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Governance

Oversight and Policies on Lobbying, Political Contributions and Corporate Memberships

The Corporate Governance and Nominating Committee of the Board of Directors oversees the Company’s lobbying, political contributions and corporate memberships. It receives an update annually that provides information on our lobbying activities, a list of our political contributions and a detailed list of our corporate memberships, including industry associations and policy organizations. 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.

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

In 2017, CN has contributed $30,600 in corporate political donations in Canada and contributed $55,790 in corporate political donations in the United States.

Separately, the 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.
 
 Employee PAC


Political Activities Policy

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