The TD Bank Group has taken significant steps toward promoting diversity, equity and inclusion, says the bank’s first racial equity audit, noting it could do more on aspects like consistency and measurement.
TD was the first of Canada’s big six banks — and among the first companies in Canada — to agree to conduct such an audit amid increasing pressure from shareholders. These reviews are intended to provide a mechanism for assessing company policies and programs through a racial equity lens and to identify opportunities where organizations can enhance efforts to be more equitable and inclusive.
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The report by law firms Covington & Burling LLP and WeirFoulds LLP found TD has numerous initiatives and programs in place on DEI and “committed leadership” across the bank. However, the organization could improve in areas like more centralized, enterprise-level communications about DEI work, improved awareness of development opportunities for employees and more consistency in implementing policies.
It also found the bank could be better at setting targets and tracking its progress through data. “TD should enhance the consistency of the use of actionable and measurable goals . . . to better determine and articulate progress,” said the report.
The racial equity audit didn’t go far enough, says Emma Pullman, head of shareholder engagement at the British Columbia General Employees’ Union, one of the shareholders that pressed the bank to complete the assessment. It was impressive and important that it went ahead with the audit, and, while the report shows numerous worthwhile initiatives, there were notable deficiencies including limiting the assessment to employment practices and the lack of data in the report.
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“This audit is an important start, but it does miss the mark and that’s why we would like to see both some enhanced disclosure and also a commitment to completing this audit process.”
She notes both the Royal Bank of Canada and the Bank of Montreal last month committed to full audits that will go beyond employment practices into products and services as well, which would include impacts on customers and how lending practices contribute to racial equity.
In a letter responding to TD’s report, the BCGEU pointed to the racial equity audit conducted by Citigroup Inc., which set a goal to assess the bank’s efforts to “help address the racial wealth gap.” The bank’s audit was largely limited to questions around its efforts to provide a racially equitable and non-discriminatory workplace.
In an internal letter, the bank said it has a longstanding commitment to DEI but recognizes it has more work to do. It said it will incorporate the recommendations into its human resources plans and sees opportunities to apply the insights to its customer service practices.