Lobbying and political donations | What matters to CN | Who are we | About CN

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

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

Anti-corruption policy

CN prohibits the payment of kickbacks and kickbacks, or the offering of gifts, entertainment or anything of value to government officials, for the purpose of improperly influencing decisions or actions of a government official in the performance of his or her duties. CN also prohibits the offer or provision of facilitation payments. This policy outlines CN’s expectations of employees regarding integrity-based business practices to avoid the occurrence or even the appearance of improper or illegal conduct and to encourage ethical behavior in all CN activities.

Code of Professional Conduct

CN’s Code of Business Conduct (the Code) provides employees with the expected standards of conduct to help maintain CN’s reputation for honesty, integrity and reliability. The Code states that we respect the political process and only make political contributions and engage in lawful and transparent lobbying activities. The Code refers our staff to the Anti-Corruption Policy for more specific guidance on these matters.

Political contributions and activities

At CN, we have a responsibility to participate in public debate on certain public policy issues, particularly issues that may impact our legitimate business objectives and issues that may affect the communities where we do business. .

CN strictly follows the law when it comes to making contributions in Canada and the United States to political parties, political organizations or their representatives. We also engage in party politics, including fundraising activities, only as permitted by law.

In 2021, CN made approximately US$1,000 in corporate political donations in the United States. CN has not contributed to corporate political donations in Canada.

In addition, an independent US Employee Political Action Committee (PAC) is registered with the US Federal Election Commission and complies with the regulations implemented by that agency. The employee’s PAC can be found at:

CAP of employees