Modern Slavery Report 2024 TMX Group Limited | 4 Assessment of Modern Slavery risk TMX Group’s view is that we operate within an industry (financial market infrastructure) where the risk of modern slavery is inherently limited. Given the nature of our business, the number of our goods suppliers, the location of our suppliers and contract value, we believe that the risk of modern slavery within our operations or supply chain is low. Notwithstanding this, TMX Group is firmly committed to monitoring and driving efforts to eradicate modern slavery risks in our operations and our supply chain, in adherence to the requirements of the Act, our stakeholders expectations and as part of our long-term sustainability objectives. After the enactment of the Act, an internal working group consisting of personnel from our risk, compliance, legal and procurement functions was created with the mandate of developing and delivering a modern slavery framework, consistent with the requirements of the Act. The working group’s assessment of modern slavery risk focused on our direct suppliers of goods in alignment with the requirements contained in the Act. Factors considered included: the goods category, the supplier country, the value of goods supplied and whether TMX Group was the importer of record of the goods. TMX Group consulted modern slavery data and resources1 and determined that the majority of our suppliers are based in countries that are at a low risk of modern slavery. That said, we recognize the possibility that their supply chain could include offshore manufacturers in higher risk regions. This assessment of TMX Group’s risk remains unchanged. Steps taken In living out our commitment relative to modern slavery risk, we have implemented a number of appropriate measures to raise awareness amongst our suppliers and our employee base and to ensure compliance with the requirements of the Act. 1 Walk Free Foundation Global Slavery Index and the US Department of Labor’s List of Goods Produced by Child Labor or Forced Labour Employee Code of Conduct Update Following the update to our Third Party Risk and Outsourcing Management (TPROM) Policy in 2023, we updated our Employee Code of Conduct which is applicable to all TMX Group employees and available on the TMX Group website. The Employee Code of Conduct now specifically reflects our stance against all forms of modern day slavery and our commitment to preventing adverse impacts of human rights violations in our operations and supply chains. Supplier Due Diligence Protocol We continued to implement the supplier due diligence processes that were developed in 2023 for procurement of goods from targeted suppliers outside of Canada and resellers, to enable the identification of potential risks or occurrences of forced and/or child labour in our operations and supply chains. In 2024, we expanded this process to include all of our direct goods suppliers. This process includes the following components: • Direct communication to all suppliers of goods raising awareness about the Act inclusive of a request to complete a questionnaire to gather information on the supplier’s policies and practices with regards to their management of modern slavery risks and compliance with the Act. • Tracking and reviewing responses to supplier questionnaires. • Using a third party service to identify sanctions and adverse media coverage which encompasses modern slavery, human trafficking and migrant smuggling.
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