Canadian National Railway Co

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Canadian National Railway Co (CN) has demonstrated a comprehensive level of transparency regarding its climate lobbying activities. The company explicitly names specific climate policies it has engaged with, including the "Quebec and Nova Scotia GHG cap-and-trade systems," "British Columbia and Alberta carbon taxes," the "Government of Canada Federal backstop levy," the "Canadian Government's Federal Fuel Charge," and the "Clean Fuel Regulation enacted in 2022." These disclosures include detailed information about the policies' geographic scope and regulatory focus, such as carbon pricing and emissions trading schemes. CN also provides clear details about its lobbying mechanisms and targets, stating that it engages "with various Canadian federal and provincial governments on their cap-and-trade and carbon taxes," and participates in advisory councils, review boards, and regulatory proceedings. Specific targets include provincial and federal governments in Canada, such as those involved in the Quebec and Nova Scotia GHG cap-and-trade systems. Furthermore, CN has been transparent about the outcomes it seeks through its lobbying efforts, aiming to "position rail freight as a viable low-carbon transportation solution," support "future policy developments in a manner that will foster low-carbon economic growth while ensuring significant GHG emission reductions," and advocate for "the allocation of funds to support a modal shift from truck to rail," investment in "rail fuel efficiency technologies," and the development of "zero-emission rail technologies." This level of detail illustrates CN's comprehensive approach to disclosing its climate lobbying efforts and objectives.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	CN demonstrates a structured approach to managing its climate lobbying alignment, as indicated by statements that "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." The company also notes that "public policy decisions that could impact our overall climate strategy are communicated to the Sustainability team to be validated for consistency," with "recommendations proposed to ensure alignment" if inconsistencies are found. Although CN further mentions that "we evaluate our engagement with these trade associations to ensure alignment with the goals of the Paris Agreement," limited detail is provided on how alignment is enforced or how ultimate oversight roles, including the GSS Committee's responsibilities, are defined. Nevertheless, the references to periodic reviews, cross-functional coordination, and integration with its climate strategy indicate strong governance, even though additional clarity around accountability measures would enhance transparency.	3