Toronto-Dominion Bank | Interfaith Center on Corporate Responsibility

<div class=”col-lg-9 content-page left-side”>
<section class=”section-a-single-resolutions resolutions-info top-content”>
<div class=”resolutions-contain”>
<div class=”top-content”>
<h4>Resolution Details</h4>
</div>
<div class=”bottom-content”>
<div class=”row-info”>
<strong>Company:</strong>
<p>Toronto-Dominion Bank</p>
</div>
<div class=”row-info”>
<strong>Year:</strong>
<p>2025 </p>
</div>
<div class=”row-info”>
<strong>Issue Area:</strong>
<p>Corporate Governance </p>
</div>

<div class=”row-info”>
<strong>Focus Area:</strong>
<p>Board Competency and Risk Oversight </p>
</div>
<div class=”row-info”>
<strong>Status:</strong>
<p>Filed</p>
</div>

</a>
</div>
</div>
</div>
</section>

<section class=”section-b-single-resolutions content-blocks”>
<div class=”top-content editor-block”>
<div class=”content-block”>
<div class=”main-content”>
<h2>Resolution Text</h2>
<p><strong>Resolved:</strong> Shareholders request an independent review of TD’s board governance policies and director selection criteria with a view to improving accountability and competency regarding key risks and emerging priorities.</p>
<p dir=”ltr”><strong>Supporting Statement:</strong></p>
<p dir=”ltr”>In October, 2024, TD Bank NA pled guilty to money laundering charges and agreed to pay U.S. authorities more than US$3 billion in fines. The ongoing scandal derailed TD’s 2023 attempted purchase of First Horizon, and as part of the settlement, TD’s U.S. subsidiaries will have their growth capped.</p>
<p dir=”ltr”>This is a governance failure which shareholders are concerned may be systemic in nature. A column in Canada’s national newspaper concluded that TD board members earned a “black mark” and questioned their ongoing tenure. Canada’s bank supervisor Peter Routledge specifically referred viewers to this piece on a television appearance.</p>
<p dir=”ltr”>TD’s governance failure may extend beyond money laundering. Several independent assessments show the bank well off track to meet its net zero commitment, and directors have been unresponsive to significant shareholder votes asking for clarity on how the bank will address these concerns. </p>
<p dir=”ltr”>TD’s Corporate Governance Guideline outlines how the board operates. Under “board feedback process,” the Guideline is unclear on the issue of committee accountability, and silent regarding consequences for lapses or underperformance.</p>
<p dir=”ltr”>The Guideline indicates that board members should have a broad spectrum of competencies that reflect the nature and scope of the bank’s business and refers to the Key Areas of Expertise / Experience matrix disclosed in TD’s annual proxy circular.</p>
<p dir=”ltr”>Yet this matrix uses broad categories that leave shareholders guessing about specific competencies. For example, “Audit/Accounting” does not necessarily include skills related to money laundering. Or, “Environmental, Social, and Governance” does not necessarily include experience related to net zero.</p>
<p dir=”ltr”>The Guideline considers the challenge of “Other Directorships and Board Interlocks Policy” as a matter of time management of directors and not also as a potential systemic conflict of interest if directors must discharge their fiduciary duty at seemingly incompatible businesses. TD has more cross-posting of directors at fossil fuel companies than any other Canadian bank despite its net zero commitment. It considers two of these directors as satisfying its ESG category in its director expertise/experience matrix.</p>
<p dir=”ltr”>Because it is difficult for a board to assess itself, shareholders request an external review of TD’s board governance policies and director selection criteria with a view to improving director accountability and competency for existing risks and emerging priorities like net zero, the results of which are presented in the bank’s 2025 proxy circular, together with the bank’s response.</p>
<p dir=”ltr”> 1 David Milstead, “Opinion: TD’s expensive board failed to fix years of…”, Globe and Mail (Oct. 15, 2024).</p>
<p dir=”ltr”>2 See the 11:00 minute mark at: www.bnnbloomberg.ca/video/shows/trading-day/2024/10/16/osfi-expresses-concern-over-td-banks-guilty-plea/.</p>
<p dir=”ltr”>3 See for example: TPI: www.transitionpathwayinitiative.org/banks; BloombergNEF, Financing the Transition (2023); WRI: www.wri.org/financial-institutions-net-zero-tracker.</p>
<p dir=”ltr”>4 In 2024, the net zero transition activity disclosure proposal received 28.6% for, 0.7% abstain, and in 2023 it received 23.5% for, 4.5% abstain.</p>
<p dir=”ltr”>5 TD Bank, Corporate Governance Guideline (2023) online: www.td.com/content/dam/tdcom/canada/about-td/pdf/2023-corporate-governance-guideline-en.pdf.</p>
<p dir=”ltr”>6 TD Bank, 2024 Proxy, at 23.</p>
<p dir=”ltr”> </p>

</div>
</div>
</div>
<div class=”middle-content editor-block”>
<div class=”content-block”>
<div class=”main-content”>

</div>
</div>
</div>

</section>
</div>
<aside class=”col-xl-3 right-side”>
<div class=”column-contain”>

<h3>Lead Filer</h3>
<div class=”views-row”>
<div class=”views-field views-field-nothing”><span class=”field-content”> Matt Price</span></div><div class=”views-field views-field-title views-field-field-shareholder”><span class=”field-content”>Investors for Paris Compliance</span></div>
</div>

</div>

</div>
</div>

</div>
</div>
</aside&gt

Resolution Details

Company:

Toronto-Dominion Bank

Year:

2024

Issue Area:

Corporate Governance

Focus Area:

Executive Compensation

Status:

Filed

Resolution Text

BE IT RESOLVED

The Board of Directors undertake a review of executive compensation levels in relation to the entire workforce and, at reasonable cost and omitting proprietary information, publicly disclose the CEO- compensation-to-median-employee-pay-ratio on an annual basis.

SUPPORTING STATEMENT

Job action by United Auto Workers and Hollywood talent illustrates the employee unrest impacting many industries and underscores the discrepancy between corporate profits and increased executive pay compared to workers’ trailing wages. Exacerbating this unrest is stagnant wage growth combined with rising inflation, particularly impacting necessities like housing, energy, and food1.

Sluggish wage growth trailing inflation for average employees is in stark contrast to executive compensation, where realized wages have continued to exceed inflation and diverge from the rest of the workforce. This data is widely available, and this growing gap is undisputed.

While companies with lower levels of unionization are less exposed to direct labour action, they are still exposed to similar financial impacts. This is often felt through increased employee turnover, absenteeism, and lowered employee morale. For instance, research has shown that a burnt-out employee can incur a cost equivalent to over 30% of their salary and that replacing an existing employee can cost up to 400% of their annual salary2.

To effectively implement strategies that increase company value, senior executives need engaged employees to execute their vision. Many studies show that social comparison is a powerful factor in human interaction and employee satisfaction is heavily dependent on perceived fairness in compensation3.

The perception that only executives benefit from company growth and that the average worker is not fairly compensated for their individual contribution is demotivating for employees. The CEO- compensation-to-median-employee-pay-ratio is a useful mechanism to evaluate and assess wage distributions within a company. When pay differentials are closely monitored and managed, employees are more likely to be highly engaged and productive.

Say-on-pay vote results have very little to do with a company’s management of pay differentials. Shareholders are lacking information on how exposed TD Bank is to human capital risks associated with skewed compensation distributions. Vancity filed this proposal last year and received 12.9% support.

MEDAC previously filed a similar proposal with TD Bank, indicating there is demand for this information.

As a financial institution, TD Bank is heavily dependent on human capital to drive growth and in turn, shareholder value. The CEO-compensation-to-median-employee-pay-ratio provides a simple cost- effective way for TD Bank to communicate how the company manages pay differentials. Scotiabank provides this ratio and the Global Reporting Initiative, which TD Bank already utilizes, offers a well- recognized method to calculate this through indicator 2-21.

The aim of this disclosure is not to limit executive compensation but to ensure that shareholders have the appropriate information to evaluate TD Bank’s management of human capital risks. Disclosing and tracking the ratio will allow TD Bank to better manage employee engagement and morale, talent recruitment and retention and mitigate the increasing financial and reputational risk associated with growing pay differentials.

1 https://www.forbes.com/sites/annefield/2022/05/23/ceo-worker-pay-gap-widens-and-employees-arent-happy- about-it/?sh=3ac80050142c

2 https://www.joinpavilion.com/blog/the-real-cost-of-burnout; https://www.simplybenefits.ca/blog/employee- retention-what-is-the-true-cost-of-losing-an-employee

3 https://www.psychologytoday.com/ca/blog/work-smarter-not-harder/202303/the-executive-worker-pay-gap- isnt-without-consequences

Resolution Details

Company:

Toronto-Dominion Bank

Year:

2024

Issue Area:

Climate Change

Focus Area:

Climate Financing

Status:

Filed

Resolution Text

RESOLVED: Shareholders request that TD disclose transition activities that describe how it will align its financing with its 2030 sectoral emissions reduction targets, including specific measures and policies to be implemented, reductions to be achieved by such planned measures and policies, and timelines for implementation and associated emission reductions.

SUPPORTING STATEMENT

This is the second year filing this proposal. Last year, 28.9% of shareholders broke with management – 23.5% voting for and 5.4% abstaining.

The core of the proposal is that TD continues to be vague regarding what actions it intends to take, or how its day-to-day business practices will change to meet its 2030 emissions reduction targets. Clearly articulated transition activities are increasingly urgent in light of the fact that TD had the largest jump of any global bank in its fossil fuel financing between 2021 and 2022, adding US$7.3 billion (34%) for a total of US$29 billion.1

Since last filing, the bank continues to do a fair job of measuring its financed emissions and describing its climate governance processes. It has also set interim emissions reduction targets for its most carbon-intensive portfolios. But, we are yet to hear what it will actually do differently at the deal level and in client engagement to drive down its climate transition risk and increase exposure to climate opportunities.

Indeed, the September 2023 investor-led Transition Pathway Initiative’s global bank assessments found TD’s transition activities to be lacking, scoring TD at just 4% for its Decarbonization Strategy and 33% for the Climate Solutions category.2 I4PC’s 2023 Canadian Net Zero Report Card also highlights TD’s ongoing transition plan gaps.3

Meanwhile, net-zero transition guidance continues to grow. Guidance was published by the IIGCC (June 2023)4 and UK Transition Taskforce (Nov. 2023).5 Both build on GFANZ guidance.6 Each outlines the need for banks to establish lending criteria that align with a 1.5 degree scenario and clearly defined climate solutions financing policies, among other things.

This past year we have seen other Canadian banks announce some specific transition activities. National Bank set a target to increase its renewable energy lending faster than its fossil fuel lending; CIBC began quantitatively reporting on its assessment of client transition plans; BMO established a $350 million sustainability solutions fund (vs. vague “sustainable finance” targets like TD’s Sustainable and Decarbonization Financing) and aligned its lobby policy with the Paris Agreement.

Globally, G-SIB peer banks are progressing faster. For example, HSBC committed not to finance new oil and gas fields (Dec. 2022). BNP Paribas will no longer arrange bond deals for issuers intending to use proceeds to finance new fossil-fuel exploration and production (June 2023).

By the time of TD’s 2024 AGM it will have been 3.5 years since TD made its net zero commitment, with less than 6 years remaining to hit its 2030 targets. Without greater clarity regarding what actions TD will implement, investors are concerned that TD’s transition risk continues to grow.

1 www.bankingonclimatechaos.org/wp-content/uploads/2023/08/BOCC_2023_vF.pdf

2 www.transitionpathwayinitiative.org/banks/toronto-dominion-td

3 https://www.investorsforparis.com/wp-content/uploads/2023/07/I4PC_Banks-report-card-2023.pdf (at 13)

4 https://139838633.fs1.hubspotusercontent-eu1.net/hubfs/139838633/Past%20resource%20uploads/IIGCC-Net-Zero-Standard-for-Banks-June-2023.pdf

5 https://transitiontaskforce.net/disclosure-framework/

6 www.td.com/content/dam/tdcom/canada/about-td/pdf/td-investor-2023-proxy-en.pdf (at 90)

Resolution Details

Company:

Toronto-Dominion Bank

Year:

2023

Issue Area:

Climate Change

Focus Area:

Climate Financing

Status:

Vote

Vote Percentage:

24.80%

Resolution Text

RESOLVED: Shareholders request that TD disclose a transition plan that describes how it intends to align its financing activities with its 2030 sectoral emissions reduction targets, including the specific measures and policies to be implemented, reductions to be achieved by such planned measures and policies, and timelines for implementation and associated emission reductions.

SUPPORTING STATEMENT:

In 2022 TD released an updated Climate Action Plan in response to its commitment to achieve net zero financed emissions by 2050.

While TD’s updated Plan provides more clarity on the measurement of financed emissions, its intensity-based 2030 targets don’t align with the absolute 2050 target TD has committed to and the Plan lacks clarity as to the specific measures and policies that TD will implement to achieve progress.

For example, TD discusses the existence of its “Climate Target Operating Model” with “sequences and actions,” but does not disclose what those are. Similarly, TD says that it continues to embed climate risk into its enterprise risk framework, but does not disclose whether and how this is related to meeting its targets.

TD says that it is making good progress towards its $100 billion “low carbon” lending, financing, and asset management target, but it‘s unclear whether and how this relates to its emission reduction targets as TD does not systematically quantify and disclose the impact of this activity on emissions.

TD’s need for a credible transition plan is acute considering the bank is particularly exposed to transition risk. A recent study concluded that TD has the highest financed emissions – at 447 million tonnes CO2 equivalent – of any Canadian bank.[1]

TD is yet to adopt any policy to phase down its exposure to fossil fuels, including in its updated 2022 coal policy. On the contrary, it is still involved with financing fossil fuel expansion projects such as the Trans Mountain pipeline and Coastal GasLink project.

This uncertainty about whether and how TD will meet its climate targets represents a material business risk given the shifting regulatory environment. The Office of the Superintendent of Financial Institutions is developing climate risk management guidance that will require TD to have a Climate Transition Plan to manage “increasing physical risks from climate change, and the transition towards a low-GHG economy.”[2]

Similarly, the Glasgow Financial Alliance for Net Zero, of which TD is a member, recommends that financial institutions have a transition plan that contains “a set of goals, actions, and accountability mechanisms to align an organization’s business activities with a pathway to net-zero.”[3] TD is yet to meet this bar.

TD’s peers disclose greater specificity regarding how they will reach net zero, including absolute 2030 targets (BMO, Citi, Wells Fargo), fossil fuel financing reductions (Lloyds, BNP Paribas, ING, Societe General), and public disclosure regarding client net zero evaluation and progress (Credit Suisse, ANZ Group). This proposal is consistent with one filed and withdrawn by MÉDAC last year.[4]

To address uncertainty and increase transparency, we urge shareholders to vote FOR this proposal.

[1] https://oxfam.qc.ca/wp-content/uploads/2022-canada-banks-carbon-footprint-report.pdf

[2] https://www.osfi-bsif.gc.ca/Eng/fi-if/rg-ro/gdn-ort/gl-ld/Pages/b15-dft.aspx#toc1

[3] https://assets.bbhub.io/company/sites/63/2022/09/Recommendations-and-Guidance-on-Financial-Institution-Net-zero-Transition-Plans-November-2022.pdf

[4] https://www.td.com/document/PDF/investor/2022/E-2022-Proxy-Circular.pdf

Resolution Details

Company:

Toronto-Dominion Bank

Year:

2023

Issue Area:

Climate Change

Focus Area:

Indigenous Peoples/FPIC

Status:

Withdrawn for Agreement

Resolution Text

The United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP) stipulates that States shall consult in good faith with Indigenous peoples in order to obtain their free, prior and informed consent (FPIC) before implementing measures that may affect them. The federal UNDRIP Act affirms that UNDRIP has legal effect in Canada.1

The Truth and Reconciliation Commission’s Call to Action #92, calls upon the corporate sector to adopt and implement UNDRIP “as a reconciliation framework and to apply its principles, norms, and standards to corporate policy and core operational activities involving Indigenous peoples and their lands and resources.”2

Foley Hoag LLP’s report to banks which funded the controversial Dakota Access Pipeline Project recommended that international industry good practices on FPIC means going beyond the minimum standards set by domestic law.3

Failing to consider FPIC also overlooks a material risk. Companies which only seek domestic legal minimums or fail to obtain FPIC routinely see project delays, conflict, and other significant legal, political, reputational, and operational risks.

The Government of Canada has stated that FPIC is contextual and there is no “one size fits all” approach, and operationalizing FPIC may require different processes or new creative ways of working together.4

A 2019 paper prepared for the Union of BC Indian Chiefs entitled Consent5 (Consent Paper) attempts to clear up misconceptions about FPIC, including:

“consent” and “veto” are not the same; they have different meaning and uses; and
FPIC is not an extension of consultation and accommodation, which are procedural in nature.

The Consent Paper outlines ways in which Canadian businesses can operationalize FPIC, including:

seeking and confirming Indigenous consent prior to making decisions;
outlining the conditions necessary for obtaining and maintaining a Nation’s consent, as opposed to legal devices such as releases that are intended to limit Indigenous rights;
using collaborative dispute resolution mechanisms and not limiting a Nation’s ability to take legal action; and
building a process for future decision-making and obtaining consent before any approvals are sought from the Crown.

TD outlines a mechanism for evaluating FPIC within its Environmental and Social Credit Risk assessments. A good first step, but the process is not transparent and relies on the Equator Principles which are not aligned with the Consent Paper. The material risks related to the failure to obtain FPIC are not captured in current policies and have not been reflected in financing decisions.

Further action is required to operationalize FPIC and Call to Action #92 into TD’s corporate policies and activities. An explicit reference to operationalizing FPIC will help mitigate human rights risk while giving TD additional leverage to effect meaningful and necessary change on the path towards reconciliation.

RESOLVED THAT: TD align its policies and practices with international industry good practice as outlined by Foley Hoag, and take further steps to operationalize FPIC by revising its Environmental and Social Credit Risk Process to be consistent with the Consent Paper.

1 https://daccess-ods.un.org/access.nsf/Get?OpenAgent&DS=A/RES/61/295&Lang=E

2 https://www.rcaanc-cirnac.gc.ca/eng/1524506030545/1557513309443

3 https://www.foleyhoag.com/news-and-insights/publications/ebooks-and-white- papers/2017/may/good_practices_social_impacts_oil_pipelines_united_states/

4 https://www.justice.gc.ca/eng/declaration/bgnrcan-bgrncan.html

5 https://www.ubcic.bc.ca/consent_paper

Resolution Details

Company:

Toronto-Dominion Bank

Year:

2023

Issue Area:

Climate Change, Finance

Focus Area:

Climate Financing

Status:

Vote

Vote Percentage:

10.40%

Resolution Text

Public companies with pollution-intensive assets such as coal, oil, and gas projects (polluting assets) are coming under increasing pressure from institutional investors with ESG concerns. Certain issuers have sold or are contemplating selling these pollution-intensive assets. When these assets are sold to private enterprises, investors are concerned about the lack of disclosure that results.

The challenge of facilitating the movement of polluting assets from public companies to private enterprises was outlined by the UN Principles for Responsible Investment (PRI) in a recent publication discussing divestment of polluting assets by public companies[1]:

While a listed company spinning off a polluting asset may eliminate emissions from its balance sheet, it is unlikely to translate to a reduction in real-world emissions. In fact, it may reduce transparency and accountability over how the asset is managed, result in higher absolute emissions from more intensive exploitation of the asset, and shift risk onto governments and taxpayers.

A March 2022 paper by the European Corporate Governance Institute (ECGI) labels this phenomenon as “brown-spinning”[2]:

[T]here has been a concerning recent phenomenon known as brown-spinning whereby public companies sell their carbon-intensive assets to players in private markets (including private equity firms and hedge funds). This helps divesting companies to reduce their own emissions but does not result in any overall emission reduction in the atmosphere. [H]aving carbon-intensive assets going dark where they are not subject to the usual strict scrutiny of public markets is worrisome from the perspective of lowering emissions.

TD’s Environmental and Social Risk Process for Non-Retail Lending Business Lines describes heightened due diligence for transactions with higher environmental and social risk and includes a list of prohibited transactions, including mining of conflict minerals and activities within sensitive cultural/ecological sites.[3] A similar approach is needed for the bank’s involvement in brown-spinning transactions to bridge the disclosure gap between public and private enterprises.

TD’s Thermal Coal Position states TD will not lend to, facilitate capital markets transactions for, or advise on M&A for new mining company clients with a certain level of involvement in thermal coal operations. [4]

ECGI describes the benefits of improved disclosure from private entities, stating: “the uneven playing field between public and private companies would be levelled, thus eliminating the classical problem of avoiding regulatory obligations tied to being public by staying private (i.e, removing incentives to remain private longer to avoid sustainability disclosures).”

RESOLVED THAT TD amend its Environmental and Social Risk Process for Non-Retail Lending Business Lines to provide that when TD provides new project-specific financial services, including advisory services, on brown-spinning transactions, TD will take reasonable steps to have parties to such transactions take steps and make disclosures consistent with TCFD, including:

ensuring acquiring board oversight of climate-related risks,
annual acquiring entity disclosure of Scope 1 and 2 GHG emissions from the acquired assets, and
regarding such acquired assets, having the acquiring entity set targets for reducing GHG emissions within a reasonable time after completing the transaction.

[1] https://www.unpri.org/download?ac=16109

[2] https://ecgi.global/sites/default/files/working_papers/documents/gozlugolringefinal.pdf

[3] https://www.td.com/document/PDF/ESG/2021-TD-Environmental-and-Social-Credit-Risk-Process.pdf

[4] https://www.td.com/document/PDF/ESG/2021-Climate-Action-Report.pdf

Resolution Details

Company:

Toronto-Dominion Bank

Year:

2023

Issue Area:

Finance, Human Rights & Worker Rights

Focus Area:

Affordable Housing

Status:

Vote

Vote Percentage:

16.90%

Resolution Text

As part of the Canadian federal government’s National Housing Strategy and its recognition of housing as a fundamental human right, in February 2022 the federal government appointed a Federal Housing Advocate (FHA), whose role is to promote and protect housing rights in Canada by independently conducting research on systemic housing issues.[1]

The FHA commissioned a series of reports on the financialization of housing, which is described as the growing dominance of financial actors in the housing sector, transforming the primary function of housing into a for-profit financial asset.

According to the summary report to the FHA, 20-30% of Canada’s purpose-built rental housing stock is owned by real estate investment trusts (REITs). The report outlines certain controversies[2]:

Financial firms strategically pursue unit “turnovers” to capitalize on allowable rent increases between tenancies. Researchers in the US have found that financial operators use eviction as a revenue-generating tool, and that they evict tenants at higher rates than other types of owners.

This concentration is higher in Canada’s north. A series of CBC News reports from 2021 highlighted tenant complaints against a publicly traded REIT that owns approximately 80% of the multi-unit private residential housing stock in Yellowknife and Iqaluit.[3]

A recent CTV News article highlighted the results of a survey indicating that “large, publicly-traded corporations, were more likely to face poor living conditions compared to those in housing owned by families or private companies.”[4]

The report for the FHA on the financialization of multi-family rental housing in Canadas describes the negative effects of cost-cutting and under-maintenance strategies of financialized landlords, which result in worsened living conditions, as well as the displacement of lower income and racialized renters.[5]

Human Rights Due Diligence in Commercial Real Estate

In October 2022, BOMA Canada released its 2022 Human Rights Guide for Commercial Real Estate, which draws upon the United Nations Guiding Principles on Business and Human Rights (UNGPs) and the OECD Guidelines for Multinational Enterprises (OECD Guidelines). The guide outlines how commercial property owners can incorporate business and human rights due diligence concepts into their operations.[6]

Human Rights Due Diligence in Multi-Family Rental Real Estate

Without an equivalent set of human rights due diligence practices for REITs operating in the in the multi-family residential space, banks must ensure that they are complying with their own obligations under the UNGPs and OECD Guidelines. Specifically, banks must ensure they are seeking to prevent and mitigate adverse human rights impacts linked to their business relationships with these REITS, even if the banks themselves have not contributed to those impacts.

TD Involvement with Canadian Multi-Family Rental REITs

TD is the lead or administrative agent and lender for significant credit facilities for two leading Canadian REITs, and TD Securities Inc. has provided capital markets services to at least one leading Canadian REIT.

RESOLVED THAT TD disclose how it assesses and mitigates human rights risk in connection with its business relationships with clients which own multi-family residential rental properties in Canada.

[1] https://www.canada.ca/en/canadian-heritage/news/2022/02/statement-by-the-minister-of-housing-and-diversity-and-inclusion-on-the-appointment-of-canadas-federal-housing-advocate.html

[2] https://www.homelesshub.ca/resource/financialization-housing-canada-project-summary-report

[3] https://newsinteractives.cbc.ca/longform/the-landlords-game

[4] https://www.ctvnews.ca/business/tenants-with-large-corporate-landlords-more-likely-to-face-poor-living-conditions-survey-suggests-1.5992030

[5] https://www.homelesshub.ca/resource/financialization-multi-family-rental-housing-canada

[6] https://bomacanada.ca/wp-content/uploads/2022/09/BOMACANADA_HumanRightsGuide_2022_EN.pdf

Review of Governance Policies

Resolution Details

Resolution Text

Lead Filer

Resolution Details

Resolution Text

Lead Filer

Co-filer

Resolution Details

Resolution Text

Lead Filer

Co-filer

Resolution Details

Resolution Text

Lead Filer

Resolution Details

Resolution Text

Lead Filer

Resolution Details

Resolution Text

Lead Filer