Ethics and Integrity

Our commitment to business ethics and integrity is reflected in our focus on continuously improving our governance policies and practices, and establishing clear systems to ensure accountability, risk management and control are embedded across our business.

In our daily activities, we face a variety of issues. Establishing clear, consistent and uncompromising standards and adherence to integral and ethical behaviour ensures that we deal professionally with issues as they arise, always do the right thing, maintain a positive image in all aspects of our business, and encourage an innovative spirit among employees while enhancing shareholder value.

Our Code of Business Conduct (PDF), corporate governance policies, our Board Diversity Policy, and environmental, health and safety policies frame our values and commitments to delivering responsibly.

Human Rights

Our Policy

Our commitment to uphold internationally recognized human rights is anchored by our Human Rights Policy, which includes the Declaration on Fundamental Principles & Rights at Work by the International Labour Organization (ILO).

We support the Guiding Principles on Business and Human Rights endorsed by the United Nations Human Rights Council in 2011, and have aligned our practices with the UN Global Compact – a voluntary global standard on human rights, labour, the environment and anti-corruption.

The UN Global Compact (UNGC) is a strategic policy initiative for businesses that are committed to aligning their operations and strategies with ten universally accepted principles in the areas of human rights, labour, environment and anti-corruption. In 2022, CN submitted a Letter of Commitment to join the UNGC. CN will continue to demonstrate measurable impact on these goals through periodic updates and annual reporting to the UNGC.

Our Human Rights Policy, our Supplier Code of Conduct  and approach to delivering responsibly are aligned with these UNGC principles.

In addition to complying with applicable laws and regulations, our Human Rights Policy is also brought to life through various established company-wide policies, including:

• Safety Policy
• Anti-corruption Policy
• Harassment-free Policies
• Employment Equity Policy
• Protection of Personal Information Policy
• Information Security Policy
• Workplace Violence Prevention Policy
• Environmental Policy
• Workplace Alcohol and Drug Prevention Policy
• Code of Business Conduct and Ethics
• Supplier Code of Conduct

These policies and standards define how we operate. Through training, awareness and on-the-job coaching, we work with our employees and business partners to pursue the highest standards in all our activities. For more information, please refer to our Human Rights Policy.

Due Diligence Assessments

We conduct high level due diligence assessments across our value chain to proactively identify, address and mitigate potential human rights related issues.

Last year, our high level review consisted of management level interviews and desktop review covering employees, suppliers, customers and community groups. Through the process, we identified nine human rights related issue areas where we are focusing our efforts. These include: health and safety, diversity, indigenous people, discrimination and harassment, forced labour and child labour, work hours, wages and benefits, freedom of association, and community engagement.

Mitigation Measures

The management of human rights is embedded in our business, including through:

a) employment policies and standards covering topics related to diversity, equal opportunities, health and safety, labour conditions and discrimination and harassment;

b) supplier standards and audits that ensure we promote human rights in our supply chain, which is part of the vendor management program;

c) community engagement practices through environmental and social impact assessments as well as outreach programs that create positive societal impacts;

d) Indigenous People programs aimed at building positive and sustainable relationships and partnership; and,

e) Union agreements focused on fair and respectful work conditions.

In 2022, no material human rights violations were reported. As a result, no sites are currently under mitigation plans and no remediation action has been necessary.

Grievance Mechanisms

Requests, concerns, and disclosures of misconduct can be reported through a variety of channels defined in our Code. These include our Law Department, Human Resources Centre, CN Police, and Ombudsman, who plays an integral role in ensuring equitable resolutions of concerns. We also have a confidential general CN telephone hotline.

Anyone who becomes aware of a violation of our Human Rights Policy is strongly encouraged to speak up. CN prohibits retaliation against any person for reporting, in good faith, contraventions of this Policy, or for filing a complaint or testifying, assisting, or participating in any manner in any investigation, proceeding, or hearing conducted by a government enforcement agency. Prohibited retaliation includes, but is not limited to, termination, demotion, suspension, failure to hire or consider for hire, failure to give equal consideration in making employment decisions, failure to make employment recommendations impartially, adversely affecting working conditions, or otherwise denying any employment benefit because an employee has reported alleged prohibited conduct or participated in an investigation.

The Code of Business Conduct

Our Code of Business Conduct (PDF) – available in French and English – communicates our values and principles. It reflects our commitment to engaging with our stakeholders with trust and integrity and the importance of maintaining a positive reputation in all aspects of our business.

The Code applies to our employees, directors and officers. We expect everyone working on our company’s behalf, including consultants, agents, suppliers and business partners, to obey the law and adhere to high ethical standards. 

Anti-Corruption Policy

CN believes that clean business is sustainable business and is committed to using only ethical and legal business practices. Corruption hinders CN’s ability to develop and maintain long-term, fair, mutually beneficial relationships with our suppliers, customers and business partners.

The purpose of this Policy is to ensure legal compliance and prevent illicit activities which are counter to CN’s ethical culture and would harm CN’s reputation and business.

This policy applies to all employees of Canadian National Railway Company and its subsidiaries, including contract employees.

 Learn more about our Anti-Corruption Policy (PDF)

Training and Awareness

The Code of Business Conduct (PDF) is an important part of our commitment to the highest standards of ethical business conduct and reflects what CN stands for. It addresses matters such as conflicts of interest, anti-corruption, health and safety, environment, and human rights. In 2015, we launched web-based training on the Code to managers across the Company. As well, we provide "Our Obligations" training to managers in Canada, which includes a review of our Human Rights Policy, Harassment-Free Environment Policy, Accommodation Guidelines and Employment Equity Policy. We also train our human resources staff on their roles and responsibilities related to human rights and employment equity legislation, guidelines, and policies.

On an annual basis, management reports to the Corporate Governance and Nomination Committee of the Board on the implementation of the Code and on any material breaches by employees. Over the past year we have not had any material breaches of the Code of Conduct.

Reporting Violations

Find out how to report violations.