Canadian National Railway Co – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Canadian National Railway discloses a defined governance structure that covers both direct and indirect climate-related lobbying and sets out how alignment is monitored and overseen at board level. The company states that "The GSS Committee of the Board oversees CN’s strategic government advocacy, corporate memberships, and political contributions" and that this committee "receives an update annually that provides information on our lobbying activities, a detailed list of our corporate memberships…"; this indicates clear board-level responsibility and regular reporting. Alignment mechanisms are described in operational detail: "the direct and indirect activities that could influence public policy are typically reviewed by the Government and Public Affairs department on an annual basis to ensure alignment with the strategic direction of the business, including our climate change strategic focus areas," after which "Public policy decisions that could impact our overall climate strategy are communicated to the Sustainability team to be validated… Where inconsistencies are noted, recommendations are proposed to ensure alignment." The company also addresses trade-association positions, noting that "we actively engaged with the RAC and AAR… We evaluate our engagement with these trade associations to ensure alignment with the goals of the Paris Agreement," demonstrating that indirect lobbying is subject to the same alignment checks. In addition, CN makes a public commitment that its advocacy will be "in line with the goals of the Paris Agreement" and confirms that "Yes, we publicly disclose a list of all the research organizations we fund." These disclosures together show a strong process—regular internal reviews, sustainability team validation, and board oversight—for ensuring lobbying consistency with climate strategy. However, the company does not disclose a stand-alone, publicly available lobbying-alignment audit or examples of correcting or ending memberships where misalignment persists, limiting the transparency of outcomes from these processes. View Sources	B

Overall Assessment

Analysis

Score

Strong

Canadian National Railway discloses a defined governance structure that covers both direct and indirect climate-related lobbying and sets out how alignment is monitored and overseen at board level. The company states that "The GSS Committee of the Board oversees CN’s strategic government advocacy, corporate memberships, and political contributions" and that this committee "receives an update annually that provides information on our lobbying activities, a detailed list of our corporate memberships…"; this indicates clear board-level responsibility and regular reporting. Alignment mechanisms are described in operational detail: "the direct and indirect activities that could influence public policy are typically reviewed by the Government and Public Affairs department on an annual basis to ensure alignment with the strategic direction of the business, including our climate change strategic focus areas," after which "Public policy decisions that could impact our overall climate strategy are communicated to the Sustainability team to be validated… Where inconsistencies are noted, recommendations are proposed to ensure alignment." The company also addresses trade-association positions, noting that "we actively engaged with the RAC and AAR… We evaluate our engagement with these trade associations to ensure alignment with the goals of the Paris Agreement," demonstrating that indirect lobbying is subject to the same alignment checks. In addition, CN makes a public commitment that its advocacy will be "in line with the goals of the Paris Agreement" and confirms that "Yes, we publicly disclose a list of all the research organizations we fund." These disclosures together show a strong process—regular internal reviews, sustainability team validation, and board oversight—for ensuring lobbying consistency with climate strategy. However, the company does not disclose a stand-alone, publicly available lobbying-alignment audit or examples of correcting or ending memberships where misalignment persists, limiting the transparency of outcomes from these processes.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Canadian National Railway provides a highly transparent picture of its climate-policy lobbying. It names a suite of specific measures it engages on, including the “Quebec and Nova Scotia GHG cap-and-trade systems,” the “British Columbia and Alberta carbon taxes,” the “Government of Canada Federal backstop levy,” the “Canadian Government’s Federal Fuel Charge,” and the 2022 “Clean Fuel Regulation,” as well as broader support for provincial and state carbon markets in the United States. The company is equally clear about how it seeks to influence these rules, describing a mix of direct meetings with “various Canadian federal and provincial governments,” participation in advisory councils and working groups, written submissions and consultation responses, and indirect work through the Railway Association of Canada and the Association of American Railroads—all of which are recorded in public lobbying registers. Finally, CN articulates concrete policy outcomes: it advocates “the allocation of funds to support a modal shift from truck to rail,” seeks “investment in rail fuel-efficiency technologies,” champions the “development of zero-emission rail technologies,” and supports carbon pricing and emissions-trading schemes that align with Canada’s net-zero commitments. By detailing the policies, the channels it uses, the government bodies it targets, and the specific results it is pursuing, CN demonstrates a comprehensive level of transparency around its climate-related lobbying activities.	A