1 | TMX Reconciliation Action Plan Reconciliation Action Plan TMX Group’s Plan to Further Indigenous Reconciliation in Canada September 2025
2 | TMX Reconciliation Action Plan Table of Contents Land Acknowledgment Message from the CEO Adawe Meet the Artist - Kathryn Corbiere How We Arrived Here Acknowledgements Our Commitments Pillar 1 - Capital Realignment Pillar 2 - Relationships Pillar 3 - Truth, Learning and Action Pillar 4 - First Nations, Inuit and Métis Talent 3 4 5 6 9 10 11 14 17 20
3 | TMX Reconciliation Action Plan We respectfully acknowledge the time-immemorial, interwoven relationship that the First Nations, Inuit and Métis have with their homelands and traditional territories. We operate at the centre of a financial ecosystem that extends across the land we now call Canada and impacts the lives of diverse First Nations, Inuit and Métis communities, nations and people. We have a role to play on the path to reconciliation and as such, we are committed to upholding the spirit and intent of the treaties and working towards a future that is equitable, just, and inclusive for all. We are grateful to be able to live, work and learn on these lands. Land Acknowledgement
4 | TMX Reconciliation Action Plan TMX Group’s unifying purpose is to make markets better and empower bold ideas. More than a marketing slogan or a tagline, this is our commitment to the financial ecosystem and everyone who participates in it. Our role at the heart of Canada’s markets, and by extension the economy, is one of privilege, and it is also one of responsibility. In keeping with this responsibility, we have set out to improve Indigenous inclusion and representation across our organization and our industry in Canada. Capital markets represent powerful engines of opportunity: platforms for entrepreneurs and businesses to raise capital to fund the next great idea, and for investors to participate in that prosperity. Canada’s markets are the best in the world, but they can be better – by increasing access and participation for groups that have historically been excluded and strengthening ties to communities across the country. This belief drives our commitment to advancing reconciliation. TMX Group’s transformative journey began in 2021, with a proposal brought forward by the Shareholder Association for Research and Education (SHARE), filed on behalf of the Atkinson Foundation, to improve Indigenous relations and inclusion at TMX. Our shareholders voted overwhelmingly in favour of this proposal and everyone at TMX – the Board of Directors, senior leaders and employees – embraced the effort. We reached out to Indigenous organizations and began the process of building closer relationships by listening, learning and collaborating on new ways to support the sustainable growth of the underrepresented Indigenous economy, and more inclusive practices. Our first Reconciliation Action Plan represents an important milestone in this journey. In it, we detail how we will work to realign capital, an idea shared with us by the Indigenomics Institute, one of Canada’s leading Indigenous economics organizations. The concept of realigning capital builds on the need to support Indigenous access to capital – acknowledging that beyond access, investors and capitalseekers require education, knowledge and access to one another. Our goal in sharing this plan is not only to put forth TMX’s commitments, but also to help investors understand and assess the important work we are doing. We recognize that the path to reconciliation is an ongoing and evolving process. TMX Group’s Board, senior management team and our entire organization are committed to the important work ahead. We look forward to updating you on our progress. John McKenzie Chief Executive Officer Message from the CEO
5 | TMX Reconciliation Action Plan Our team engaged in wide-ranging and productive conversations with leaders across Canada, and this Reconciliation Action Plan reflects many of the key insights and ideas represented in these meetings. The concept of Adawe, the Algonquin word for buying and trading, rooted our work. Trade and commerce have always existed in the lands we now call Canada. Long before settlers arrived, Indigenous nations and groups were bound by commerce, and the initial relationships with newcomers were based on peace, friendship and trade. As we seek to advance reconciliation and re-establish relationships based on peace, friendship, and mutual prosperity, Adawe is a reminder that commerce has long played a central role in building and maintaining good relationships. It is no accident that the name of Canada’s capital city comes from Adawe. Trade is the heart of our national identity. TMX’s role is to operate marketplaces that enable commerce. From our position at the heart of Canada’s financial markets, we are reminded by the word Adawe that our work is one of many chapters in the long story of trade on Turtle Island. Adawe
6 | TMX Reconciliation Action Plan Meet the Artist
7 | TMX Reconciliation Action Plan Kathryn Corbiere Kathryn Corbiere is from M’chigeeng First Nation. Her art focuses partly on CNC plasma cutting, modern furniture and custom fabrication. Her passion for working with steel is to express a strong visual aesthetic by bringing the material to life in the form of structural design. The mix of practicality and aesthetics is where she finds growth in her fabrication and capabilities. Influenced by her families’ traditional crafting and quill practices, she is interested in the integration of traditional visual forms, shapes, and processes into metal work, and is increasingly exploring the conversation between strong lines and curves. You can learn more about Kathryn and her work at onekwe.com.
8 | TMX Reconciliation Action Plan About Wiigwaas In approaching Kathryn for this piece, TMX hoped to achieve a tribute to both its 170 year-plus history and the history of this land and its people. The origins of Canada as a nation are rooted in the historical trade between European nations and Indigenous tribes. The sculpture honours the historical trading relationships of Indigenous peoples on Turtle Island and renewed efforts to establish economic reconciliation between Indigenous and settler Canada. The work – formed of polished stainless steel and proudly on display in the entrance to the TMX Market Centre in downtown Toronto – is designed to engage multiple perspectives, from various viewing directions. Iron ore, one of Canada’s commodities, is brought into a new life, in a contemporary space, in the contemporary timeframe. The primary sculptural form of this work evokes birch bark, which is historically and culturally significant to Indigenous peoples and the origins of Canada and its trade relations. Indigenous peoples, particularly in the Great Lakes region, used birch to create scrolls for communications, and to make canoes, which were central to the establishment of European trade systems. The sculpture references the natural formation of the birch tree bark: after it has been harvested, birch holds its curvature. Like Canada’s history of trade and business, the bark is not in a straight line; rather, it tells a story of ups and downs in the relationship between Indigenous peoples and settler Canada. The curved sculpture represents the ongoing relations between Indigenous peoples and Canada. In the petroglyphs, a curved or circular shape denotes that something is ongoing, or will return. We chose to highlight the creation process for Wiigwaas throughout this Reconciliation Action Plan document as a thematic reminder of the connections between the Indigenous and non-Indigenous economies that we hope to foster through our commitments.
9 | TMX Reconciliation Action Plan How We Arrived Here TMX Group’s Reconciliation Action Plan first came into focus in the summer of 2022. Over the course of several days in the Huron-Wendat community of Wendake, a cross-section of our senior leaders and executives convened with Indigenous experts and leaders in the Indigenous economy, to explore reconciliation in relation to Canada’s capital markets ecosystem. We left with big ideas, and the recognition that ultimately, our commitments must be grounded in relationships, truth, and action. Over the following three years, TMX Group engaged formally and informally with Indigenous business leaders, investors, development corporations and community leadership. During multiple facilitated discussions, we explored paths to develop, execute and report on meaningful commitments to advance reconciliation within our company, as well as more broadly throughout Canada’s financial markets. We are proud to publish TMX Group’s first Reconciliation Action Plan. And while this represents an important step forward, we also recognize that the publication of this plan marks yet another beginning. In addition to executing on the commitments outlined within, we commit to reporting, within the next five years, on the progress we make. TMX would like to thank everyone who offered their wisdom and their advice. We are deeply grateful for your insights, and your partnership. This Reconciliation Action Plan would not be possible without you.
10 | TMX Reconciliation Action Plan In Particular, We Wish to Acknowledge: • Colette Murphy, CEO of the Atkinson Foundation, and Mark Sevestre, General Manager of the Mississaugas of the Credit First Nation Community Trust, who brought forth the 2021 shareholder proposal that started TMX on our reconciliation journey and continue to provide their support, guidance and assistance. • Kevin Thomas, CEO of SHARE, and NATOA, whose partnership created the Reconciliation and Responsible Investment Initiative, encouraging non-Indigenous and Indigenous institutional investors to use their voices and capital to promote positive economic outcomes for Indigenous peoples. • The Canadian Council for Indigenous Business (CCIB), and CEO Tabatha Bull, who provided advice and insights to us as we created our Reconciliation Action Plan. • Indigenomics Institute and the First Nations Major Project Coalition (FNMPC), in particular Carol Anne Hilton and Mark Podlasly, who each partnered with us to host a facilitated engagement session with Indigenous experts and thought leaders. • Indspire, who worked with us to establish and launch our first Indigenous bursary: the Bourse de Montréal Indigenous Education in Finance bursary. • The National Aboriginal Capital Corporations Association (NACCA) and Acosys, who provided us with insights on important economic reconciliation ideas. • Blackbird Strategies, who supported our engagement sessions, advised on the creation of our Reconciliation Action Plan and provided ongoing insights to our team about reconciliation trends and topics. • Creative Fire, who led the design of the Reconciliation Action Plan. • Mokwateh, who led our work related to procurement guidelines and commitments and generously participated in multiple engagement sessions. • Coeuraj, who facilitated our first internal corporate dialogue about reconciliation in Wendake. • Haskan Sioui and Sebastien Desnoyers, who joined our first Reconciliation Action Plan exploration session in Wendake. • JP Gladu, Clint Davis, Shannin Metatawabin, Travis Boissoneau, Cassidy Caron and Victoria Pruden, who participated in TMX employee events and offered their unique insights and perspectives on economic reconciliation. • Oxford Properties and Sam Butwell, who have partnered with us to host Indigenous community events in the TMX Market Centre. • Kim Barrington, who has championed our reconciliation work from day one.
11 | TMX Reconciliation Action Plan Capital Realignment TMX Group is committed to supporting capital realignment. This means we will use our role as a marketplace facilitator in Canada to help investors learn about the Indigenous economy and connect with Indigenous companies, to help Indigenous entrepreneurs navigate public markets, to better engage Indigenous investors in our markets and to publicly recognize examples of reconciliation on our exchanges. Our overarching aim in this pillar is to increase capital flows to First Nations, Inuit and Métis businesses, communities and priorities. Our Commitments Pillar 1
12 | TMX Reconciliation Action Plan Pillar 1: Capital Realignment 1. Working in partnership with other organizations, we will co-create and facilitate access to information for Indigenous entrepreneurs and investors about Canadian public markets. • We will work with Indigenous organizations to adapt materials and programs that TMX Group currently offers to make them more accessible and available to Indigenous entrepreneurs and investors. 2. We will foster more relationships between Indigenous and non-Indigenous entrepreneurs and investors. • We will act as a facilitator to share knowledge with investors about Indigenous businesses. • We will look to offer support for interested Indigenous companies to learn more about and access our Canadian exchanges. This will include: – Support for Indigenous companies interested in the listing process. – Profiling Indigenous companies at events, including investor days. – Profiling procurement opportunities and the services of Indigenous companies at investor days. – Supporting listing strategies that make sense for Indigenous businesses, which may include: ■ Facilitating the use of dual-class share structures that preserve Indigenous ownership and decision-making within Indigenous businesses; and ■ Exploring opportunities through our Capital Pool Company program to support Indigenous businesses listing on the TSX Venture Exchange. • We will provide resources to Indigenous investors, including community capital corporations, about investing in the public markets. 3. We will use our position at the centre of Canada’s capital markets to highlight the work of public companies and other market participants engaged in reconciliation. • We will seek opportunities to develop indices that allow for the purchase of an investment vehicle that profiles reconciliation activities, when created by an issuer. – In partnership with CCIB, we have created the VettaFi Canadian Council for Indigenous Business PAIR Index, which tracks the performance of public companies who have committed to continual improvement in Indigenous relations and to working across cultures. Companies with higher levels of PAIR certification/ commitment are given higher weight multipliers in the index. – We will explore opportunities to create indices that profile companies engaged in and excelling at Indigenous Reconciliation. • We will work with Indigenous investors and investment groups to tailor indices and solutions to their investment interests. • We will work with partners to create investor days for Indigenous investors. 4. W e will support Indigenous procurement at TMX through a procurement guideline that aims to create opportunities for Indigenous businesses. • We will engage with Indigenous companies and organizations to expand our Indigenous suppliers list. • We will follow industry best practices to ensure the suppliers we work with are authentic Indigenous businesses. • We will profile Indigenous suppliers we work with through our owned media channels. 5. Through our TSX Trust business, we will continue to pursue opportunities to support financing for Indigenous community investments and business initiatives. • We will leverage our experience and industry relationships to create and support new opportunities in project finance, including public-private partnerships.
13 | TMX Reconciliation Action Plan Pillar 1: Capital Realignment We recognize the importance of taking immediate action. That is why we have: • Actively encouraged Indigenous participation in investor days since 2023. • Launched an index of publicly listed companies that are certified under the Canadian Council of Indigenous Business’ Partnership Accreditation in Indigenous Relations (PAIR) program. • Hosted content related to both Indigenous procurement and, separately, community engagement on our Exchange Feed podcast. • Sought opportunities for purchases from Indigenous suppliers, including consulting services and office supplies. What We Are Doing Now Photo: Nick Wons
14 | TMX Reconciliation Action Plan TMX Group recognizes that reconciliation is centred on relationships. It is through these relationships that we can uncover opportunities to make meaningful progress. Our overarching aim in this pillar is to establish long-term relationships with First Nations, Inuit and Métis peoples and organizations in Canada, and work together to discover and empower bold ideas to achieve prosperity for Indigenous peoples. Our Commitments Relationships Pillar 2
15 | TMX Reconciliation Action Plan Pillar 2: Relationships 1. We will use our spaces and convening power to help Indigenous organizations network across Canada’s finance and business sectors. • We will offer to host receptions and events for Indigenous partners in our spaces across Canada. • We will continue to make the TMX Market Centre available for Indigenous marketplaces to support Indigenous traditional economies. • We will continue to host market opening and closing ceremonies focused on profiling and promoting Indigenous community and business causes. • We will convene and facilitate high-level exchanges between senior business and Indigenous leaders. 2. We will support Indigenous-led and organized events that advance economic reconciliation. • We will make annual sponsorships available for events that are focused on and further economic reconciliation. • We will make our expertise and insights available for Indigenous organizations hosting economic reconciliation-focused events. 3. We will support Indigenous thought leadership activities that further dialogue, understanding, and ideas about economic reconciliation. • We will assess opportunities for TMX Group to offer financial and in-kind support for economic reconciliation thought-leadership activities led by Indigenous organizations or individuals including research, publications and roundtable conversations. We will also profile Indigenous business success stories through TMX social and other media channels and events.
16 | TMX Reconciliation Action Plan We have begun, and will continue, the important work of relationship-building. Since 2023, we have been proud to both host and participate in multiple events, conferences and ceremonies with partners including: • Aboriginal Peoples’ Television Network (APTN) • CCIB • FNMPC • Indigenomics Institute • Indspire • NATOA • The Métis National Council • Three Sisters Indigenous Crafts Market • Toronto Metropolitan University’s Student Association for Indigenous Growth and Economics (SAIGE) What We Are Doing Now Photo: Nick Wons
17 | TMX Reconciliation Action Plan TMX Group understands that reconciliation begins with truth and learning, and is followed through with action. We recognize that we are in a unique place to create truth and learning opportunities – and to champion action – because we are an employer, a facilitator of Canada’s capital markets, and a thought leader in the financial sector. Our overarching aim in this pillar is to advance learning opportunities within our team and among our ecosystem partners, while publicly demonstrating our commitment to action on our own reporting and reporting through credible, Indigenousled third party programs. Our Commitments Truth, Learning and Action Pillar 3
18 | TMX Reconciliation Action Plan Pillar 3: Truth, Learning and Action 1. We will provide educational resources to listed companies about truth, reconciliation and key concepts related to Indigenous rights. • We will facilitate knowledge transfer between Indigenous subject matter experts and our clients and ecosystem partners on topics including Indigenous rights and reconciliation. • We will make resources available to listed companies on topics related to reconciliation and Indigenous rights. 2. We will support initiatives that seek to enhance Indigenous representation on corporate boards of directors. • We will advance initiatives that facilitate connections between listed companies seeking talented and diverse board members and Indigenous and other professionals interested in serving on corporate boards. This includes: – TMX DOOR, a centralized platform designed to connect experienced and diverse candidates with leadership opportunities, and help provide critical data insights into board and management diversity trends. 3. We will continue our participation in the Partnership Accreditation in Indigenous Relations program. • We will continue to participate and engage in CCIB’s PAIR program. • We will continue to explore programs and actions we can commit to in alignment with the PAIR program. • We will continue to explore pathways to reach higher levels of PAIR accreditation in the future. 4. W e will establish an internal, cross-functional Reconciliation Working Group to guide our work on truth, learning and action. • We will ensure representation from the business units and corporate functions that are ultimately responsible for the execution of the commitments in this plan, and for reporting on progress. 5. We will continue to create educational opportunities for TMX employees to learn about Canada’s history with Indigenous peoples and ways of advancing reconciliation. • We will facilitate access to third party courses and materials for employees so that they can further their understanding and commitment to reconciliation. • We will host internal workshops on topics and themes related to reconciliation. • We will ensure enhanced learning opportunities and training for parts of our organization that may directly interact with Indigenous peoples, communities, entrepreneurs and investors. • We will help TMX employees identify volunteering and charitable opportunities to support Indigenous organizations, events and community activities. • We will include resources dedicated to indigenous reconciliation on internal communications channels. 6. We commit to reconciliation reporting through multiple channels. • We will transparently track and report on the actions we have taken, our successes, challenges and learnings. These reports will be made available through documents such as: – Our annual sustainability report – Periodic dedicated Reconciliation Action Plan reporting and updates – Our annual management information circulars • We will update TMX employees annually on our progress through existing internal channels.
19 | TMX Reconciliation Action Plan We started our work to advance truth and reconciliation in 2021, as soon as our shareholders and board passed a resolution committing us to our reconciliation journey. Since then, TMX Group has: • Attained Level 3 PAIR Committed status; • Hosted multiple learning opportunities for TMX employees to learn more about Indigenous history and major themes in reconciliation; • Reported on our work to advance our shareholder resolution in our information circulars and sustainability report; and • Launched TMX DOOR, a centralized platform designed to connect experienced and diverse candidates with leadership opportunities, and help provide critical data insights into board and management diversity trends. What We Are Doing Now
20 | TMX Reconciliation Action Plan As a company at the centre of the Canadian financial services sector, TMX Group recognizes we are in a unique position to create opportunities for Indigenous talent and for the next generation of Indigenous financial sector leaders. Our overarching aim in this pillar is to support the current and next generation of First Nations, Inuit and Métis talent. Our Commitments First Nations, Inuit and Métis Talent Pillar 4
21 | TMX Reconciliation Action Plan Pillar 4: First Nations, Inuit and Métis Talent 1. We will support scholarships for Indigenous students interested in post-secondary studies related to business and finance. • We will make a bursary available for Indigenous students through our partners at Indspire: the Bourse de Montréal Indigenous Education in Finance bursary currently contributes $25,000 per year from the Bourse de Montréal Fine Fund to support two Indigenous postsecondary students. The first bursaries were awarded in April 2025, and our initial commitment runs until 2029. • We will maintain relationships with the students we support to facilitate access to internships, career and networking opportunities. – We will invite learners and alumni to career fairs and TMX-sponsored events. – We will notify learners and alumni about career and co-op opportunities within TMX Group. – We will maintain contact and relationships with our bursary recipients. 2. We will actively recruit and support Indigenous talent in Canada. • We will survey our workforce to understand current Indigenous representation through a voluntary self-identification questionnaire. • We will work to increase the number of Indigenous applicants by advertising opportunities in Indigenous media and job boards and attending career fairs, and reaching out through our networks and partners. • We will work with post-secondary partners to make educational opportunities more available to Indigenous learners. Photo: Nick Wons
22 | TMX Reconciliation Action Plan We have started to act on our commitment to developing and supporting Indigenous talent. TMX Group has: • Launched two bursaries in partnership with Indspire, which have been made possible through the Bourse de Montréal Fine Fund; and • Launched our first voluntary self-identification survey so we can establish a baseline for Indigenous representation in our workforce, which will enable us to measure our progress over time. What We Are Doing Now
Wiigwaas unveiling event, 2022
About TMX Group (TSX:X) TMX Group operates global markets, and builds digital communities and analytic solutions that facilitate the funding, growth and success of businesses, traders and investors. TMX Group’s key operations include Toronto Stock Exchange, TSX Venture Exchange, TSX Alpha Exchange, The Canadian Depository for Securities, Montréal Exchange, Canadian Derivatives Clearing Corporation, TSX Trust, TMX Trayport, TMX Datalinx and TMX VettaFi, which provide listing markets, trading markets, clearing facilities, depository services, technology solutions, data products and other services to the global financial community. TMX Group is headquartered in Toronto and operates offices across North America (Montréal, Calgary, Vancouver and New York), as well as in key international markets including London, Singapore and Vienna. The commitments in this document apply to TMX Group’s operations in Canada only. tmx.com
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