Submissions and Statements History

2020

DateDetails
January 30, 2020 Letter to U.S. Securities and Exchange Commission

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.

2019

DateDetails
December 3, 2019 UNEP FI Members Support Letter Canada EP

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.

October 8, 2019 Investor Statement to Support Gender Equality in the Workplace

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.

September 18, 2019 US SIF Letter to the SEC Regarding the Shareholder Proposal Process

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.

September 11, 2019 Investor Expectations on Climate Lobbying

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.

August 21, 2019 The Equator Principles Draft for Consultation

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).

May 27, 2019 OSC Statement of Priorities Comments

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.

March 8, 2019 Voting for Board Gender Diversity Canadian Investor Statement

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.

January 31, 2019 Response to EP Interim Report with The Co-operators

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.

2018

DateDetails
November 30, 2018 Statement of Investor Commitment to Support a Just Transition on Climate Change

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.

November 13, 2018 Rule 14a-8 and Proxy Process Reform

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.

September 12, 2018 Global Investor Statement to Governments on Climate Change

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.

June 29, 2018 CSA Staff Notice 61-303 and Request for Comment Soliciting Dealer Arrangements Comments

The Canadian Securities Administrators (CSA) requested comments regarding soliciting deader 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.

May 28, 2018 OSC Statement of Priorities Comments

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.

January 23, 2018 CSA Consultation 52-404

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.

January 11, 2018 Letter on Threshold for Filing Shareholder Proposals

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.

2017

DateDetails
November 9, 2017 ISS Held Consultation on Two Draft Policies for TSX-listed Issuers

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. 

October 26, 2017 Declaration of Institutional Investors on Climate-related Financial Risks

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 

September 29, 2017 Federal Financial Sector Review

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.

July 18, 2017 Letter to CSA with SHARE

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

May 17, 2017 Financial CHOICE Act Letter

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.

May 8, 2017 Letter from Global Investors to Governments of the G7 and G20 Nations

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.

March 16, 2017 Investor Recommendations for Improving Gender Diversity on Boards

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.

January 31, 2017 2017 Pre-Budget Consultations

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.

January 30, 2017 Comments on the Proposed Ontario Change Solutions Deployment Corporation EBR Number 012-9270

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.

2016

DateDetails
November 17, 2016 Business Backs Low-carbon USA

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.

October 11, 2016 Proposed Amendments to National Instrument 58-101 Disclosure of Corporate Governance Practices and Form 58-101F1 Corporate Governance Disclosure

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).

July 21, 2016 File Number S7-06-16 Comment on Modernizing Certain Business and Financial Disclosure Requirements in Regulation S-K

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.

May 25, 2016 ESG Content in the CFA Program and Continuous Education Program

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.

May 9, 2016 OSC Notice 11-774 Statement of Priorities for 2016-2017

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.

February 9, 2016 Green Bond Assessment Methodology

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.

2015

DateDetails
September 3, 2015 Investor Expectations on Corporate Climate Lobbying

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.

February 10, 2015 A Statement of Investor Expectations for the Green Bond Market

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.

2014

DateDetails
December 15, 2014 Investor Statement re: Green Bonds & Climate Bonds

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.

October 10, 2014 Investor Statement to IOSCO

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.

September 23, 2014 Global Investor Statement on Climate Change

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.

April 16, 2014 Proposed Amendments to Form 58-101F1 Corporate Governance Disclosure of National Instrument 58-101 Disclosure of Corporate Governance Practices

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).

2013

DateDetails
July 12, 2013 Letter to CSA on Early Warning Reporting Regime

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.

2012

DateDetails
November 2, 2012 Proposed amendments to the TSX Company Manual issued October 4, 2012

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