Business Context and Reporting Period
Company: Canadian National Railway Company (CN) and Autoport Limited (collectively, the "CN Group").
Filing Type: Form 6-K (Report of Foreign Issuer).
Reporting Period: Financial year ended December 31, 2025.
Document Purpose: This filing announces the availability of the 2025 Annual Report under Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act. It details steps taken to prevent and reduce risks of forced or child labour in the CN Group's supply chains. The report is delivered via a "notice-and-access" mechanism.
Key Financial and Operational Metrics
Note: This filing is a compliance report regarding human rights and supply chain ethics. It does not contain a full set of audited financial statements. The following metrics are provided for context within the report.
- Total Revenues (2025): $17.3 billion.
- Freight Revenues (2025): $16.7 billion.
- Total Employees: 23,839 (18,078 unionized).
- Active Suppliers: Approximately 7,500.
- Network Size: 18,900 route miles.
- Cargo Volume: Over 300 million tons transported annually.
- Supplier Spend Geography: Approximately 99% of spending is with suppliers in Canada and the U.S.
Material Changes and Operational Highlights
The report outlines specific actions taken during the 2025 reporting period to address supply chain risks:
- Contractual Updates: Added wording to standard contracts requiring suppliers to comply with the Fighting Against Forced Labour and Child Labour in Supply Chains Act and applicable laws regarding slavery and human trafficking.
- Due Diligence Expansion: Engaged a third-party provider to assess forced labour risks for the top 135 tier 1 suppliers of CN and top 35 tier 1 suppliers of Autoport.
- Supplier Screening: Deployed an in-house questionnaire to suppliers identified as having moderate or high risk. Results indicated 100% of these suppliers have a framework to manage forced labour risks.
- Training: In 2024, approximately 4,400 management employees received enhanced training on human rights, forced labour, and child labour.
- Monitoring Coverage: Critical suppliers representing approximately 40% of CN's addressable spend are monitored via a third-party sustainability platform. In 2025, assessments covered 92% of CN's critical suppliers.
Outlook, Risks, and Management Commentary
Risk Assessment Results (2025):
- CN Tier 1 Suppliers (Top 135): 69% Low Risk, 27% Moderate Risk, 4% High Risk, 0% Elevated Risk.
- Autoport Tier 1 Suppliers (Top 35): 80% Low Risk, 20% Moderate Risk, 0% High Risk, 0% Elevated Risk.
Remediation: The CN Group states it has not identified any instances of suspected or actual forced labour or child labour in its business or supply chain. Consequently, no remediation measures were required during the reporting period.
Future Actions: The company plans to roll out refresher training in 2026 and intends to expand the use of its in-house supplier questionnaire across the entire CN Group, including Autoport, in the next reporting period.
Effectiveness Assessment: The filing explicitly states that while measures have been implemented, the CN Group has not yet assessed the overall effectiveness of these measures.
Key Facts for Investor Verification
- Verify the full 2025 Annual Financial Statements (Form 40-F) for detailed revenue, profit, and cash flow data, as this 6-K filing only provides high-level revenue context.
- Confirm the specific nature of the "High Risk" classification for the 4% of CN's top tier 1 suppliers (identified as providing fleet, rail cars, IT hardware, signals, and telecom products).
- Monitor the upcoming 2026 reporting period for the rollout of the in-house questionnaire to Autoport suppliers and the first formal assessment of the effectiveness of current mitigation measures.
- Review the separate report for TransX Ltd., a subsidiary excluded from this specific filing, which is due by May 31, 2026.