2023 Report assessment focused on our direct suppliers of goods. Factors considered in the risk assessment 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 resources published by organizations such as the Walk Free Foundation Global Slavery Index 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. Consequently, a subset of key goods suppliers, including resellers and suppliers outside Canada, received a communication from TMX Group to provide them with information about the Act, complete with a request to supply information as part of a due diligence process, for the purpose of further refining our risk assessment. 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. THIRD PARTY RISK MANAGEMENT POLICY UPDATES In addition to reviewing our supply chain and conducting an internal risk assessment of forced labour and/or child labour as described in the previous section, we have updated our Third Party Risk and Outsourcing Management (TPROM) Policy, which is applicable to all TMX Group employees and is the overarching policy addressing how we manage risks when entering into any business relationships for the provision of products and services. The TPROM Policy 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 Based on a reviewof industry best practices, enhancements to our supplier due diligence processes were developed to enable the identification of potential risks or occurrences of forced and/or child labour in our operations and supply chains. This process includes the following components: • Using a third party to identify sanctions and adverse media coverage which encompasses modern slavery, human trafficking and migrant smuggling. 5
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