Raising standards

Addenda submitted comments expressing support for the IASB’s effort to educate market participants through releasing illustrative examples to clarify how existing IFRS requirements apply to climate-related disclosures in financial statements. Continuing education on this topic will support informed investment decisions and effective capital allocation.

Addenda’s comments are publicly posted on the IASB website at this link.

Addenda’s comments to the CSSB encourage alignment with the global International Sustainability Standards Board in terms of timing and requirements, as much as possible, to ensure that Canadian companies maintain global competitiveness. Addenda responded to all three documents included in the consultation process. 

• CSSB Exposure Draft – Proposed Canadian Sustainability Disclosure Standard (CSDS 1), General Requirements for Disclosure of Sustainability-related Financial Information
• CSSB Exposure Draft – Proposed Canadian Sustainability Disclosure Standard (CSDS 2), Climate-related Disclosures
• CSSB Consultation Paper – Proposed Criteria for Modification Framework

The purpose of this ESG Disclosure Statement is to explain how environmental, social, and governance (ESG) issues are considered within an investment product’s objectives, investment process, and/or stewardship activities.

Addenda submitted comments in collaboration with nine other investors commending the government’s efforts to adopt cost-effective regulations to achieve at least a 75% reduction in oil and gas methane emissions by 2030 from a 2012 baseline, and encouraging the swift actions to adopt comprehensive final standards.

Addenda submitted comments to the CSA consultation on diversity supporting the proposed Form B proposal as an initial step in the evolution required to improve diversity disclosure as it would provide more consistent and comparable disclosures to investors.

At Addenda, people are central to our strategy, emphasizing diversity, equity, and inclusion (DEI) in our operations. Our commitment drives organizational transformation, fosters value-creating ideas, and ensures client needs are met. Discover our proactive DEI initiatives and join our journey towards inclusive excellence.

Addenda was the first global manager to adopt the CFA Institute's ESG Disclosure standards for an impact investment product with our Impact Fixed Income Strategy. This underscores our dedication to best practices in reporting and transparency.

Addenda submitted a comment letter to the SEC supporting their proposed new rules standardizing and enhancing disclosure of climate and carbon emissions data. More consistently reported climate and carbon emissions from companies we believe will provide investors more decision-useful and comparable data leading to a significant improvement from currently available disclosures.   

We became a signatory to the Net Zero Asset Managers Initiative, an international group of asset managers committed to net zero greenhouse gas emissions by 2050 or sooner, in line with limiting global warming to 1.5 degrees Celsius; and to working with clients to align investing with this goal.

We joined 35 institutional investors with $5.5 trillion in assets under management in signing the Canadian Investor Statement on Climate Change. We were also a contributor to drafting the statement. Through the statement, investor signatories commit to actions to support net zero emissions by 2050 and set out expectations for investee companies to address their own climate risks, opportunities and impacts.

We were a founding signatory to the Canadian Investor Statement on Diversity & Inclusion, which the Responsible Investment Association (RiA) prepared with the input of the Sustaining Members. The Statement is focused on the role we can play, as an institutional investor, in addressing the inequities and discrimination that exist in Canada by taking intentional steps to promote diversity and inclusion across our portfolios and within our organization.

We, along with institutional investor peers, wrote to the Ontario Capital Markets Modernization Taskforce to respond to their draft recommendations. In particular, we addressed:

• Board and executive diversity disclosure and target-setting for the inclusion of women, as well as Black, Indigenous  and People of Colour (BIPOC)
• Regulation of proxy advisory firms  
• Annual advisory vote on executive compensation  
• Shareholder proposal appeals process  
• ESG disclosure for listed companies

We wrote to the U.S. Department of Labor to provide comments on the proposed rule entitled “Financial Factors in Selecting Plan Investments”. We recommended that the Department refrain from introducing a new rule and urged it allow the existing guidance to remain in effect. The proposed rule mischaracterizes ESG integration and fails to distinguish between ESG integration and economically targeted investing and could lead to confusion for ERISA fiduciaries and costs for plan savers.

Together with NEI Investments, Addenda wrote and sent a letter to TMX Group encouraging it to move forward with a platform to facilitate ESG disclosure by issuers. The letter encourages TMX Group to use the Sustainability Accounting Standards Board (SASB) and Task Force on Climate-related Financial Disclosures (TCFD) frameworks as its basis for disclosure. 26 other major Canadian institutional investors also signed the letter. An encouraging response was received from TMX at the end of June.

We signed the Investor Statement on Coronavirus Response which acknowledges the challenges companies are experiencing and recommends a long-term focus in workforce and governance decisions to manage the crisis. The statement encourages companies to prioritize paid leave, health and safety measures, preservation of employment, supplier/customer relationships, and financial prudence in managing the crisis.

In January, we wrote to the U.S. Securities and Exchange Commission (SEC) regarding two proposed rules changes which would impact our firm and clients. Our submission identifies how the existing processes have strengthened capital markets and improved corporate practices on ESG matters. It also highlights how the proposed changes would negatively impact market participants, particularly shareholders.

In December we co-signed a letter to the Prime Minister and the Ministers of Finance, Environment & Climate Change, Natural Resources and Infrastructure & Communities to show support for the Expert Panel on Sustainable Finance’s recommendations. The Co-operators and Addenda Capital led the initiative among Canadian members of the United Nations Environment Programme Finance Initiative. The letter was signed by the CEOs of many large Canadian financial institutions.

We signed on to the Investor Statement to Support the United Nations Women's Empowerment Principles. The statement asks companies to strengthen commitments and take action towards gender equality.

We signed on to a letter coordinated by the US Sustainable Insurance Forum (SIF) intended for the U.S. Securities and Exchange Commission (SEC) regarding the current shareholder proposal process. The letter explains that the process has strengthened capital markets and improved corporate performance and does not need to be changed.

We were among the 200 institutional investors (representing a combined $6.5 trillion in assets-under-management) who announced that they are calling on 47 of the largest U.S. publicly traded corporations to align their climate lobbying with the goals of the Paris Agreement. The statement warns that lobbying activities that are inconsistent with meeting global climate goals can be an investment risk.

As part of a stakeholder consultation for the revision of the Equator Principles, we recommended that signatories align with the Paris Agreement and that they commit to disclosing according to the final recommendations of the Task Force on Climate-related Financil Disclosures (TCFD).

In response to an Ontario Securities Commission (OSC) request for comments, we highlighted the importance of investors’ duties and disclosures regarding environmental, social and governance risks and the need for greater issuer disclosure regarding cybersecurity governance and risk management. In addition, we support the OSC’s continued focus on monitoring progress on disclosure related to women on boards and in executive officer positions. Furthermore, we recommended the prioritization of new disclosure requirements for issuers regarding climate change.

On International Women’s Day, Addenda Capital and NEI Investments invited other investors to join them in committing to vote for gender diversity on Canadian boards. Drafted by the Engagement Workstream of the Toronto Responsible Investing Working Group in which we participate, the statement is a public signal to Canadian companies that investors are committed to encourage improved gender diversity on publicly listed corporate boards through proxy voting.

With the Co-operators, we submitted feedback to the Canadian Expert Panel on sustainable finance regarding the questions in the interim report of the Expert Panel.

We signed on to the Statement of Investor Commitment to Support a Just Transition on Climate Change, recognizing the social dimension of the transition to a low-carbon economy. A just transition is one in which social inclusion, including implications for workplaces and wider communities, are considered alongside climate action. The statement has been endorsed by 100 institutions representing US$5 trillion in assets under management. As part of this work, the final guide on Just Transition was launched in Poland during COP24.

In advance of the U.S. Securities and Exchange Commission (SEC) roundtable discussion on the Proxy Process, we co-signed a letter to the SEC on the matter. Drafted by the Ceres policy working group, the letter outlines arguments in support of SEC rule 14a-8 on shareholder resolutions. Signing on to the letter benefits our firm and our clients because it supports maintaining the ability of shareholders to file shareholder proposals, which can be an important tool for investors seeking to engage in meaningful dialogues with companies.

We became a signatory to the Global Investor Statement to Governments on Climate Change. The statement calls on governments around the world to achieve the Paris Agreement's goals, accelerate private sector investment into the low carbon transition and commit to improve climate-related financial reporting.

The Canadian Securities Administrators (CSA) requested comments regarding soliciting dealer arrangements, which are when companies pay fees to investment dealers to get help soliciting votes or encouraging investors to tender securities. We responded that it supports these arrangements when they are in the public interest but not when they give rise to conflicts of interest.

We submitted a response to an Ontario Securities Commission request for comments on their Statement of Priorities. Our comments addressed the consideration of ESG risks and opportunities in institutional investors’ duty to act in the best interest of their clients, women on boards and in executive officer positions and mandatory climate change disclosure by companies.

We submitted a response to the Canadian Securities Administrators’ (CSA) Consultation Paper 52-404 Approach to Director and Audit Committee Member Independence, indicating that the current approach has a good balance of allowing boards to exercise judgement while still specifying some relationships that would make independence an unreasonable expectation. We also suggested two improvements: address the impact director tenure might have on independent judgement; and, require all director nominees to disclose circumstances and relationships that could reasonably be perceived as material.

We wrote to the Government of Alberta requesting that the threshold for filing shareholder proposals be lowered to the one used elsewhere in North America. We joined a growing chorus of investors that have been working with the responsible Ministers and their staff for some time to advance the proposal. In February 2018, we received a response from the Minister of Service Alberta and Status of Women, Stephanie McLean, indicating that our suggestion will be brought forward the next time the legislation is reviewed.

Institutional Shareholder Services (ISS) held a consultation on two draft policies for TSX-listed issuers. The first draft policy was about director elections, specifically regarding overboarded directors. The second draft policy was regarding director elections, specifically board gender diversity. We submitted comments to ISS on these draft policies. 

We were one of thirty Canadian and international financial institutions that issued a collaborative Declaration of Institutional Investors on Climate-Related Financial Risks. The declaration encourages Canadian public companies to make a commitment to improve disclosure regarding exposure to climate change risks and actions to manage these risks. The signatories also commit to: 
• Encourage Canadian public companies to improve disclosure on the risks of climate change 
• Improve ability to measure climate change risks and opportunities and use this in decision-making processes
• Identify and assess low-carbon investment opportunities which contribute to the energy transition
• Work with investee companies and support them in managing their climate risks 

In August 2017, the Department of Finance launched the second stage of consultations on the renewal of the federal financial sector legislative and regulatory framework, to gather views on potential policy measures to support a competitive and innovative sector, modernize legislative framework, and safeguard a stable and resilient financial sector. In September, The Co-operators, with our input, submitted a formal response to the consultation paper. The Department of Finance may share these submissions with federal financial sector regulatory agencies to facilitate their review. The main points of the letter include:
• The financial sector needs to be harnessed to achieve a transition to a sustainable, low-carbon, climate-resilient society.
• Innovation is a key element of a healthy, sustainable economy.
• The Co-operators believes that it is possible to balance economic, environmental, and social priorities as a responsible corporate citizen.
• The Co-operators is pleased to see an emphasis on corporate governance highlighted as a central tenant of public confidence in the financial sector.

In March 2017, the Canadian Securities Administrators (CSA) launched a consultation with investors and reporting issuers on climate change disclosures. Along with the Shareholder Association for Research & Education (SHARE), we brought together a group of large Canadian institutional stakeholders to meet with the Ontario Securities Commission and the Alberta Securities Commission. After an honest discussion, we co-authored a letter with SHARE to provide input into the CSA’s consultation, including the following points:
• Climate-related information is material for reasonable investors
• Current reporting regulations are not sufficient to address the specific question of climate-change-related risks and opportunities
• Specific climate-related disclosure requirements in regulatory filings are necessary and warranted
• The Task Force on Climate-related Financial Disclosures recommendations are the best starting point for disclosure obligations

We co-signed a letter hand delivered to all members of the U.S. House of Representatives opposing certain provisions of the Financial CHOICE Act that would likely be deterimental to investors. The letter was coordinated by the Council of Institutional Investors in the United States.

We co-siged a letter to G7 and G20 governments urging them to continue to support and implement the Paris Agreement, drive invesments into the low carbno transition and implement climate-related financial reporting frameworks. The letter was coorindated by several initatives Addenda is involved in including the Principles for Responsible Investment, the Investor Network on Climate Risk and CDP.

We co-signed a letter to Ontario's Ministry of Finance with some recommendations to facilitate greater representation of women on boards. This letter followed a meeting held in 2016. The letter was coordinated by the Responsible Investment Associate, of which Addenda is a Sustaining Member.

We wrote to Ontario's Minister of Finance during 2017 Pre-Budget consultations to 1) encourage the government to review the Task Force on Climate-related Financial Disclousures (TCFD) final report in 2017 and consider using regulatory means to require disclosure; and 2) explore enforceable means to increase the representation of women on corporate boards to at least the largest of 3 board positions or 30% by the end of 2022.

Along with The Co-operators, we wrote to Ontario's Ministry of the Environment and Climate Change regarding the creation of the Ontario Climate Change Solutions Deployment Corporation (green bank) and made some recommendations to increase the supply of capital and promote the creation of impact investing intermediaries.

We co-signed a letter to President-elect Trump, President Obama, Members of the US Congress and global leaders urging implementation of the Paris Agreement.

We wrote to the Alberta Securities Commission to provide supportive comments regarding increasing gender diversity on boards and in management roles as addressed in the proposed amendments to National Instrument 58-101 Disclosure of Corporate Governance Practices (NI 58-101) and Form 58-101F1 Corporate Governance Disclosure (Form 58-101F1).

We wrote to the U.S. Securities and Exchange Commission (SEC) to reiterate our view that we believe it is critical for the Commission to improve reporting of material sustainability information both because such disclosure is mandated by current law and because we need it to make informed investment and voting decisions.

We co-signed a letter to the CFA Society Toronto encouraging the increasing effort to include ESG-related content in the Society's programing. This letter followed a meeting held in 2016. The letter was coordinated by the Responsible Investment Association, of which Addenda Capital is a Sustaining Member.

We wrote to the Ontario Securities Commission regarding their Statement of Priorities for 2016-2017 to raise the following issues that were not included: shareholder democracy, diversity, and environmental reporting requirements.

We provided feedback to Moody's Investor Service regarding their proposed Green Bond Assessment methodology. We were pleased to see Moody's taking a serious look at green bonds and provided feedback on their approach to evaluating the use of proceeds and their use of pre-issuance and post-issuance assessment criteria.

We co-signed an investor statement that calls for improvements in practice and transparency from investee companies on aspects such as their governance processes for climate policy engagement and their membership of or support for all third-party organisations that lobby on climate change. The development of this statement was facilitated by the Principles for Responsible Investment, of which Addenda Capital is a signatory.

We co-signed the Statement of Investor Expectations for the Green Bond Market to encourage better eligibility criteria, disclosure, reporting and independent assurance in the green bond market. The statement was coordinated by the Investor Network on Climate Risk, of which Addenda Capital is a member.

We co-signed the Investor Statement re: Green Bonds & Climate Bonds to encourage the responsible growth of the green bond market. The statement was coordinated by the Climate Bonds Initiative.

We co-signed a letter to the International Organization of Securities Commissions (IOSCO). The letter highlights investors’ need for consistent and material disclosure of corporate sustainability information to inform their investment decisions.

We co-signed the Investor Statement on Climate Change that was released at the United Nations Secretary-General's Climate Summit on September 23, 2014. The purpose of the statement was to urge stronger national and international policy action on climate change and clean energy, and it outlined steps investors are taking and intend to take to scale up low-carbon investment, given the right policy signals. The statement was coordinated by several initiatives we are involved in including the Principles for Responsible Investment and the Investor Network on Climate Risk.

We wrote to the Ontario Securities Commission to provide comments regarding gender diversity on boards and in management roles as addressed in the proposed amendments to National Instrument 58-101 Disclosure of Corporate Governance Practices (NI 58-101) and Form 58-101F1 Corporate Governance Disclosure (Form 58-101F1).

We wrote to the Canadian Securities Administrators regarding proposed amendments and changes to the early warning reporting regime in Canada. We were supportive of the CSA’s efforts to provide greater market transparency and increase investor confidence.

We wrote to the Toronto Stock Exchange to express our support for mandatory majority voting for TSX listed issuers.