Canada’s Big Six Banks Under Fire: AI, Child Labour Risks & the Push for Energy Transparency
March 27, 2025
Daniel Kehoe and Caoimhe Taylor
As we move into April, the ‘Big Six’ Canadian Banks once again are prominent on shareholder engagement with multiple proposals being put forward at each of the six companies. The ‘Big Six’ are all hosting their Annual General Meeting (AGM) in April, with five of the meetings coming during the first half of the month. The AGM dates are as follows:
- Canadian Imperial Bank of Commerce (CIBC) – April 3, 2025, at 9:30am
- Bank of Nova Scotia (BNS) – April 8, 2025, at 9:30am
- Royal Bank of Canada (RBC) – April 10, 2025, at 9:30am
- Toronto-Dominion Bank (TD) – April 10, 2025, at 9:30am
- Bank of Montreal (BMO) – April 11, 2025, at 9:30am
- National Bank of Canada (NBC) – April 24, 2025, at 10:00am)
At the forefront of the shareholder proposals is the Mouvement d’éducation et de défense des actionnaires (MÉDAC), a shareholder group who state their aim is to provide ‘small shareholders with both an opportunity to be heard and a space for discussion, information, and advocacy.’ MÉDAC have been prominent in Canadian shareholder engagement for several years now and show no signs of slowing down.
Diversity and sustainable environmental practices are recurring themes within upcoming US shareholder proposals, with resolutions from shareholders such as As You Sow and The Comptroller of the City of New York. However, by and large, the most prominent resolution proponent for the US companies at the beginning of April is John Chevedden, filing a variety of resolutions on lobbying, executive remuneration packages, and pollution goals.
Canadian Banks
As shown in Table 1 below, a total of 42 shareholder proposals will be faced by the ‘Big Six’ Banks with all meetings being subject to at least 5 proposals. This will undoubtedly be the busiest time in Canada for shareholder engagement.
Table 1: Total Shareholder Proposals among the ‘Big Six’ Canadian Banks in 2025
Source: Minerva Analytics Ltd
*Please note the figures only reflect proposals which made it onto the agenda and not those withdrawn in advance.
As we delve further into the proposals, we see many common proposals amongst the banks as shown in the table 2 below, which highlights the resolution number of the same proposals at each of the Canadian banks.
Most of the proposals have been proposed by MÉDAC apart from one by Vancity Investment Management Ltd, which related to internal metrics and their influence on executive pay, as well as the energy supply ratio proposal which was proposed predominantly by SHARE and by The Comptroller of the City of New York.
Table 2: Common Proposals among the ‘Big Six’ Canadian Banks in 2025
Source: Minerva Analytics Ltd
*Please note this table includes only common proposals and not all proposals presented at each Bank’s AGM.
Provided below are short summaries of each of these recurring proposals, including further insight into the potential aspirations of the proponents for filing such shareholder resolution:
Country-by-Country Reporting & Tax Transparency
Featured in all six banks’ agendas, MÉDAC requests the banks to annually disclose non-confidential information relating to their Country-by-Country Reporting which includes calculations of compensation ratios. The aim of the proposal is to enhance financial transparency and accountability and reduce the chance for the banks to engage in tax avoidance.
Say on Climate
This proposal is looking to hold companies accountable for their impact on the environment. The proposal makes references to the fossil fuel industry receiving financing from the ‘Big Six’ and is featured at all their AGMs. MÉDAC is requesting the company to adopt an annual advisory voting policy with respect to their environmental and climate action plans and objectives (known as a ‘say on climate’) to ensure the banks are held accountable.
Employee Language Disclosure
This proposal seeks the companies to provide disclosures of the language fluency of their employees, or in some cases directors and executives, noting the multicultural nature of Canada as well as the fact that companies on the Toronto Stock Exchange may operate in either English or French. MÉDAC has proposed this to all of the six Banks, and is not a new resolution, having been proposed to several Canadian companies since 2023.
Generative AI Code of Conduct
Featuring at five of the ‘Big Six’, this is a new proposal for the 2025 AGM season and has been filed by MÉDAC. The proposal requests that the banks adopt the Generative AI Voluntary Code of Conduct in order to increase transparency and accountability around generative AI usage. Given the advancement in such technologies, shareholders are concerned about the lack of regulation in this area and thus the voluntary Code is aimed at ensuring responsible practice and usage of these new technologies.
Forced & Child Labour Risk in Loan Portfolios
Again proposed by MÉDAC, five of the six banks have received a proposal regarding the risk of incidents of child labour within the companies’ supply chains. This is a new proposal for the Canadian banks, although similar topics are of frequent concern in North American companies. This proposal seeks for the companies to disclose their efforts to combat forced labour according to the Fighting Against Forced Labour and Child Labour in Supply Chains Act 2023.
Internal Metrics & Their Influence on Executive Compensation
Less prominent than some of the other proposals but this topic was among three of the Banks agendas. This proposal was put forward by Vancity Investment Management Ltd. The proposal asks for greater disclosure on the internal metrics and their influence on Executive Compensation. The proposal looks to ensure fairer pay by assessing the pay gaps between the CEO and workers, with the proponent being concerned about the widening pay disparities.
Energy Supply Ratio
The Energy Supply Ratio requests three banks to disclose annually their Energy Supply Ratio, defined as the banks’ total financing through equity and debt underwriting as well as project financing in low-carbon energy supply relative to that in fossil fuel energy supply. This proposal is aimed at increased accountability and pushing for the banks to improve their ratio by increasing financing within the clean energy sectors and provide greater transparency on fossil fuel financing.
US Companies
In the US, we can see a range of shareholder proposals being put forward in the first half of April. Both Moody’s Corp (15 April) and Synopsys Inc (10 April) have received resolutions from John Chevedden requesting the implementation of an advisory vote on golden parachute payments, or termination provisions in excess of 2.99 times salary plus target bonus. This proposal seems to be particularly prevalent this AGM season, demonstrating a continued concern that executive pay packages may not be appropriately reflecting shareholders’ interests. The increased frequency of resolutions relating to golden parachute payments in 2025 demonstrates shareholders looking to progress away from huge payments to executive directors. One thing which will be interesting is whether shareholders opt to support these proposals or not. The support of such proposals would leave the companies open to losing competitive advantages in terms of attracting and retaining top level talent, if top level talent had concerns about a reduction in these packages.
As demonstrated below, this was a reasonably frequent proposal in 2024. Although receiving a fairly low average percentage of votes in favour, there were some instances of the proposal being well received, such as at Xerox Holdings Corp, where it received 41.42% votes in favour. However, on the opposite side, there were cases of much lower support, for instance, at Paramount Global, as shown below. Given the frequency of these proposals so far in 2025, shareholders can continue to expect these Golden Parachute resolutions frequently throughout the rest of 2025.
Table 3: Frequency of Golden Parachute resolutions in 2024 versus 2025, and average 2024 votes in favour
Source: Minerva Analytics Ltd
Once again, DEI is also a prevalent issue at upcoming AGMs in April. A. O. Smith (8 April) has received a proposal from NorthStar Asset Management requesting a report outlining the Company’s policy on hiring formerly incarcerated individuals; a proposal also present at the company’s 2024 AGM. In addition, Lennar Corp (9 April) has received a proposal from The Comptroller of the State of New York requesting that the company report on its LGBTQIA+ equity and inclusion policies. Although this is not a new proposal, it is a particularly salient issue at present, given the Trump administration’s anti-DEI stance, and thus reflects the anxieties held by shareholders on the impact of government policies on corporate human capital programmes. The continued impact of Trump’s anti-DEI stance has no doubt generated concerns for shareholders who view diversity as positive, and the continued presence of such proposals demonstrates that DEI remains a key issue for investors.
Lennar Corp’s second shareholder proposal comes from As You Sow, seeking for the Company to disclose plans to reduce GHG emissions within their value chain according to short and long-term science-based goals. Setting and disclosing time-bound GHG reduction goals in-line with international standards such as the Paris Agreement remains a key priority point for investors, despite the Trump administration’s anti-ESG stance and withdrawal from the Paris Climate Agreement. This proxy season has continued to follow this trend.
Furthering demonstrating the continued importance of sustainable business practices is As You Sow on behalf of John Chevedden’s proposal to Goodyear Tire & Rubber Co (14 April), requesting the adoption of goals to reduce tyre shedding. They note that tyre wear particles are a significant contributor to pollution, thus damaging wildlife and biodiversity. While this is a new proposal for Goodyear, proposals that seek companies to reduce forms of pollution specific to their particular sectors are not new and demonstrate the emphasis investors place on ensuring that companies maintain sustainable and responsible business practices.
Conversely, US Bancorp (15 April) has received a proposal from American Conservative Values ETF, a notable anti-ESG proponent opposed to ‘woke liberal investments’. In line with their ideology, they have requested that the company undertake an evaluation regarding risks relating to politicised de-banking. This was a common “shadow proposal” filed during the 2024 proxy season at major financial companies like Wells Fargo and Citigroup, and the proposal alleges that banks are denying services to ‘conservatives and religious Americans’. Proposals such as this demonstrate the anxieties held by anti-ESG investors regarding the ‘woke’ influence on companies, especially financial services.
Proposals regarding lobbying contributions and policies disclosures have been presented at the upcoming April AGMs; Hewlett Packard Enterprise Co (2 April) and Carrier Global Corp (9 April) have both received such resolutions from John Chevedden. Shareholders are often concerned with ensuring companies are making the recommended disclosures to ensure transparency and accountability; these types of proposals are ones seen during every peak AGM season, and it is expected that these resolutions will continue to occur throughout the rest of the 2025 season.
As we progress into the second half of April, the next proposal blog will look to analyse the updates in shareholder engagement. The blog will look at proposals from several US meetings for financial companies such as Bank of America, Citigroup, Wells Fargo, and Goldman Sachs, as well as other companies such as Coca-Cola, Johnson & Johnson, and HCA Healthcare.
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Last Updated: 28 March 2025