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CSA Updates Requirements For Delivering Proxy-Related Materials During Canada Post Labour Dispute

The Canadian Securities Administrators (CSA) has updated requirements for delivering proxy-related materials for shareholder meetings, advising that the relief is no longer required under Coordinated Blanket Order 51-932 Temporary Exemption from requirements in National Instrument 51-102 Continuous Disclosure Obligations and National Instrument 54-101 Communication with Beneficial Owners of Securities of a Reporting Issuer to send certain proxy-related materials during a postal suspension (The Blanket Order).

This move comes as the Canadian Union of Postal Workers (CUPW) moves from a nationwide postal strike to a series of rotating strikes in their ongoing labour dispute with Canada Post, and the resumption of postal service. The CSA had originally issued The Blanket Order on October 9, 2025, providing temporary relief from requirements to deliver proxy-related materials for shareholder meetings to consider “annual matters” during a complete suspension of all postal service in Canada. It was a condition of the relief that commercial volumes were not accepted by Canada Post.

Since Canada Post has resumed mail deliveries and is now accepting commercial volumes, the regulator decided that relief in the Blanket Order is no longer available, and relief from delivery requirements in securities legislation in connection with the postal strike is no longer required. In the event of an escalation in labour action resulting in another complete suspension of postal service in Canada, the CSA will provide further information.

Coordinated Blanket Order 51-932 Temporary Exemption from requirements in National Instrument 51-102 Continuous Disclosure Obligations and National Instrument 54-101 is available for download from the websites of the Canadian Securities Administrators.

For more information, please call Barbara Hendrickson at BAX Securities Law (647) 403-4606.

This publication is not intended to constitute legal advice. No one should act on it or refrain from acting on it without consulting with a lawyer. BAX does not warrant or guarantee the accuracy or currency or completeness of the publication. No part of this publication may be reproduced without the prior written permission of BAX Securities Law.