Toronto-Dominion Bank/The

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Toronto-Dominion Bank offers a comprehensive account of its climate-policy advocacy. It names multiple identifiable measures it has worked on, including the Office of the Superintendent of Financial Institutions’ Guideline B-15 Climate-Risk Management, OSFI’s “Discussion Paper on Navigating Uncertainty in Climate Change,” consultations on the IFRS Foundation’s sustainability disclosure standards (IFRS S1 and S2), and participation in the Government of Canada’s Sustainable Finance Action Council and its Disclosure Technical Expert Group. The bank also explains how it engages: it “dialogue[s] with elected officials, public servants, regulators and advocacy organizations,” submits feedback “through industry group CBA – Canadian Bankers Association,” provides data directly to the Bank of Canada and OSFI for a national flood systemic risk assessment, and coordinates activity via an internal ESG Advocacy Executive Forum and inventory. Targets are explicitly identified, including Finance Canada, Environment and Climate Change Canada, the Bank of Canada, the IFRS Foundation, provincial securities commissions and prudential supervisors, and U.S. and Canadian federal officials. TD is equally explicit about what it wants these engagements to achieve—advocating for “near-complete coverage of the economy with climate-related disclosures aligned with international standards,” supporting a “made-in-Canada green and transition finance taxonomy,” improving climate data quality in sectors such as Real Estate and Agriculture, and developing affordable national flood-insurance solutions. TDAM’s parallel efforts press companies and regulators for “science-based, time-bound greenhouse-gas reduction targets” and standardized ESG disclosure, while TD Insurance seeks better climate-risk management rules through OSFI guideline B-15. Collectively, the disclosures provide clear visibility into the specific policies addressed, the mechanisms and public bodies engaged, and the concrete outcomes the group is pursuing, demonstrating a high level of transparency in its climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Toronto-Dominion Bank discloses several mechanisms that indicate a structured, but still developing, approach to governing its climate-related lobbying. The Boards Corporate Governance Committee "oversees the Banks corporate responsibility strategyand receives regular reports that include significant developments arising out of TDs public policy interactions," demonstrating top-level oversight of lobbying activity. At the executive level, the Bank states it has "launched a new advocacy framework that coordinates climate-related advocacy across the Bank and articulates key focus areas for engaging with governments and regulators" and has created 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." TD describes concrete monitoring tools, noting it has "developed an internal inventory to track our various advocacy efforts and inform our approach and priority areas for engagement" and that "lobbying is tracked and measured by the Environment, Government & Industry Relations team and reviewed with the support of our legal team." The company also refers to processes intended to keep indirect lobbying consistent with its climate strategy: "Stakeholders from relevant areas of the bank are engagedto ensure alignment with our climate strategy and milestones in our Climate Target Operating Model (TOM)" when it participates in consultations "primarily through industry associations." However, the disclosures do not provide evidence of a formal, publicly available review of trade-association positions, nor do they describe actions taken to correct or exit misaligned associations, and no dedicated climate-lobbying alignment report or third-party audit is referenced. Overall, the published information shows named oversight bodies and some internal procedures for tracking and aligning both direct and association-based advocacy, but the depth of monitoring and the transparency of outcomes remain limited.	2