TMX GROUP LIMITED 2024 Annual Sustainability Report Where Business Meets Purpose
Report Contents 3 Message from our CEO 4 About TMX Group 5 About this Report Sustainability Reporting at TMX 5 Additional Resources 5 6 Sustainability Strategy Sustainability Pillars 6 Stakeholder Engagement 7 Sustainability Risk Management 8 9 Sustainability Governance REPORT CONTENTS ABOUT THIS REPORT SUSTAINABILITY STRATEGY SUSTAINABILITY GOVERNANCE PROSPERITY PLANET PEOPLE APPENDICES 10 Sustainability Pillar: Prosperity Building Resilience 10 Channeling Transition Capital 11 Evolving Products and Services 12 13 Sustainability Pillar: Planet Leading by Example 13 Protecting Healthy Ecosystems 18 Shaping Public Policy 19 21 Sustainability Pillar: People Workforce Representation 22 Inclusive Practices 23 Client, Market & Community Impact 25 26 Appendix A: SSE Initiative Aligned Activities 27 Appendix B: Climate-Related Risk & Opportunity Data 29 Appendix C: Our Emissions Data 31 Appendix D: Social Data 35 Appendix E: Governance Data 41 Appendix F: SASB Data Table 45 Endnotes
People Planet Prosperity 3 | T M X G R O U P S U S TA I N A B I L I T Y R E P O R T 2 0 2 4 On behalf of TMX Group, I am pleased to present our 2024 Sustainability Report, and to provide an update on the progress we have made across the enterprise in advancing TMX’s sustainability strategy. TMX Group occupies a unique position at the centre of Canada’s capital markets ecosystem: operator of our premier equities and derivatives markets, Toronto Stock Exchange and Montreal Exchange, as well as Canada’s public venture marketplace, TSX Venture Exchange. At the centre of this powerful engine of economic growth and opportunity, our purpose is to make markets better and empower bold ideas. It’s an enterprise commitment rooted in a proud history, and focused on ensuring a viable future for our stakeholders across this dynamic ecosystem. Our approach to sustainability also recognizes TMX’s responsibilities as corporate citizens. To deliver on this dual role requires an adaptive, thoughtful approach to sustainability. In 2023, we presented a new sustainability strategy that increased the alignment between our business, the needs of our clients and stakeholders, and the broader operating environment. The strategy – where business meets purpose – established three strategic pillars: Prosperity, Planet, and People. In 2024, we continued to advance our strategy, including through further integrating sustainability objectives into how we think and plan across the enterprise. This integration, and our focused advocacy, enables us to advance our initiatives and our product offerings in a way that is globally competitive and responsive to client needs – appropriately balancing the needs of our stakeholders with our obligations to our shareholders. Recognizing that successful climate action will require sustained collaboration across sectors and industries, Toronto Stock Exchange, in collaboration with several national organizations, launched Canada Climate Week Xchange™ (CCWX™). At our first event in 2025, CCWX will curate and promote a variety of events focused on Canada’s unique perspective and prospects on climate-related issues. The advances we have made are the result of the dedicated efforts of our people, and I would like to thank our employees for their unwavering commitment to excellence. I encourage you to read TMX Group’s 2024 Sustainability Report to learn more. Thank you for your continued support. Sincerely, John D. McKenzie Chief Executive Officer TMX Group Limited May 6, 2025 A Message From Our CEO Sustainable long-term growth and enabling the scaling of climate solutions Demonstrating sustainability performance that fosters healthy ecosystems Fostering a fair, diverse and inclusive culture of belonging for our people, communities and markets REPORT CONTENTS ABOUT THIS REPORT SUSTAINABILITY STRATEGY SUSTAINABILITY GOVERNANCE ENTERPRISE RISK MANAGEMENT PROSPERITY PLANET PEOPLE OPERATING RESPONSIBLY APPENDICES
4 | T M X G R O U P S U S TA I N A B I L I T Y R E P O R T 2 0 2 4 About TMX Group 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 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. For more information about TMX Group, visit www.tmx.com. Follow TMX Group on X: @TMXGroup. Please contact TMX Group if you have any additional questions or require further clarification. General Enquiries 300-100 Adelaide St. West Toronto, ON M5H 1S3 T +1 888 873-8392 info@tmx.com Purpose We make markets better and empower bold ideas Mission We power capital and commodity markets with client-centric, technology-driven global solutions Vision To be an indispensable solution for companies around the world to raise capital and the preferred destination for traders and investors to prosper
5 | T M X G R O U P S U S TA I N A B I L I T Y R E P O R T 2 0 2 4 Sustainability Reporting at TMX This report presents information on TMX Group Limited’s sustainability strategy and its performance related to environmental, social and governance issues for the financial year ended December 31, 2024. Throughout the report, “TMX Group,” “TMX” or “we” or “us” or “our” refers to TMX Group Limited. As reported in our 2023 Sustainability Report, we engaged in a comprehensive and structured review of our sustainability strategy in 2023 to ensure that our sustainability-related initiatives and activities are fully aligned with our purpose to make markets better and empower bold ideas. In the pages that follow, we detail the progress we made in 2024 on implementing that strategy, fulfilling our commitment to measuring and reporting social and environmental impacts, and in particular, to continuing to improve the quality of our data. We regularly monitor the development of sustainability reporting regulations, standards and frameworks for their relevance and usability, along with the expectations of our stakeholders regarding these standards. Our disclosures are informed by and aligned with the Sustainability Accounting Standards Board (SASB) and our reconciliation table can be found in Appendix F. This year, we continued refining our carbon emission accounting exercise by improving inventory quality and quantification processes as set out in the Planet section of this report. We also continue to participate in the annual S&P Global Corporate Sustainability Assessment and CDP Corporate Questionnaire. The performance data footnotes include commentary regarding restatements or data changes, where applicable. All amounts in this document are in Canadian dollars unless otherwise noted. Certain sections of this report may contain forward-looking information as detailed in Endnotes. Additional Resources This report is focused on the performance, activities and operations of TMX Group that support our sustainability strategy. It complements information on the results of our operations and financial condition in our 2024 Annual Report and our governance and executive compensation information in our 2025 Management Information Circular. Our sustainability reports from previous years are available under our Investor Relations tab at www.tmx.com. About This Report REPORT CONTENTS ABOUT THIS REPORT SUSTAINABILITY STRATEGY SUSTAINABILITY GOVERNANCE PROSPERITY PLANET PEOPLE APPENDICES
6 | T M X G R O U P S U S TA I N A B I L I T Y R E P O R T 2 0 2 4 Sustainability Strategy REPORT CONTENTS ABOUT THIS REPORT SUSTAINABILITY STRATEGY SUSTAINABILITY GOVERNANCE PROSPERITY PLANET PEOPLE APPENDICES Our 2023 Sustainability Report presented our sustainability strategy “where business meets purpose”, that is aimed at driving progress and sustainable growth through the lens of three pillars: prosperity, planet and people. We remain engaged in this approach that we believe furthers our vision to make markets better and empower bold ideas and is anchored in meeting the needs of our stakeholders now and in the future. Viewing sustainability in this way means continuously working toward integrating sustainable practices into every part of our operations while maintaining focus on our financial performance and supporting our desire to increase our global reach. Sustainability Pillars PROSPERITY PLANET PEOPLE Sustainable long-term growth and enabling the scaling of climate solutions Building a sustainable TMX that enables climate action both by supporting issuers through the transformation of the economy and by channeling capital toward sustainable pursuits. • Building resilience • Channeling transition capital • Evolving products and services Demonstrating sustainability performance that fosters healthy ecosystems Setting an example by reducing our carbon footprint and collaborating with partners to support healthy ecosystems that form the basis of economic value creation and human life. • Leading by example • Protecting healthy ecosystems • Shaping public policy Fostering a fair, diverse and inclusive culture of belonging for our people, communities and markets Nurturing the diversity of our workforce through an inclusive culture of belonging that creates value for our business and our stakeholders by empowering our communities and building diverse markets. • Workforce representation • Inclusive practices • Client, market & community impact
7 | T M X G R O U P S U S TA I N A B I L I T Y R E P O R T 2 0 2 4 REPORT CONTENTS ABOUT THIS REPORT SUSTAINABILITY STRATEGY SUSTAINABILITY GOVERNANCE PROSPERITY PLANET PEOPLE APPENDICES TMX GROUP LEADERSHIP OUR PEOPLE • Board of directors • Governance and regulatory oversight committee • Human resources committee • Audit committee • Senior management team • Executive operating and risk committee • All-employee meetings and town halls • Employee engagement surveys • Intranet and events (in-person and virtual) • Learning and development programs • Performance evaluations • Whistleblower hotline CLIENTS AND CUSTOMERS SHAREHOLDERS • Sustainability products and tools • Education resources, webinars and podcasts • Conferences and meetings • Opinion surveys • ESG data and analytics • Investor outreach, presentations and meetings • Roadshows and conferences • Investor relations website • Annual meeting of shareholders • Quarterly investor calls • Investor surveys REGULATORS AND GOVERNMENTS OUR COMMUNITIES • Public policy discussions and advocacy • Standard setting organizations and regulators • Conferences, panels and roundtables • Association memberships • Community investment and partnerships • Team Impact and employee volunteering • Market ceremonies • Conferences and events Stakeholder Engagement We continue to engage with our stakeholders to better understand the sustainability issues that are most significant to them. This broad range of perspectives ensures that we can adapt our sustainability initiatives to serve evolving needs and trends. In keeping with our desire to lead in an authentic and purposeful manner, we will balance this broad range of perspectives with the results of a materiality assessment of our sustainability related risks and opportunities conducted in early 2025. This exercise, involving both internal and external stakeholders, will allow us to refresh our previous climate-specific materiality assessment and expand the assessment scope to include other sustainability topics. The results of this assessment are currently being analyzed and will be shared in our next report.
8 | T M X G R O U P S U S TA I N A B I L I T Y R E P O R T 2 0 2 4 REPORT CONTENTS ABOUT THIS REPORT SUSTAINABILITY STRATEGY SUSTAINABILITY GOVERNANCE PROSPERITY PLANET PEOPLE APPENDICES Sustainability Risk Management TMX provides essential services to the Canadian capital and global commodity markets. Effectively and consistently managing risks and objective certainty is fundamental to our ability to execute on our enterprise and business strategies. Enterprise risk management facilitates and supports the businesses in meeting their objectives to ensure the outcomes of these activities are transparent and understood, consistent with our risk appetite, appropriately balance risk and reward, and serve as inputs into the enterprise strategy formulation process. For information about our risk management principles, our Objective Centric Risk Management (OCRM) approach and the governance of risk at TMX, please refer to pages 83 to 84 of our 2024 Annual Report and page 23 of our 2025 Management Information Circular. We continue to integrate sustainability objectives and initiatives into our core objectives to manage and respond to key and emerging sustainability and climate risks and opportunities in the long and short-term. Through our OCRM process, we assess sustainability-related risks against our strategic objectives and their sustainability components. We are strengthening this process by establishing a clear sustainability-specific risk appetite and defining clear sustainability risk ownership across all organizational levels. Key sustainability risks, which will be updated on completion of the sustainability materiality assessment, include those related to the resilience of our critical business functions, climate related risks (physical and transition), cybersecurity and information security, and talent attraction and retention1. Recognizing that the complex evolution and accelerated pace of change in society, business, and disclosures can impact our ability to attract and retain listings, we prioritize proactive stakeholder engagement through feedback mechanisms, partnerships and materiality assessments. Furthermore, we are enhancing our adaptability by implementing robust horizon scanning and scenario planning, investing in sustainable innovation and technology, and fostering continuous improvement in sustainability risk management. The processes allow us to address these risks and create long-term value. 1 Please refer to our 2024 Annual Report on p. 84 and the following for a more comprehensive list of the top material risks to TMX Group’s business.
9 | T M X G R O U P S U S TA I N A B I L I T Y R E P O R T 2 0 2 4 REPORT CONTENTS ABOUT THIS REPORT SUSTAINABILITY STRATEGY SUSTAINABILITY GOVERNANCE PROSPERITY PLANET PEOPLE APPENDICES Responsibility for the oversight of sustainability is included in the charter of our Board of Directors (Board) as well as three standing committees of the Board that each have various sustainability-related responsibilities. To align our approach across the enterprise and drive the operationalization of our sustainability strategy across TMX, our governance framework sets out responsibilities for senior management-level committees (which oversee and support a coordinated, enterprise-wide approach to sustainability) and our sustainability enterprise team and cross-business working groups that execute and implement our sustainability strategy on a day-to-day basis. Sustainability Governance BOARD OVERSIGHT SENIOR EXECUTIVE OVERSIGHT IMPLEMENTATION TMX Group Board of Directors2 (Charter) Oversees sustainability strategy and sustainability and climate-related objectives, risks and opportunities. Governance and Regulatory Oversight Committee (Charter) Oversees sustainability and ESG reporting and, supported by Enterprise Risk Management, sustainability and climaterisk related risks. Senior Management Team Strategy Committee (Chair: Chief Executive Officer) Sets enterprise strategy, aligns required resources for its execution and regularly reports on progress to the Board and committees. Sustainability Enterprise Team (Lead: VP, Governance and Sustainability) Coordinates and monitors sustainability strategy implementation and oversees sustainability disclosures and communications Human Resources Committee (Charter) Oversees executive compensation, ESG objectives and ED&I.3 Executive Operating and Risk Committee (Chair: Chief Operating Officer) Monitors overall operational resilience including the management of sustainability and climate related risks and opportunities. Sustainability Working Group5 (Chair: Head, Sustainability and ESG Strategy) Executes and delivers on sustainability strategy. Audit Committee4 (Charter) Oversees sustainability and climate related risk management. Equity, Diversity & Inclusion Council (Sponsors: Chief Executive Officer and Chief Human Resources Officer) Employee-led body developing and supporting the execution of programs and policies supporting the ED&I strategy. 2 Please refer to page 32 of our 2025 Management Information Circular for information on our Board’s various areas of expertise including sustainability. Additional information regarding the Board can also be found in Appendix E. 3 Please refer to page 44 of our 2025 Management Information Circular for information on how sustainability is integrated into executive compensation at TMX. 4 Subject to regulatory approval, the Finance and Audit Committee will be renamed Audit Committee. 5 Implementation to progress in 2025.
1 0 | T M X G R O U P S U S TA I N A B I L I T Y R E P O R T 2 0 2 4 Building Resilience TMX Group plays a central, facilitating role in Canada’s economic transition to a low-carbon future, while prioritizing revenue growth for shareholders. This involves enhancing issuers’ resilience to shifting market conditions, attracting new listings by fostering capital flow opportunities, and directing capital towards the financing and scaling of decarbonization technologies. We also recognize the importance of enabling resource companies, including those in sectors like energy and mining, to transition while remaining globally competitive. We are committed to ensuring that companies, especially small and medium enterprises (SMEs) who represent the majority of our public companies, can access the transition capital necessary to fuel innovation and future economic growth. Supporting the Sustainable Growth of Companies Operating an exchange such as TSXV, designed specifically for SMEs, is recognized by the United Nations Sustainable Stock Exchanges (SSE) Initiative as an activity in advancement of sustainability in the markets in which we operate (see also Appendix A). TSXV also offers specialized structures, policies and programs to support and promote venture and growth stage companies active in all sectors, including those that support the low-carbon transition (mining, cleantech, renewable energy), to access public markets earlier in their life cycle. • TSX lists over 1,800 issuers and funds and close to 1,600 growth stage companies are listed on TSXV • Over 770 companies have graduated from TSXV to TSX and graduates currently comprise 22% of S&P/TSX Composite Index issuers • Close to $21 billion of equity capital was raised on TSX and TSXV in 2024 Promoting Transparent and Efficient Capital Markets TSX and TSXV implement rules, policies and other similar instruments around governance and disclosure for our issuers. Our quality standards for our issuers are layered on top of requirements under securities law and corporate law to ensure our exchanges operate in a manner consistent with the public interest, which includes protecting our clients and capital markets stakeholders from unfair or improper practices and fostering fair and efficient capital markets. Sustainability Pillar: Prosperity REPORT CONTENTS ABOUT THIS REPORT SUSTAINABILITY STRATEGY SUSTAINABILITY GOVERNANCE PROSPERITY PLANET PEOPLE APPENDICES Useful Links • TSX Venture Exchange • Capital Pool Company® program • TSX Venture 50® recognition program • Canadian Climate Investor Conference
1 1 | T M X G R O U P S U S TA I N A B I L I T Y R E P O R T 2 0 2 4 REPORT CONTENTS ABOUT THIS REPORT SUSTAINABILITY STRATEGY SUSTAINABILITY GOVERNANCE PROSPERITY PLANET PEOPLE APPENDICES Channeling Transition Capital Canada’s economy is strongly linked to its natural resources, which are essential to its GDP. As the world’s energy systems evolve, Canada’s resources remain a crucial asset. The global move toward electrification increases the need for resources like copper, platinum, manganese, and uranium for energy modernization; as well as lithium, cobalt, and nickel while growing populations require potash for food production. Canadian energy resources, including oil, natural gas, and hydrogen, produced responsibly, are key to global energy security and can support emissions reductions internationally during the transition to lower-carbon energy. Climate Related Opportunities Our businesses and issuers are well positioned to be at the forefront of this transition, and TMX Group is focused on facilitating transition capital opportunities that will help finance and scale climate solutions and economic growth6. Our sustainable business growth objectives include: • Expanding our global reach to attract clients across all sectors • Accelerating growth in key sectors, including innovation, clean technology, and renewable energy, while maintaining our focus on the resource sector • Supporting the energy sector’s decarbonization and lowcarbon mineral issuers Our commitment to building support for these sectors extends to connecting issuers and leading private companies with retail and institutional investors through recurring cleantech investor conferences: • TSX Cleantech Investor Day: Leading public and private cleantech companies presenting to institutional investors • Annual Canadian Clean Energy Conference: Institutional investor meetings hosted in partnership with National Bank Financial Markets in London, UK • Canadian Climate Investor Conference: Concerted effort to connect issuers with retail investors and build the retail investor base for the cleantech and renewable energy sector over the long-term Governance and Sustainability Resources for Issuers TSX and TSXV are committed to supporting all our issuers by promoting strong corporate governance and sustainability practices. This includes guiding companies towards providing comparable, decisionrelevant, standardized ESG disclosure, leveraging globally recognized standards and frameworks and advocating on behalf of its issuers for guidelines well adapted to the Canadian ecosystem. We provide issuers with resources, facilities and educational opportunities to assist them in navigating through various regulatory requirements and investor expectations. Such tools also align with the recommendations of the SSE. INITIATIVE DESCRIPTION ESG 101 Resource Hub Central repository of resources, guides, articles, and events from leading experts, peers and agencies on sustainability topics including Indigenous relations and modern slavery Education and Support Tools Thought-leadership and tool development to assist issuers with climate reporting and GHG emissions assessments, in collaboration with Carbonhound: a Canadian-owned business that specializes in GHG emission accounting solutions Sustainability Reporting Practices for New Reporters General guidance for new reporting companies supplemented by a TMX ESG Template, a basic reporting tool based on leading frameworks Growth Accelerator Education Program Complimentary one-on-one education and mentorship program including both a Governance and an ESG module 6 For more information on how we track climate-related risks and opportunities, consult Appendix B.
1 2 | T M X G R O U P S U S TA I N A B I L I T Y R E P O R T 2 0 2 4 REPORT CONTENTS ABOUT THIS REPORT SUSTAINABILITY STRATEGY SUSTAINABILITY GOVERNANCE PROSPERITY PLANET PEOPLE APPENDICES Evolving Products and Services By expanding our sustainability offerings, TMX Group can help issuers and investors improve their sustainability performance and increase the visibility of high-performing, innovative sustainability leaders to investors. Leveraging our market infrastructure and the TMX ESG Data Hub, TMX Group facilitates capital allocation to green and transition activities. TMX Group also provides a range of products and services for issuers and investors to manage sustainability exposure. PRODUCT / SERVICE DESCRIPTION The Voluntary Climate Marketplace (TVCM) TVCM, operated by IncubEx and underpinned by TMX Trayport’s Joule™ platform, offers market access to trade voluntary carbon offsets. TVCM connects to leading, global registries through a low cost, open access marketplace where corporate buyers purchase verified carbon offset credits, selecting from attributes aligned with their bespoke objectives. TVCM participants place live bids and offers into the market with transparent pricing. TMX ESG Data Hub Working with leading data and analytics providers, the TMX ESG Data Hub delivers sustainability data to global clients in support of ESG integration in investment decisionmaking processes. In 2024, TMX Datalinx onboarded two additional partners to enhance our content offering which now includes impact ratings, underlying environmental and impact data, net-zero alignment datasets, company screening and controversies, news and events, biodiversity, physical asset data and climate analytics. Sustainability-related indices We offer sustainability-related indices administered through our partnership with S&P Dow Jones Indices and our indexing division, TMX VettaFi, for example: • S&P/TSX Energy Transition Materials Index* tracks the performance of North American listed securities engaged in mining, exploration, or manufacturing of energy transition materials • S&P/TSX Renewable Energy and Clean Technology Index* measures performance of TSX-listed companies whose core business is the development of green technologies and sustainable infrastructure solutions • TMX VettaFi’s Canadian Council for Indigenous (PAIR) Business Index tracks companies committed to improving Indigenous Relations. Sustainable derivatives and stocklists Montreal Exchange (MX), our derivatives trading business, offers equity options and share futures on all of the constituents of select sustainability related indices and sustainability index futures. TMX Money® helps retail investors research and discover companies that are listed on TSX and TSXV as well as Sustainable TSX-listed funds such as WiG Parity Certified, PAIR Certified, PAIR Committed companies and Sustainable ETFs.
1 3 | T M X G R O U P S U S TA I N A B I L I T Y R E P O R T 2 0 2 4 Sustainability Pillar: Planet REPORT CONTENTS ABOUT THIS REPORT SUSTAINABILITY STRATEGY SUSTAINABILITY GOVERNANCE PROSPERITY PLANET PEOPLE APPENDICES Leading by Example Decarbonizing the global economy is essential for long-term economic value creation and to sustain human life. From our position at the centre of Canada’s capital markets, we are committed to leading by example by continuing to integrate sustainability into our enterprise strategy, develop a climate transition plan to reduce our emissions and collaborate with stakeholders to support healthy ecosystems. Management of Climate Related Risks Our governance and enterprise risk management allows us to continuously manage climate-related risk and opportunities and help deepen and accelerate the integration of sustainability goals and objectives to the overall enterprise strategy and within each business unit. By proactively identifying issues most relevant to TMX Group and our stakeholders, we can respond and plan appropriately to address these risks. We assess the potential impact of physical and transition risks and opportunities from climate change based upon time horizons of short-term (2 years), medium-term (5 years) and long-term (10 years).
1 4 | T M X G R O U P S U S TA I N A B I L I T Y R E P O R T 2 0 2 4 REPORT CONTENTS ABOUT THIS REPORT SUSTAINABILITY STRATEGY SUSTAINABILITY GOVERNANCE PROSPERITY PLANET PEOPLE APPENDICES RISK TYPE DESCRIPTION MITIGATION & APPROACH TO RISK Physical Risk Acute and Chronic On a short-term and longer term basis, the increased severity of extreme weather events such as flooding, hurricanes, wildfires, cold or heat waves resulting from climate change could lead to power supply disruptions to key market infrastructure and/or create physical workplace access issues for employees. On a longer time horizon, changes in long-term climate conditions, including sea-level rise, changing patterns of precipitation, temperature or wind, could disrupt the production or operations of our listed issuers impacting their financial performance, with negative impacts to our business. We have a robust Business Resilience Management program to respond to disruptions when they arise. TMX Group’s Business Continuity Plans are designed to ensure continuous operations in the face of natural disasters and other physical risks associated with climate change. It is reviewed, at minimum, on an annual basis and more frequently if required. Transition Risk Concentration, shift in consumer preferences and sectoral stigmatization7 While TMX Group operates a globally diversified business, our performance is affected by the Canadian economy, a portion of which is based in natural resources and energy related businesses. As such, we are exposed to macroeconomic factors that impact these sectors, including those driven by environmental regulations, the transition to a low carbon economy and the growth of sustainable investing. In 2024, trading concentration by volume across mining and oil and gas sectors was 36% and 14%, respectively. In addition, TSX and TSXV depend on an adequate number of clients to maintain fair markets. Finally, listing (including IPOs), initial and additional financing, trading and clearing activities are also significantly affected by global economic, political and market conditions and the overall level of investor confidence. Any sustained fluctuation in the natural resources and energy sectors, including a downturn if those businesses fail to transition to greener undertakings as quickly as the market demands, or a general erosion of investor confidence, has the potential to impact our financial performance, including investment performance, the number of listed issuers, trading and transaction volumes across our trading, and market data sales, impacting our operating results. A significant loss of trading volume, listing activity or market capitalization in these sectors could impact our performance and limit our ability to build and support robust transition finance markets. To measure our exposure to resource-related sectors specifically, we track the aggregated activities of the mining, oil and gas and utilities and pipelines sectors as a percentage of the overall market capitalization on TSX and TSXV: Resource-related Issuer Base as a percentage of Total Market Capitalization (TSX & TSXV) % of Total Market Cap We focus on attracting increasingly global clients and targeting growth in innovation, clean technology and renewable energy, which builds on our existing advantage. By becoming a destination for transition finance, TMX Group can support the allocation of capital toward the decarbonization of our energy sector and the financing and scaling of climate solutions which presents an opportunity for resource sector issuers. 7 For additional information, please consult p. 84 and 86 of our 2024 Annual Report.
1 5 | T M X G R O U P S U S TA I N A B I L I T Y R E P O R T 2 0 2 4 REPORT CONTENTS ABOUT THIS REPORT SUSTAINABILITY STRATEGY SUSTAINABILITY GOVERNANCE PROSPERITY PLANET PEOPLE APPENDICES RISK TYPE DESCRIPTION MITIGATION & APPROACH TO RISK Transition Risk Policy & Legal Enhanced climate reporting obligations: mandated sustainability and climate disclosure obligations could have a varying impact on our issuers depending on the construct and timing of the requirements. Enhanced public company reporting obligations may result in a decrease in attractiveness in listing publicly due to increased compliance costs. A decrease in new listings or increase in de-listings may negatively impacting our business. Emissions reduction policies: more stringent emissions reduction policies such as carbon pricing and enduring uncertainty relative to these policies can impact our issuers and level of investments in Canada. TMX Group has developed products and services to support issuers in addressing evolving stakeholder expectations on climate and sustainability disclosures, recognizing that comprehensive and robust disclosures are critical to overall market resilience and capital markets investor protection. Through our regulatory compliance management process, client and policy engagements, and industry forum participation, we continue to monitor new and emerging climate-related requirements and update our processes, policies and frameworks as necessary. TMX Group continues to advocate on the role of Canadian capital markets in addressing climate change as well as the specific issues faced by public market participants (e.g., sustainability and climate disclosures, harmonization of standards). Reputation Given our central position in the capital markets ecosystem, TMX Group has a critical role in supporting Canadian capital markets and our clients through the transition to a lower carbon economy as well as addressing other sustainability needs. Failure to address this shift and demonstrate leadership may impact our reputation and the attractiveness of our markets to Canadian and global investors. While we continue to integrate climate change considerations into our strategic and investment considerations, we actively manage climate risks and opportunities through our enterprise risk management practices. We recognize the unique position of TMX Group in Canadian capital markets and the role we play in supporting our issuers as public companies promoting strong sustainability practices. We seek to lead by example by improving our carbon footprint measurements and management and by supporting issuers in addressing climate change to further investor confidence in Canadian capital markets. We publish annual sustainability reports, support the development of a global baseline for sustainability and climate disclosures and provide education and services for issuers and investors to provide the marketplace with decision-relevant information.
1 6 | T M X G R O U P S U S TA I N A B I L I T Y R E P O R T 2 0 2 4 REPORT CONTENTS ABOUT THIS REPORT SUSTAINABILITY STRATEGY SUSTAINABILITY GOVERNANCE PROSPERITY PLANET PEOPLE APPENDICES Our GHG Emissions In implementing our commitment to measuring and reporting our emissions and to continuously improve the quality of our data, TMX Group worked again with a third party service provider to inventory our 2024 carbon emissions in accordance with the Greenhouse Gas Protocol Corporate Standard (“GHG Protocol’’). Our below inventory includes Scope 1, Scope 2 and categories of Scope 3 emissions deemed relevant.8 All major TMX Group offices and facilities were covered, following the “operational control” consolidation approach of the GHG Protocol. INVENTORY CATEGORY ACTIVITY (TCO2E) 2024 2023 % VARIATION Scope 1 Stationary Combustion 50 55 -9% Scope 2 (Market-Based) Electricity 1,689 1,828 -8% Scope 3 Indirect Emissions 6,520 4,319 51% Total Gross Emissions (Market-based) 8,259 6,202 33% Emissions intensity tCO2e per FTE 3.7 3.2 15% tCO2e per revenue9 ($ million) 5.7 5.2 9% 20.4% Scope 2 0.6% Scope 1 79% Scope 3 8 A comprehensive view of our inventory, inclusive of detailed methodological changes is provided in Appendix C. 9 Based on TMX Group’s reported 2024 revenue, p.21 of our 2024 Annual Report. 2024 Carbon Emissions by Scope Key drivers behind the 8% year-over-year reduction in our combined Scope 1 and 2 emissions (from the 2023 base year) include impacts from implementing our real estate strategy to centralize activities, improving resource efficiency in our offices despite increased FTE count, and for the first time utilizing clean energy and renewable energy certificates.
1 7 | T M X G R O U P S U S TA I N A B I L I T Y R E P O R T 2 0 2 4 REPORT CONTENTS ABOUT THIS REPORT SUSTAINABILITY STRATEGY SUSTAINABILITY GOVERNANCE PROSPERITY PLANET PEOPLE APPENDICES As we work toward setting science-based emissions reduction targets, we have begun work to align with the Science Based Targets initiative (SBTi) requirements. For this exercise, we integrated new categories of Scope 3 emissions such as upstream Fuel and Energy-Related Activities (not included in Scope 1 or 2)10. Following the completion of acquisitions, including TMX VettaFi in January 202411, the emissions associated with new entities and previously reported under the Investment category were reclassified to reflect these updates to our organizational boundary and their new status as wholly-owned and operationally controlled subsidiaries. To gain a more complete understanding of our value chain impact, we’ve also broadened our emissions inventory and recategorized common area emissions from our office buildings, as well as new emissions from coworking and shared subleased real estate to Scope 3, now encompassing Upstream and Downstream Leased Assets. In the Fall of 2024, we conducted our first voluntary Employee Commuting Survey, engaging staff from all of our office locations globally to share information on their commuting and work-from-home habits. We have integrated this data into our accounting practices and recalculated our 2023 emissions to reflect this methodology change. The 2024 increase in emissions can be attributed to a FTE count increase combined with the inclusion of employee commuting-related well-totank emissions. Breakdown of 2024 Scope 3 Emissions We will continue to refine our understanding of our emissions profile, especially as it relates to indirect scope 3 emissions, to progressively align with the more comprehensive GHG Protocol Corporate Value Chain Scope 3 Standard. Improving our data collection practices and working more closely with a growing number of internal and external stakeholders has already enabled us to access more granular and expanded datasets. These process improvements are at the root of the growth of reported emissions, particularly as it relates to Purchased Goods and Services. This enhanced data quality and scope are key drivers behind the anticipated recalculation of our emissions as we continuously align with the latest industry best practices. We expect to be in a position to report to this level in our next report, with likely impacts to our overall footprint. 0.3% Upstream Leased Assets 57.6% Purchased Goods & Services 10% Capital Goods 4.0% Fuel and Energy Related Activities 2.2% Waste Generated in Operations 11.7% Business Travel 13.8% Employee Commuting 0.0% Downstream Transportation & Distribution 0.2% Downstream Leased Assets 0.2% Investments 10 This includes three primary emission sources: upstream emissions from purchased electricity; transmission and distribution (T&D) losses; and well-to-tank (WTT) emissions associated with both upstream and downstream transportation in our value chain. 11 TMX Group, TMX Group Completes Acquisition of Vettafi [Press Release], 2024-01-02.
1 8 | T M X G R O U P S U S TA I N A B I L I T Y R E P O R T 2 0 2 4 REPORT CONTENTS ABOUT THIS REPORT SUSTAINABILITY STRATEGY SUSTAINABILITY GOVERNANCE PROSPERITY PLANET PEOPLE APPENDICES Protecting Healthy Ecosystems Recognizing the interdependence of continued economic growth, healthy ecosystems, and climate resilience, we are committed to neutralizing our carbon footprint and reducing our emissions by developing a climate transition plan. We also believe that strong and transparent carbon markets, such as The Voluntary Climate Marketplace (TVCM) powered by TMX Trayport, play a vital role in enhancing global ecosystem health. Neutralizing and Reducing Emissions To offset our 2024 annual reported gross Scope 1, 2, and 3 emissions, we have purchased and retired voluntary carbon offset credits through TVCM, a practice we have maintained since fiscal year 2020. We select carbon offsets from verified, credible, industry-leading registries, prioritizing projects based on their geographical location and the socio-economic benefits they provide. Our intention is to progressively reduce our reliance on carbon offsets by identifying opportunities for emissions reductions as we develop and implement our climate transition plan. All of our major corporate sites in Canada are Leadership in Energy and Environmental Design (LEED®) certified and, as of December 31, 2024, 83% of TMX Group’s total office footprint was LEED® certified or in the process of certification.12 LEED® is the most widely used green building rating system in the world and a globally recognized symbol of sustainability achievement and leadership. LEED® certification has been integrated as a criteria for all future real estate office space as part of TMX’s real estate strategy. Our TMX Trayport London office has the ISO 14001 and ISO 9001:2015 environmental management systems accreditation. 12 We shifted from reporting specific levels of LEED certifications across the properties leased for our office locations due to the challenges associated with ensuring we capture updated data from landlords and in alignment with our criteria for future real estate office space selection.
1 9 | T M X G R O U P S U S TA I N A B I L I T Y R E P O R T 2 0 2 4 REPORT CONTENTS ABOUT THIS REPORT SUSTAINABILITY STRATEGY SUSTAINABILITY GOVERNANCE PROSPERITY PLANET PEOPLE APPENDICES Shaping Public Policy Given our central position in Canada’s capital markets and strong relationships with issuers, financial institutions, regulators, and governments, we aim to maximize our impact beyond our direct operations. We do this by partnering with like-minded organizations and working with governments to shape policies that facilitate capital flow to transition and decarbonization activities, while ensuring market competitiveness. TMX Group complies with all applicable lobbying legislation and codes of conduct in every jurisdiction where it is actively lobbying. We have a management system in place to monitor our lobbying and government communications activities along with business and trade association memberships. TMX Group does not use corporate funds to donate to political candidates or parties in accordance with the Canada Elections Act and all similar applicable provincial legislation. TMX Group is committed to: Supporting the implementation of globally comparable and consistent sustainability and climate disclosure standards, such as the Canadian Sustainability Standards Board (CSDS 1 and 2), for companies that choose to report on their sustainability and climate-related issues. Advocating for clear labels and criteria for green and transition activities to facilitate the development and financing of aligned projects and supporting investment products by companies, investors, and capital markets. Promoting the evolution of domestic carbon markets to enhance transparency, liquidity, and price discovery as essential tools for financing carbon emission reduction and removal. Supporting measures that foster the growth of renewable energies, including: • Enhancing access to capital for critical minerals companies • Modernizing Canada’s Scientific Research & Experimental Development tax credits to provide direct support to innovation companies including cleantech companies • Expanding the utilization of flow-through shares to emerging sectors, such as cleantech Fostering a transparent, predictable, and streamlined investment environment for responsibly developed major projects in infrastructure and natural resources.
2 0 | T M X G R O U P S U S TA I N A B I L I T Y R E P O R T 2 0 2 4 REPORT CONTENTS ABOUT THIS REPORT SUSTAINABILITY STRATEGY SUSTAINABILITY GOVERNANCE PROSPERITY PLANET PEOPLE APPENDICES Sustainability Memberships, Endorsements and Engagements International Sustainability Standards Board (ISSB) and Canadian Sustainability Standards Boards (CSSB) TMX Group has been a long-standing supporter of the development of a global baseline for sustainability and climate-related disclosures that will provide the investment community with consistent, robust and above all else, useful information for investment decision-making. The International Sustainability Standards Board’s (ISSB) climate and sustainability disclosure standards provide the foundation for such a global baseline. Given our central role in the Canadian capital markets and as owner and operator of TSX and TSXV, TMX Group has regularly engaged with the ISSB, the CSSB, the CSA and other market participants to ensure that these standards are applied in a way that is calibrated to Canada’s unique marketplace and recognize the importance of proportionality, materiality and global competitiveness. United Nations Sustainable Stock Exchanges (SSE) Initiative TMX Group’s equities and derivatives exchanges (TSX, TSXV, and Montreal Exchange) are active members of the SSE Initiative, which promotes sustainable performance and transparency in capital markets. This membership allows TMX Group to report its sustainability efforts (see Appendix A) in comparison to other exchanges and provides access to global thought leadership, educational content, and knowledge-sharing opportunities. World Federation of Exchanges (WFE) - Sustainability Working Group TMX Group is a member of the World Federation of Exchanges, the global industry group for exchanges and clearing houses, which promotes an orderly, secure, fair, and transparent environment for investors and market participants. Within the WFE, TMX Group actively participates in the WFE Sustainability Working Group to define the role of exchanges as sustainable financial markets evolve. We also contribute to the WFE’s Annual Sustainability Survey, which captures global progress and challenges in exchanges’ engagement with ESG issues. In 2024, we partnered with the organization to host the WFE Global Sustainability Meeting at the TMX Market Centre on June 5, 2024. This event brought together leaders from member exchanges and sustainability experts worldwide to discuss the evolving landscape of sustainability reporting standards, the challenges they pose for corporations, and the role exchanges can play in supporting issuers. Additionally, on November 22, 2024, we joined 34 other exchanges in WFE’s Ring the Bell for Climate campaign with a dedicated market open ceremony. This ceremony convened stakeholders who are partners in advancing sustainable and transition finance in Canada. Canada Climate Week Xchange (CCWX) With the intent of accelerating Canada’s climate goal, TSX announced the establishment of Canada Climate Week Xchange on November 25, 2024. Launching in 2025, this five-year initiative will bring together diverse organizations, including publicly-listed companies, to champion Canada’s commitment to significant reductions in greenhouse gas emissions by 2030, through events dedicated to addressing Canada’s climate-related challenges and opportunities. Collaborating with TSX on this initiative are its founding members, Canada Climate Law Initiative, CPA Canada, First Nations Financial Management Board, GLOBE, and the Responsible Investment Association. Together, the group encourages Canadian organizations and individuals to apply to have their events included in the inaugural CCWX, which will run from November 24 to 30, 2025.
2 1 | T M X G R O U P S U S TA I N A B I L I T Y R E P O R T 2 0 2 4 REPORT CONTENTS ABOUT THIS REPORT SUSTAINABILITY STRATEGY SUSTAINABILITY GOVERNANCE PROSPERITY PLANET PEOPLE APPENDICES We are committed to leading by example by fostering a fair, diverse and inclusive culture of belonging that results in positive change for the people, communities and markets we serve. Our goal is first and foremost to be thoughtful and deliberate in our strategy and focus on initiatives that will have the most meaningful and long-term impact on TMX Group, our employees, and the communities in which we work across the globe. Through the implementation of our long-term Equity, Diversity and Inclusion (ED&I) strategy, our employee-led global ED&I Council has been delivering programs and policies that support a rewarding employee experience and positively impact our clients, markets and communities. In 2024, key accomplishments included piloting an inaugural employee resource group for women and their allies, advancing our analytics capabilities through the development of a new self-identification questionnaire, and celebrating a range of cultural events with our employees and supporting inclusion in the workplace. Sustainability Pillar: People Useful Links • 2025 Management Information Circular • Appendix D: Social Data
2 2 | T M X G R O U P S U S TA I N A B I L I T Y R E P O R T 2 0 2 4 REPORT CONTENTS ABOUT THIS REPORT SUSTAINABILITY STRATEGY SUSTAINABILITY GOVERNANCE PROSPERITY PLANET PEOPLE APPENDICES Workforce Representation We derive strength from the diversity of thought represented by the variety of backgrounds, qualities, skills and experience of our workforce. We strive to reflect the demographic profile of our industry as a whole within our leadership team, and we seek to ensure that our workforce is representative of the communities in which we operate. Our new self-identification questionnaire, which is launching in 2025, will allow us to better understand our workforce and their work experience. Additional information about our workforce can be found under “2024 Workforce Demographics” in Appendix D. Gender Representation Our ED&I strategy continues to focus on progressing balanced gender representation in the overall workforce (defined as 40% - 60% women or men), taking into account that identification is not just binary. We achieved this goal in 2021 and have generally maintained overall workforce representation, with 39.5% of all positions held by women as at December 31, 2024. Further, we aim to have at least 40% women in executive positions (both senior executives and other executives) by the end of 2025. As at December 31, 2024, approximately 25.5% of all executive positions were held by women – a decline from 31% in the previous year, largely driven by a change in the composition of our executive base as a result of acquisition activity. For additional information regarding gender and our workforce in 2024, please see Appendix D. Positions Held by Women POSITION GOAL (EST. IN 2021) POSITIONS HELD BY Senior Executives 40% women by 2025 2 of 8 (25.0%) Executives 11 of 43 (25.6%) All other employees 40 to 60% women or men by 2025 807 of 2,026 (39.8%) Gender Pay Equity An annual equal pay analysis and a gender-neutral job evaluation tool and job grading structure serve as the foundation for our comprehensive compensation structure. Consistent with 2023, our average pay differential between women and men across graded roles remained at less than 2% in 202413. We will continue to actively monitor and review job grades and address any material differences that we observe by making adjustments as appropriate, while recognizing differences in experience and performance. In 2024, we achieved “Platinum” parity-certified status through Women in Governance, an increase from the “Gold” status achieved in 2023. The certification recognizes organizations that have achieved results by articulating a commitment to gender parity in the workplace, integrating it into the ecosystem of the organization and implementing mechanisms to achieve that commitment and sustain it over time. Strategic Partnerships In 2024, we continued to engage with and support a number of organizations and initiatives within our capital markets ecosystem which align with and support our values and principles regarding the advancement of women including: • Partnering with the London School of Economics on “The Inclusion Initiative”, a research study focused on gender equity for Women in Capital Markets in Canada. • Marking International Women’s Day with a Ring the Bell for Gender Equality market open. • Our Post-Trade Women’s Resource Group produced an event for employees called Shattering the Glass Ceiling: Advancing Women in the Workplace, featuring women leaders from TMX and allies and gender equity leaders in the sector. • Sponsoring, through TMX Trayport, Women of Silicon Roundabout and becoming a gold partner of Karren Brady’s Women in Business and Tech Expo. 13 Our average pay differential evaluation only includes roles which have assigned job grades and may exclude employees from acquisitions who have not yet been job graded.
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