SustainablyEngaging with Stakeholders Across our Business
CP’s sustainability commitments are driven by the expectations of, and feedback from, our internal and external stakeholders. We are committed to building and maintaining strong relationships with the diverse stakeholders across our business, including employees, unions, customers, suppliers, communities, Indigenous groups, landowners, local organizations and service providers, non-governmental organizations and advocacy groups along our network. The objective of CP’s stakeholder engagement is to proactively and strategically address issues of concern both to CP and to the communities we serve. Through a respectful engagement approach, we aim to understand and respond to stakeholder needs, strengthen relationships, and continually improve our practices.
POLICY AND PLANNING
The nature of our business, extent of our network, and diversity of stakeholder interests requires cross-functional and inter-departmental cooperation to implement our extensive engagement program. As such, responsibilities for stakeholder engagement are applied across our business. Corporate policies that guide engagement efforts include:
- Our Environmental Policy, which provides for engagement with relevant stakeholders to consider and discuss CP’s environmental management practices and environmental concerns associated with our operations.
- Our Human Rights Policy, which addresses CP’s commitment to engage and involve key stakeholders on matters that affect them, including understanding human rights concerns.
- Our Supplier Code of Conduct Policy, which guides CP’s engagement with our suppliers, ensuring that suppliers chosen by CP are aligned with our company’s values and standards.
In addition, we prepare project- or site-specific engagement plans for new or expanded infrastructure, or in situations that involve a change in our business operations or engagement context. These plans include identification of key stakeholders and engagement objectives; identification of key issues including known concerns and topics of interest; and strategies for communication, consultation and engagement with different stakeholder groups.
GUIDING PRINCIPLES
Although many of CP’s teams and departments are involved in—and have responsibilities for—stakeholder engagement, our approach focuses on a common commitment of respectful engagement to build and maintain strong relationships with our diverse stakeholders. This commitment is supported by our culture of continual improvement and our core values of accountability, diversity and pride.
Across our business, the following guiding principles apply to all of CP’s stakeholder engagement efforts:
- Accessibility: we provide a variety of ways for stakeholders to contact and engage in dialogue with CP, and make sure these contact avenues are known and available.
- Responsiveness: we strive to provide all stakeholders with timely and relevant feedback to their questions and comments.
- Understanding: we recognize that our stakeholders have diverse backgrounds and experiences, and make efforts to understand their points of view.
- Collaboration: we work with interested and affected stakeholders to identify solutions and opportunities for improvement, and collaborate with relevant teams and external parties to improve performance.
IDENTIFYING AND PRIORITIZING STAKEHOLDERS
At CP, our stakeholder groups are far-reaching. Stakeholders are identified through reviews of our operating landscape, as well as analysis of communication through our long-standing Community Connect platform. We work closely with local communities and governments to identify key stakeholders and we actively contact a wide range of stakeholders to gauge interest in CP operations. Depending on the context, we prioritize stakeholders based on a number of factors that may include proximity to CP operations, level of impact and interest in engaging with CP.
MEANS OF ENGAGEMENT
Each CP department employs engagement methods that best fit the particular stakeholder, issue, and location of interaction. Frequently, these interactions are conducted by phone or email, or face-to-face in our communities through education sessions, safety awareness, and community events.
To ensure our engagements are accessible to all stakeholders we often travel to the communities in which we work. With consideration for community capacity, we often provide multiple options for community consultation to accommodate various schedules. If there are concurrent projects underway in the community, we will aim to ensure that our engagement does not overlap, where possible. For Indigenous communities, we may offer capacity funding agreements which aim to provide the resources to facilitate meaningful participation in the project.
Considering the interdisciplinary landscape of our engagement program, some of the primary avenues for stakeholder engagement at CP are summarized below. This includes engagement related to information sharing, consultation, community investment and management of grievances. In addition, our Environmental, Human Rights and Supplier Code of Conduct policies outline our commitments to engaging and involving key stakeholders in the identification and resolution of concerns related to our business.
|
Topic |
Means of Engagement |
Responsibility within CP |
Key Stakeholders |
|
Rail operations |
Land agreements: CP’s real estate team works with landowners and Indigenous groups along our network to manage land access and rights of way. |
Facilities and Real Estate |
Communities, Indigenous groups, landowners |
|
CP website: CP provides a hub of information about living near the railway including rail projects, maintenance activities and vegetation management along the tracks. |
Corporate Communications |
Public (all) |
|
|
Projects |
Environmental assessments: CP engages with communities and Indigenous groups throughout project planning, environmental assessment and permitting processes. Engagement may include open house meetings, regular meetings with Indigenous groups or other stakeholders, or other mechanisms, depending on the scope of the project. |
Environmental Risk |
Communities, Indigenous groups, local governments |
|
CP website: CP provides regularly updated information about rail projects to keep our neighbours informed of new facility or infrastructure projects and track upgrades. |
Corporate Communications |
Public (all) |
|
|
Indigenous Relations |
Indigenous engagement: CP maintains relationships with Indigenous groups along our Canadian and U.S. network. We work with communities to understand the significance of specific areas to Indigenous history and culture. Through engagement, CP aims to proactively identify and understand concerns and work together to resolve issues that may arise. |
Facilities and Real Estate, Indigenous Relations and Corporate Risk |
Indigenous groups |
|
Participatory environmental monitoring: depending on the location of a project, CP may integrate representatives from Indigenous groups into environmental monitoring projects to serve as a community liaison, promote cross-party learning, build capacity and to communicate with the leadership of participating Indigenous groups. |
Environmental Risk |
Indigenous groups |
|
|
Community investment |
Donations, partnerships and sponsorship programs: CP supports the health and well-being of the communities along our network through strategic giving, volunteering and community events. |
Community Investment and Workplace Giving |
Local community members and organizations |
|
Public Safety |
Community awareness training: CP supports proactive, community-based training to inform neighbouring communities about safety near tracks and crossings. |
CP Police Service, in partnership with Operation Lifesaver |
Communities and Indigenous groups |
|
Community outreach: CP employees visit communities across the CP network to share the message of rail safety. |
Community Relations |
Communities |
|
|
Emergency preparedness and response: CP works with neighbouring communities and Indigenous groups to ensure they are equipped with the knowledge and resources to respond to potential emergencies. |
Facilities and Real Estate, Corporate Risk and CP Police |
Local law enforcement, first responders, public safety agencies and Indigenous groups |
|
|
Grievance mechanism |
Grievance management: CP provides a telephone hotline, Community Connect online platform and other avenues for stakeholders to submit questions and concerns. CP Police are engaged on issues of safety and security. Significant concerns are escalated to the Chief Legal Officer and Corporate Secretary, and reported to the Board of Directors. |
Community Relations team, CP Police, Chief Legal Officer, and Corporate Secretary |
Communities |
|
CP’s professional standards department tracks all citizen complaints and concerns regarding the CP Police Service. |
CP Police Service |
Public (all) |
|
|
Workforce |
Talent management: CP engages with current and future employees through our recruitment, hiring, development and workforce engagement programs. |
Human Resources |
Existing and prospective workers |
|
Recruitment partnerships: CP has established partnerships with educational and training institutions to support hiring for technical roles within our business. |
Human Resources |
Existing and prospective workers |
|
|
Employee engagement: CP leverages town hall meetings and employee surveys, and maintains grievance mechanisms for our union workforce. |
Human Resources and CEO |
Employees |
|
|
Anti-discrimination and harassment: CP takes an active management approach to instances of discrimination and harassment. Complaints, when received, are addressed directly through leadership training, anti-discrimination training, and employee wellbeing assessments |
Human Resources |
Employees |
|
|
Supply chain |
Supplier contracting: CP has a Supplier Code of Conduct and proactively engages with suppliers on requirements. CP provides safety and security awareness training to our contractors. |
Procurement and Safety |
Suppliers and contract employees |
|
Collaboration: CP is an active board member of the RailMarketplace and directly engages suppliers through auditing, and product and service development. |
Procurement |
Suppliers |
|
|
Investors |
Shareholder engagement: CP maintains an active shareholder engagement program to meet with our shareholders on a regular basis. Shareholders can also communicate with CP via email by sending inquiries or comments to ocs@cpr.ca or to shareholder@cpr.ca. |
Investor Relations |
Shareholders |
|
Legislation and regulations |
Meetings with key politicians: CP proactively builds relationships with federal, provincial and state level government who are involved in CP’s areas of interest. CP works with lawmakers to ensure that safety, efficiency, and impact are top of mind through regulatory and legislative processes. |
Government Relations |
Government representatives |
|
General information |
CP website: CP’s 24/7 Community Connect online platform provides answers to frequently asked questions and an online form to submit inquiries. CP provides clear contact channels and information for various stakeholders including customers, sales, suppliers, investors, media, and prospective employees. |
Corporate Communications |
Public (all) |
We manage stakeholder engagement risk by clearly communicating the engagement goals to all stakeholders, engaging with local partners to facilitate interaction, and building trusted, long-standing relationships with our stakeholders. We incorporate lessons learned from previous stakeholder engagements in a process of continuous improvement.
Each CP department frequently communicates the results of stakeholder engagement with relevant internal departments and senior management. CP also provides public communication on community stakeholder engagement results related to major projects.
COMMUNITY CONNECT
Community Connect is CP’s public-facing feedback mechanism accessible to all stakeholders, and provides a direct way for stakeholders to communicate questions, complaints or suggestions to CP. The Community Relations team works to resolve issues and respond to stakeholders’ concerns. In 2021, most of the issues identified through Community Connect generally occurred within three main categories: use and condition of crossings, noise and disturbances and property conditions.
Our Commitment to Human Rights
POLICY COMMITMENT
Our Human Rights Policy articulates our commitment to respect the universal human rights of all people throughout our operations, including our employees, the communities in which we operate and our supply chain. This Policy supports our strategy to uphold and monitor human rights across CP’s network and operations by establishing sound due diligence, business and operational practices that minimize exposure to and incidents of human rights violations. As a participant in the United Nations Global Compact, we commit to support and respect the protection of internationally proclaimed human rights and ensure that we are not complicit in human rights abuses.
Our Code of Business Ethics is aligned with this policy and provides additional guidance related to our expectations for employees and contractors, while our Supplier Code of Conduct Policy upholds these commitments within our supply chain.
HUMAN RIGHTS DUE DILIGENCE
CP’s approach to human rights is founded on the principles established by the United Nations Guiding Principles on Business and Human Rights (UNGPs). In addition to our policy commitment, we have developed a company-specific human rights due diligence process to:
- Systematically and periodically identify and assess actual and potential human rights issues.
- Integrate and act on findings (including mitigation and/or adaptive management measures, if needed).
- Provide access to remedy.
- Track and report on the effectiveness of our response.
Through our human rights due diligence, we have prioritized the human rights issues most salient to our operations. These issues are the focus of our management, mitigation, tracking and reporting efforts.
IDENTIFICATION AND ASSESSMENT
In identifying and assessing our actual and potential human rights issues, we considered: our employees, women, children, Indigenous people, third-party contracted labour and local communities. Our process consisted of:
- Assessing our international and national obligations against key human rights frameworks, including:
- UN Guiding Principles on Business and Human Rights
- International Bill of Rights
- Relevant ILO conventions
- OECD Guidelines for Multinational Enterprises
- Canadian Charter of Rights and Freedoms
- Collecting good practices from direct and indirect peers and global industry leaders.
- Reviewing CP’s existing commitments, policies, and processes to identify past and present potential human rights-related issues.
- Conducting interviews with key functional teams across CP to understand human rights interactions and validate findings.
HUMAN RIGHTS ISSUES
As a result of this identification and assessment process, we have identified three areas where we are focusing our efforts including: nondiscrimination; workforce; and community and supply chain. These are the salient human rights issues associated with our activities and business relationships.
Nondiscrimination
- Diversity, equity and inclusion
- Gender equality and women's rights
- 2SLGBTQ+ rights
- Indigenous and cultural rights
Workforce
- Right to a safe and healthy working environment
- Right to fair and equitable employment
- Right to fair and equitable working conditions and hours
- Right to freedom of association and collective bargaining
Community
and Supply Chain
- Right to life, liberty and security
- Right of quality standard of living
- Right to health and environmental protection
- Prevention of child and forced labour and exploitation
- Right to freedom of movement and assembly
INTEGRATION AND ACTION
CP is actively working to manage human rights issues throughout our decision-making processes and through specific mitigative actions. Some examples of our actions are highlighted below.
|
Area |
Issues |
Integration and Action |
|
Nondiscrimination |
|
Relevant Policies:
Management Systems:
Regulatory Compliance: |
|
Workforce |
|
Relevant Policies: Management Systems:
Regulatory Compliance: Representation
|
|
Community and supply chain |
|
Relevant Policies: Management Systems:
|
REPORTING AND ADDRESSING CONCERNS
As a good corporate citizen, CP is committed to not only respecting and upholding human rights, but to implementing proactive measures to mitigate human rights risks within our control or influence. We also commit to taking relevant and meaningful steps to support access to remedy where applicable.
To support effective remedy, CP provides a number of different mechanisms through which affected persons can register a grievance, or suggest an improvement to CP’s existing systems and processes:
- The Community Connect platform can be used by members of the public—including community and Indigenous stakeholders—to submit feedback on any matter. Each concern is treated individually and confidentially by a trained member of CP’s team.
- The Alert Line (A-Line) is our internal mechanism for CP staff and other stakeholders to register complaints related to ethics, corruption, environmental or safety violations, or related matters. The A-Line facilitates anonymous reporting.
- Each collective bargaining agreement has provisions for filing grievances. A unionized worker can file a grievance or the union can file a grievance on their behalf.
- CP’s Safety Management System includes a safety hazard reporting application enabling all employees to identify and communicate safety hazards, triggering prompt corrective action and notification to management and workplace health and safety committees. CP has a defined Safety Hazard Escalation Process that outlines how safety concerns or hazards should be managed, and escalated if required.
Once reports are received, CP assigns the most appropriate internal teams to conduct a thorough and prompt investigation and urges all parties to participate. Throughout the process, CP maintains confidentiality and provides protection from retaliation when reporting in good faith.
Where concerns are substantiated, CP will implement corrective actions to remediate the situation. The remedial action taken will depend on the nature and gravity of the conduct or circumstances found as the result of an investigation. This action may include disciplinary action against any offending employees or contractors, up to and including termination of employment or any other working relationship that the offending party may have with CP. Reasonable and necessary steps will also be taken to prevent any further violations.
For complaints regarding environmental matters, remediation is handled by CP’s Environmental Risk function. CP attempts to mitigate any health and safety-related complaint filed by the workforce internally through a local cross-functional health and safety committee. For complaints related to accommodations, CP’s Human Resources team works with employees and unions to provide appropriate accommodation to employees.
