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2025 ESG Disclosure Study

Fasken
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Overview

Navigate the complexities of ESG with greater clarity. This study surveys 81 public companies on the Toronto Stock Exchange and Climate Engagement Canada Focus List and delivers practical insights to help corporate decision-makers manage environmental, social and governance risks and opportunities. 

 

Download the study to delve into key highlights such as:

  • Board oversight: Almost all large Canadian issuers surveyed have board or committee oversight of environmental and social considerations. Many rely on multifunctional committees for ESG matters, with over 85% of directors having expertise in these areas.
  • Executive and Employee Compensation: ESG remains relevant for short-term compensation decisions, with more companies using specific environmental and social metrics. A considerable number of companies report on their “wage gap” ratio, comparing pay for equity-seeking groups to the broader workforce.
  • Reporting Frameworks: Despite a few companies withdrawing ESG disclosures after Bill C-59, most continue to use reporting frameworks. The ISSB standards have not yet been widely adopted, with SASB, GRO, and TCFD continuing to be the most referenced frameworks.
  • Assurance: The growing demand for reliable ESG information is prompting companies to seek third-party assurance to boost credibility and mitigate legal risks. About 70% of TSX60 and CEC41 companies obtained external assurance for their ESG disclosures, mainly focusing on greenhouse gas emissions.
  • Forced and/or Child Labour: In the first year of mandatory reporting under the Fighting Against Forced Labour and Child Labour in Supply Chains Act, nearly all surveyed companies submitted reports.
  • Targets: The response to Bill C-59 negatively impacted the availability of greenhouse gas reduction disclosures. Among available reports, absolute emissions reduction targets and net-zero emissions targets remain the most commonly disclosed.
  • Shareholder Proposals: Certain stakeholders engage companies on ESG matters through shareholder proposals. The study found that about a quarter of surveyed companies received ESG-related proposals, with most proceeding to a vote. Topics included environmental issues such as greenhouse gas emissions, social issues such as racial equity, and governance issues such as in-person shareholder meetings. Anti-ESG proposals received minimal support.
  • Indigenous Engagement: Whole most companies mention Indigenous issues in their disclosures, only a few have specific plans or policies for Indigenous reconciliation, engagement, or economic development. Companies in natural resource sectors and Financial Services are most likely to disclose such policies or plans. 

The authors wish to acknowledge the tireless contribution of our Articling Students: Cara Arsenault, Spencer Atin, Peter Garrett, Amanda Samuels, and Nicky Young.  Additional contributors to this Study include Articling Students Tara Christensen, Chantelle deMontmorency, Natalia Bernal Garcia, Madeline Maclean, Tyler Murphy, and Jenaea Reimann.

For more information or to discuss specific matters, our dedicated team is ready to assist you.

Contact the Authors

Authors

  • Tracy L. Hooey, Partner | Mergers & Acquisitions, Toronto, ON, +1 416 868 3439, thooey@fasken.com
  • Kai Alderson, Partner | Co-Leader, ESG and Sustainability, Vancouver, BC, +1 604 631 4956, kalderson@fasken.com
  • Brian W. Burkett, Counsel | Labour, Employment & Human Rights, Toronto, ON, +1 416 865 4466, bburkett@fasken.com
  • Stephen Erlichman, Partner | Corporate Governance, Toronto, ON, +1 416 865 4552, serlichman@fasken.com
  • Antonio Di Domenico, Partner | Co-leader, Competition, Marketing & Foreign Investment, Toronto, ON, +1 416 868 3410, adidomenico@fasken.com
  • Jackie VanDerMeulen, Partner | Labour, Employment & Human Rights, Toronto, ON, +1 416 865 5402, jvandermeulen@fasken.com
  • Christopher Pigott, Partner | Labour, Employment & Human Rights, Toronto, ON, +1 416 865 5475, cpigott@fasken.com
  • Clifford Sosnow, Partner | Anti-Bribery and Corruption, Toronto, ON | Ottawa, ON, +1 613 696 6876, csosnow@fasken.com
  • Peter Villani, Partner | Mergers & Acquisitions, Montréal, QC, +1 514 397 4316, pvillani@fasken.com
  • Dana Gregoire, Associate | Corporate/Commercial, Toronto, ON, +1 416 868 3459, dgregoire@fasken.com
  • Taylor West, Associate | Corporate/Commercial, Toronto, ON, +1 416 865 5466, twest@fasken.com
  • Heather Sorenson, Associate | Indigenous Legal Matters, Vancouver, BC, +1 604 631 4879, hsorenson@fasken.com
  • Aniket Bhatt, Associate | Corporate/Commercial, Toronto, ON | Ottawa, ON, +1 416 868 7871, abhatt@fasken.com
  • Teresa Li, Associate | Mergers & Acquisitions, Toronto, ON, +1 416 868 7839, tli@fasken.com
  • Barbara Clark, Associate | Corporate/Commercial, Toronto, ON, +1 416 868 3412, bclark@fasken.com
  • Kathryn McCoy, Associate | Corporate/Commercial, Toronto, ON, +1 416 868 7808, kmccoy@fasken.com

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