Toronto-Dominion Bank/The

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Toronto-Dominion Bank (TD) has demonstrated a comprehensive level of transparency in disclosing its climate lobbying activities. The company has explicitly named specific climate policies and regulatory frameworks it has engaged with, such as the "Office of the Superintendent of Financial Institution (OSFI) - Discussion Paper on Navigating Uncertainty in Climate Change," the "IFRS Foundation Consultation Paper on Sustainability Reporting," and the "OSFI guideline B-15 Climate-Risk Management." TD also disclosed its participation in consultations with regulatory and standard-setting bodies, including the Alberta Securities Commission (ASC) and the Monetary Authority of Singapore (MAS), showcasing its engagement with identifiable climate-related policies and regulations. TD has provided detailed information about its lobbying mechanisms and targets. It mentions direct engagement with policymakers through consultations via industry groups like the Canadian Bankers Association (CBA) and the Bank Policy Institute (BPI). Additionally, TD outlines its participation in the Sustainable Finance Action Council (SFAC) and other collaborative frameworks, identifying specific policymaking targets such as Finance Canada, Environment and Climate Change Canada, the Bank of Canada, and the Office of the Superintendent of Financial Institutions. These disclosures reflect a high degree of transparency in both the mechanisms and targets of its lobbying efforts. Furthermore, TD has been transparent about the outcomes it seeks through its lobbying efforts. The company advocates for achieving near-complete coverage of the economy with climate-related disclosures aligned with international standards, improving climate data quality in sectors like Real Estate and Agriculture, and influencing government policy to facilitate greater investment in low-carbon solutions and technologies. TD also supports the development of a made-in-Canada green and transition finance taxonomy and aligns its lobbying activities with the goals of the Paris Agreement. These examples reflect clear policy goals and desired changes, demonstrating TD's commitment to advancing climate policy.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	TD Bank Group demonstrates strong governance in climate lobbying alignment, supported by robust oversight structures and monitoring mechanisms. The company integrates climate-related oversight across its organization, with the Board of Directors playing a significant role in overseeing the Bank's sustainability strategy and objectives, receiving regular updates on progress related to the Climate Action Plan and financed emissions targets. "The Board and its Committees receive progress updates on TD's Climate Action Plan," ensuring alignment with the Bank's sustainability goals. Management oversight is well-defined, with the CEO ultimately accountable for executing the Climate Action Plan, and the ESG SET Forum, consisting of senior executives, providing oversight of sustainability strategy development. "We also look to our Management Committees, Forums and Councils to provide oversight and to support management accountability for our Climate Action Plan." Additionally, TD has incorporated ESG metrics into executive compensation, extending this consideration to all Senior Vice Presidents and above in fiscal 2024. TD Bank has implemented processes to ensure alignment of climate lobbying activities, including the Sustainable Finance Executive Council (SFEC), which oversees the Bank's strategy and work on sustainable finance. "The Sustainable Finance Executive Council (SFEC), which consists of the senior executives from across TD, oversees the Bank's strategy and work on sustainable finance." Furthermore, the company actively engages with clients, governments, and regulators to address economic, technical, and policy barriers to achieving net zero. "We launched an ESG Advocacy Executive Forum, which brings together executives from across the Bank to align on advocacy activities and facilitate co-ordination of our engagement efforts." While TD Bank has not published a detailed lobbying audit, its governance processes, including defined roles and responsibilities, systematic monitoring, and active engagement with stakeholders, indicate strong governance in climate lobbying alignment.	3