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TD Bank's Racial Equity Audit: Commendable Yet Incomplete Asserts Labour Union Investor - BC General Employees' Union (BCGEU)


Burnaby, BC, December 19, 2023 - In a landmark move, The Toronto-Dominion Bank (TSX: TD) unveiled the findings of its much-anticipated racial equity audit report which examines the bank's employment practices across its US and Canadian operations. A response to a shareholder proposal by the BC General Employees' Union (BCGEU), this audit is a significant step for North America's 6th largest bank and is the first audit of its kind in Canada.

"We commend TD for being the first bank in Canada to commit to and complete a racial equity audit," stated Emma Pullman, BCGEU's head of shareholder engagement. "However, to truly bolster investor confidence, TD must address the audit's significant limitations."

A racial equity audit critically analyzes a company's practices to identify and rectify disparities affecting Indigenous communities and people of colour. TD engaged Covington LLP and WeirFoulds LLP for this purpose, scrutinizing workplace policies, hiring, and retention. 

BCGEU has identified the following concerns with the audit that it believes could be addressed through enhanced disclosure, and in future audits: 

  • Methodological Flaws: The audit's questions have limitations. Rather than asking about the effectiveness of TD's diversity policies and practices, the audit asks what mechanisms are in place to assess the effectiveness of TD's policies and practices.
  • Insufficient Data: TD's audit fails to disclose disaggregated data, which could provide critical insights into how different racial and ethnic groups are specifically affected by TD's policies and practices. Disclosing this data may help TD develop more targeted and effective strategies to address systemic inequalities and ensure that initiatives truly benefit all employees and stakeholders in a meaningful way.
  • Narrow Scope: The audit's focus on employment practices omits key areas like products, services, and lending practices. TD has indicated that it intends to apply learnings from its employment audit to customer experience. Without conducting an audit that covers business practices, TD may overlook systemic issues, and may miss key insights and opportunities.

"We understand that racial equity audits are intensive. As a long-term TD investor, our priority is to ensure this audit is instructive and isn't mere window dressing. We believe TD is in a position right now to make straightforward and meaningful additional disclosures that will provide investors with confidence in the audit. Furthermore, we believe TD should commit to a timeline for an audit of its business practices," Pullman asserted.

During TD's proposed merger with First Horizon Bank, criticisms emerged regarding its racial lending record. TD's audit into its employment practices would not be able to provide insights into the effectiveness of new policies and programs announced by the company, including changes to overdraft policies and new programs to increase home ownership among communities of colour. This underscores the need for an inclusive audit that covers business and lending practices.

Since TD made its commitment to conduct a racial equity audit in 2022, nearly all its competitors and peers have committed to comprehensive racial equity audits that include both employment and business practices. This includes National Bank of Canada, CIBC, Bank of Montreal, and Royal Bank of Canada. Both RBC and BMO made commitments in November of 2023 in response to investor engagement led by BCGEU and other investors. 

"TD Bank has paved the way with its racial equity audit. But, without a commitment to comprehensively audit its entire business, it risks falling to the back of the pack. We hope to see TD champion change and embrace a more thorough and transparent approach," concluded Pullman.

The B.C. General Employees' Union represents over 85,000 workers in virtually every community and economic sector in the province. BCGEU's capital stewardship program leverages its power as a long-term shareholder to advance human rights, Indigenous rights, sustainability, and responsible governance at Canada's largest companies. Learn more about the union's work at

Read TD's employment equity audit

Read BCGEU's 2022 shareholder proposal at TD Bank

For media inquiries, please contact:

Emma Pullman
Head of Capital Stewardship and ESG
BC General Employees' Union (BCGEU)
[email protected]