facilitation payments. This policy outlines CN’s expectations of personnel regarding integrity-based business practices to avoid the occurrence or even the appearance of improper or illegal conduct and to encourage ethical behaviour in all of CN’s business.

Code of Business Conduct

CN’s Code of Business Conduct (Code) provides personnel with the expected standards of conduct to ensure CN’s reputation for honesty, integrity and reliability is maintained. The Code states that we respect the political process and only make political contributions and engage in lobbying activities that are legal and transparent. The Code refers our personnel to the Anti-Corruption Policy for more specific guidance on those issues.

Political Contributions and Activities

At CN, we have a responsibility to participate in public debate on certain public policy issues – specifically on issues that may have an impact on our legitimate business goals and matters that may affect the communities where we operate. Our engagement with government focuses on supporting the advancement of our business strategy, which is underpinned by our commitment to Delivering Responsibly, which encapsulates our sustainability priorities.

When making contributions to political parties, political organizations or their representatives, CN strictly respects the laws in Canada and the United States. Our participation in party politics, including fundraising activities, is undertaken only as permitted by law.

In 2023, CN contributed approximately US$43,500 in corporate political donations in the United States.

Separately, an independent U.S. employee Political Action Committee (PAC) is registered with the U.S. Federal Election Commission and complies with the regulations implemented by that agency. The employee PAC can be found at:

 
 Employee PAC

 

Political Activities Policy

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