FinanceMap scores this financial institution in the following areas. Please navigate to the relevant tab for in-depth analysis
FinanceMap assesses these portfolios for this financial institution. Please navigate to the relevant tab for in-depth analysis.
Toronto-Dominion (TD) Bank Group's board incorporates climate-related issues into corporate strategy, decisions on major transactions, and its risk management processes and policies. Management level positions and committees are assigned various climate-related responsibilities, and the organization has some descriptions of how senior management is involved in the management of climate strategy.
TD has referenced the climate-related risks and opportunities it considers relevant to its business, but does not disclose which risks and opportunities it considers over short, medium and long-term time horizons. The organization uses a heatmap analysis of risks across different lines of business to illustrate the sensitivity to climate risk by sector or location, and is transparent about climate-related risks and opportunities on lending, advisory, and investment activities. Additionally, TD has provided several examples of how it has factored climate-related risk into relevant products and services across its business, and is engaging with clients to develop decarbonization targets and transition plans.
TD uses climate scenario analysis to assess the resilience of its business, including an Enterprise-Wide Stress Test Climate Addendum using its internal climate risk heatmapping approach to determine shocks to borrowers’ risk ratings in 2023, and a physical risk scenario on its real estate portfolios in 2022. It has also participated in various initiatives to support its climate scenario analysis, including participating in a UNEP FI working group, Bank of Canada and OSFI Climate Change Pilot, and a pilot study with Moody's Analytics in 2021. However, it does not appear to use a robust range of climate scenarios, and does not describe how it plans to respond to the impacts identified in the analyses.
The organization outlines processes in place to identify and assess climate-related risks in its climate reporting. For example, TD Bank has developed a Climate Risk Inventory to identify and assess climate-related risks, and incorporates climate-related risks into its assessments of other risk types. TD details how it mitigates various types of climate risks, including using its climate risk heatmap to prioritize industry sectors for risk assessment and measurement. The organization also appears to have integrated climate-related risks into its overall risk management approach through its Enterprise Risk Management Framework.
TD discloses some key metrics used to measure and manage climate-related risks and opportunities including exposure to carbon-related assets, the amount of financing deployed towards climate-related opportunities, and remuneration policies. The organization is transparent regarding Scope 1, Scope 2, and relevant Scope 3 emissions data. TD discloses financed emissions as well, reporting absolute emissions measurements for 8 sectors and four PCAF asset classes.
TD has a net zero by 2050 target, and in October 2021 it joined the Net Zero Banking Alliance. In March 2022, TD released its 2030 interim targets for its lending to the energy and power sectors. In 2022, TD announced two additional sector targets for automotive manufacturing and aviation portfolios, both based on the IEA Net Zero scenario but both using an emissions intensity metric. In 2023 TD assessed its real estate and agriculture portfolios and determined that data quality and coverage were insufficient to set targets.
TD’s coal policy states that it will restrict new mining company clients that: derive ≥ 30% of its revenue from the production of thermal coal; new power generation clients that generate ≥ 30% of its power (MWh) from unabated coal-fired power generation; any new mining company client that publicly states its intention to expand its thermal coal mining operations; or new power generation client that publicly states its intention to expand its unabated coal-fired power operations. However, it has not set clear restrictions on existing clients, and has not outlined a coal phase out in line with IPCC guidance.
With regards to natural gas and oil, TD has set exclusionary policies that prohibit financing to new oil and gas exploration, development, or production in the Arctic Circle. However, TD has not outlined other activities related to oil and gas in its Environmental and Social Risk Process and thus appears to be actively financing new or expansionary projects. Additionally. the organization has set an interim target for the energy sector of a 29% reduction in financed emissions lending intensity by 2030.
TD is increasing its financing of renewables, using a methodology to determine what activities are eligible for its $500 billion sustainable finance target. This methodology also includes nuclear energy as part of its eligible decarbonization activities, and outlines that the organization will mobilize finance for nuclear energy facilities, services, systems, and equipment.
FinanceMap’s Climate Governance and Policies analysis assesses statements financial institutions (FIs) are making on how they are incorporating climate issues into their decision-making and operations using FinanceMap’s matrix methodology. This methodology is adapted from the Task Force on Climate-Related Financial Disclosures (TCFD) recommendations and guidelines, Net-Zero Banking Alliance (NZBA) or equivalent Glasgow Financial Alliance for Net-Zero (GFANZ) initiative reporting, and IPCC and IEA technology statements. The TCFD provide guidance on 11 recommendations across four areas which are reflected in our matrix: Governance, Strategy, Risk Management, and Metrics and Targets. Additional benchmarks have been introduced to strengthen the ambition of scoring criteria in the assessment of targets, which are supplemented by guidance from the NZBA or equivalent GFANZ initiatives.
Additionally, Science-Based Policy (SBP) benchmarks are used to measure alignment of an FIs technology positions with the science of climate change. These benchmarks are applied to an FIs internal policies on technologies including coal, oil, gas, nuclear, and renewables and also assesses its engagement with broader climate and energy policy issues such as advocacy on the role and importance of different strategy types in the future energy mix.
For each TCFD recommendation and technology, FIs statements are applied to a five point scoring scale ranging from +2 to -2, measuring alignment with the relevant benchmarks. The detailed scores for this FI are displayed below within each matrix cell.
The following table outlines the key queries and data sources, which FinanceMap uses to assess financial institutions climate governance, targets and policies. Every evidence piece is assessed on a five-point scale of -2,-1,0,1,2 or NA (not applicable)/NS (not scored). All queries, data sources, and evidence pieces are weighted against one another in a matrix system to arrive at a final top-level score. Clicking on specific cells will load the underlying evidence and information on how it has been assessed.
Fossil fuel companies are those whose primary sector falls within coal mining and services, or up-, mid-, and downstream oil and gas sectors. Green companies are defined as companies having over 75% revenue deriving from Substantial Contribution to Mitigation activities under the EU Taxonomy.
Portfolio Paris Alignment analysis of this institution's activities in this portfolio area assesses deals in 2020–2024.
Value Assessed: $403B
Sector Paris Alignment scores for the sectors to which this portfolio has exposure. FinanceMap Paris Alignment analysis is limited to the automotive, upstream fossil fuel, and power sectors.
Fossil fuel companies are those whose primary sector falls within coal mining and services, or up-, mid-, and downstream oil and gas sectors. Green companies are defined as companies having over 75% revenue deriving from Substantial Contribution to Mitigation activities under the EU Taxonomy.
Portfolio Paris Alignment analysis of this institution's activities in this portfolio area assesses deals in 2020–2024.
Value Assessed: $170B
Sector Paris Alignment scores for the sectors to which this portfolio has exposure. FinanceMap Paris Alignment analysis is limited to the automotive, upstream fossil fuel, and power sectors.
Fossil fuel companies are those whose primary sector falls within coal mining and services, or up-, mid-, and downstream oil and gas sectors. Green companies are defined as companies having over 75% revenue deriving from Substantial Contribution to Mitigation activities under the EU Taxonomy.
Portion of AUM Assessed: $13.3B
| Holding Name | Contribution to Sector Production |
|---|---|
| CLP Holdings Ltd | 12.6% |
| Emera Inc | 8.8% |
| Enel SpA | 5.6% |
| Capital Power Corp | 4.8% |
| Iberdrola SA | 4.1% |
| Fortis Inc | 4.1% |
| CMS Energy Corp | 3.5% |
| Chubu Electric Power Co Inc | 3.5% |
| TransAlta Corp | 3.1% |
| DTE Energy Co | 3.0% |
| Holding Name | Contribution to Sector Production |
|---|---|
| Toyota Motor Corp | 36.1% |
| Stellantis NV | 8.7% |
| Maruti Suzuki India Ltd | 8.2% |
| Volkswagen AG | 7.4% |
| Honda Motor Co Ltd | 6.7% |
| Suzuki Motor Corp | 4.9% |
| General Motors Co | 4.0% |
| Nissan Motor Co Ltd | 3.6% |
| Ford Motor Co | 3.5% |
| Tesla Inc | 3.4% |
| Holding Name | Contribution to Sector Production |
|---|---|
| Glencore PLC | 80.9% |
| Whitehaven Coal Ltd | 19.1% |
| Holding Name | Contribution to Sector Production |
|---|---|
| Canadian Natural Resources Ltd | 19.0% |
| Suncor Energy Inc | 12.6% |
| Cenovus Energy Inc | 7.6% |
| Tourmaline Oil Corp | 7.0% |
| BP PLC | 5.4% |
| Shell PLC | 5.1% |
| TotalEnergies SE | 3.6% |
| Exxon Mobil Corp | 3.3% |
| Eni SpA | 2.5% |
| ENEOS Holdings Inc | 2.4% |
TD Asset Management (TD AM) does not appear to be firmly engaging with companies on climate. Climate engagement appears to have a defined structure, for example, the asset manager develops an annual Climate Focus List based on the issuer’s historical environmental performance, assessment of climate targets, and the assets under management. It states it strives to track and engage companies that do not report their GHG emissions or do not have net zero aligned targets, but it is unclear whether it uses milestones to measure engagement progress. Additionally, it is unclear whether it has defined an engagement escalation strategy.
Although the asset manager states engagements under its Climate Focus List are focused on encouraging companies to publish Scope 1, 2, and 3 emissions, set SBTs that are aligned with net zero by 2050, and detail tactics to achieve emissions targets, it does not provide examples of company engagements to support this. Given its lack of engagement case studies, it is unclear whether the asset manager has driven behavior change on climate. TD AM does not appear to be engaging with companies on climate policy influence. It appears to be engaging in various collaborative initiatives including CA100+ and Climate Engagement Canada, but it is unclear the extent to which it has contributed to these initiatives.
TD AM has outlined its stewardship governance structure and processes, referencing how the work of the ESG Committee is communicated to upper management. It has limited transparency on engagements, providing some anonymous case studies in its quarterly voting reports. The asset manager discloses all of its proxy voting data as well as its proxy voting guidelines but does not provide voting justifications. TD AM does not appear to be willing to use its shareholder authority to file Paris Aligned shareholder resolutions or publicly vocalize its support for such resolutions.
Insightia data suggests that TD has become increasingly supportive in recent years of AGM resolutions InfluenceMap categorizes as in line with the Paris Agreement, supporting 32% in 2019, 52.6% in 2020, 82.5% in 2021, and 73.7% in 2022.
FinanceMap's methodology to measure the engagement process on climate was developed in consultation with several of the world's leading asset managers and uses key aspects of the UK Financial Reporting Council's 2020 Stewardship Code . The Stewardship Code was chosen to benchmark engagement quality as it provides an ambitious framework and detailed definitions of what constitutes effective engagement. FinanceMap defines the term ‘engagement’ as referring to all investor actions undertaken to influence the management strategy of the companies they own including private communications with corporate management and appointed advisors; questions at AGMs/other company meetings; comments on the company in the media; escalation and the shareholder resolution process (filing, voting behavior). FinanceMap’s methodology breaks the engagement process down into a set of sub-activities and looks for evidence associated with these across publicly available data sources.
Climate-relevance categorization of shareholder resolutions is based on the IPCC’s Special Report on 1.5°C and its concluded need for “rapid and far-reaching transitions in land, energy, industry, buildings, transport, and cities.” FinanceMap scored voting on any resolution where the intent and likely outcome is consistent with this IPCC stated need. The voting data is drawn from asset managers' disclosures to the US Security Exchange Commission (SEC), asset manager websites (including third-party websites they link to), directly from the asset managers, and through specialist voting data provider Insightia. The full list of resolutions assessed is available here.
The following table outlines the key queries and data sources, which FinanceMap uses to assess asset managers' corporate engagement programs. Every evidence piece is assessed on a five-point scale of -2,-1,0,1,2 or NA (not applicable)/NS (not scored). All queries, data sources, and evidence pieces are weighted against one another in a matrix system to arrive at a final top-level score. Clicking on specific cells will load the underlying evidence and information on how it has been assessed.
Climate Lobbying Overview: TD Bank Group (TD) and its asset management subsidiary TD Asset Management (TDAM) appear to have had limited transparent engagement on climate-related finance policy, disclosing that they are engaged on a variety of policy areas without disclosing specific positions on these policies.
Top-Line Messaging on Climate-Related Financial Policy: In TDAM’s 2023 TCFD Report it supported action to achieve net-zero by 2050. In TD’s 2023 Public Policy and Political Contributions report TD described engaging with the Canadian governments on sustainable finance policy, but did not outline details of this engagement.
Position on Regulated Corporate Climate Disclosure: TD appears engaged on regulated corporate climate disclosure with somewhat unclear positions. In its 2023 TCFD and Sustainable Investment reports TDAM described engaging on climate disclosure policies and standards across regions, including Canada, Singapore, and globally, but details of this engagement are unclear. In TD’s 2023 Climate Action Plan Progress Update, it supported the need for policy to improve climate disclosure in Canada. In TD’s 2023 CDP response it supported, with minor exceptions, climate reporting in Canada. A May 2023 memo from the US Securities and Exchange Commission (SEC) shows that TD CEO Bharat Masrani met with the SEC to discuss its climate disclosure proposal, though details of this meeting are unclear.
Position on Taxonomies: In TD’s 2023 Climate Action Plan Progress Update it supported the need for a Canadian taxonomy with clearly defined “green” and “transition” activities, and described its engagement in the Sustainable Finance Action Council’s Taxonomy Roadmap Report work. In TDAM’s 2023 Sustainable Investment Report it disclosed engagement with the Monetary Authority of Singapore on taxonomy policy, but gave no details of this engagement.
Position on Incorporating Climate Factors Into Risk Management/Prudential Regulation: In its 2022 Climate Action Report, TD described indirectly engaging on ongoing efforts by financial regulators to embed climate risk into regulation and supervision of financial institutions, but did not take a position on these efforts. In its 2022 CDP Response TD stated “support with minor exceptions” for the Canadian Office of the Superintendent of Financial Institutions (OSFI) climate risk work. A memo from the US Office of the Comptroller of the Currency (OCC) details a March 2022 meeting with the Bank Policy Institute (BPI) and its constituents, including representatives from TD Bank, where BPI and its constituents outlined the “challenges” of implementing the OCC’s proposed Principles for Climate-Related Financial Risk Management for Large Banks.
Position on Real Economy Climate Policy: In 2022 testimony to the Canadian House of Commons, TD Managing Director Francis Fong appeared to support Canada’s oil and gas emissions cap as “one of many policies” to achieve emissions reduction. In the same testimony, Fong did not take a clear position on Canada’s proposed methane regulations for the upstream oil and gas sector.
Position on Energy, Industry, and Land Transitions: In 2022 testimony to the Canadian House of Commons, TD Managing Director Francis Fong appeared supportive of government action to decarbonize the economy, and supported the use of carbon capture and storage (CCS) as “part of the larger toolbox” used to address emissions. In the same testimony, Fong advocated for CCS to decarbonize oil and gas production, but did not take a position on the overall reduction of oil and gas in the energy mix in line with IPCC findings.
Industry Association Governance: TD has disclosed a list of industry association memberships but without describing these groups' climate-related positions and engagement activities. As a result, it omits important details about engagement by these associations, including the Business Council of Canada's unsupportive position on the Canadian Oil and Gas emissions cap and the Canadian Bankers' Association's objections to some risk management principles set out by the Basel Committee on Banking Supervision.
InfluenceMap collects and assesses evidence of corporate climate policy engagement on a weekly basis, depending on the availability of information from each specific data source (for more information see our methodology). While this analysis flows through to the company’s scores each week, the summary above is updated periodically. This summary was last updated in Q1 2025.
InfluenceMap’s methodology for assessing lobbying on climate finance policy closely follows InfluenceMap’s established methodology on climate policy engagement, which is used extensively by investors, including via the Climate Action 100+ investor engagement process. Our full methodology can be found here.
Under our lobbying assessment, InfluenceMap considers engagement on all financial policies which intersect with climate issues, as well as “real economy” climate change policies.
The analysis takes into account both the engagement of the financial institution and the activities of industry associations they hold membership of. InfluenceMap’s methodology covers seven publicly available data sources, searching for evidence of engagement and corporate positioning since 2017. To determine the policy issues within the scope of the analysis, InfluenceMap breaks down policy engagement into a series of subcategories, or 'queries'. These are designed to cover high-level issues relating to the importance of sustainable finance, as well as more specific areas of sustainable finance policymaking. InfluenceMap’s research process searches for evidence of an organization's engagement with each policy issue, across each of the data sources.
The following table outlines the key queries and data sources, which InfluenceMap uses to assess financial institutions' policy engagement. Every evidence piece is assessed on a five-point scale of -2,-1,0,1,2 or NA (not applicable)/NS (not scored). All queries, data sources, and evidence pieces are weighted against one another in a matrix system to arrive at a final top-level score. Clicking on specific cells will load the underlying evidence and information on how it has been assessed.
In this section, we depict graphically the relationships the corporation has with trade associations, federations, advocacy groups and other third parties who may be acting on their behalf to influence climate change policy. Each of the columns above represents one relationship the corporation appears to have with such a third party.
In these columns, the top, dark section represents the strength of the relationship the corporation has with the influencer. For example if a corporation's senior executive also held a key role in the trade association, we would deem this to be a strong relationship and it would be on the far left of the chart above, with the weaker ones to the right. Click on these grey shaded upper sections for details of these relationships. The middle section contains a link to the organization score details of the influencer concerned, so you can see the details of its climate change policy influence. Click on the middle sections for for details of the trade associations. The lower section contains the organization score of that influencer, the lower the more negatively it is influencing climate policy.
