Modern Slavery Report 2024 TMX Group Limited | 5 Supplier Code of Conduct In alignment with industry best practices, TMX Group developed a supplier code of conduct. This initiative has resulted in a near-final draft, establishing clear expectations for our suppliers with respect to modern day slavery, among other topics. We anticipate the formal adoption and implementation of this code in 2025, further strengthening our supplier due diligence process. Guidance on Purchasing Goods While TMX Group’s Strategic Procurement function oversees the majority of our procurement activities for our Canadian based businesses, certain purchases of goods below a threshold or falling into categories that are managed by other corporate functions may fall outside of the due diligence protocols that are implemented through Strategic Procurement. To raise awareness within the functions that manage these purchases (such as promotional items and office supplies), we developed guidance to promote best practices and ensure responsible sourcing across TMX Group. Awareness Training and Education Awareness about the requirements of the Act and the supplier due diligence process continued to be provided in priority to employees of the Strategic Procurement group, as they are the primary custodians of third-party suppliers due diligence management, and to TMX Group’s senior executives. In addition to the general awareness communications shared across our global workforce in 2023, our commitment to preventing adverse impacts of human rights violations in our operations and supply chains has been embedded in our Employee Code of Conduct which all employees are required to review annually. Assessing Effectiveness To assess the effectiveness of our efforts in preventing forced labour and child labour within our operations and supply chains, we engage in ongoing monitoring and collaborative review. This primarily involves evaluating supplier responses to due diligence questionnaires to identify potential risks. The working group also meets monthly to review our progress, including with respect to the implementation of our policies and procedures. Next steps Planned improvements for the coming year include sharing the Supplier Code of Conduct with all new goods suppliers, and providing training to select employee groups which may purchase goods independently of the Strategic Procurement function.
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