October 14, 2015 Mr. Lou Eccleston TMX Group The Exchange Tower 130 King Street West Toronto, Ontario M5X 1J2 Sent by email Dear Mr. Eccleston: Re: Model Reporting Guidance We are writing to commend TSX for its contribution to the United Nations Sustainable Stock Exchanges (SSE) initiative Voluntary Model Reporting Guidance. Globally, stock exchanges promote sound financial reporting and corporate governance standards. As a conduit between issuers and investors, exchanges are uniquely placed to create more transparent and efficient capital markets that generate long-term value. While thousands of companies globally are reporting some environmental, social and governance (ESG) data, the current state of disclosure 1 is not sufficient for investors to effectively inform investment decisions. Guidance for companies on how reporting may address ESG considerations, as well as highlighting these issues in existing definitions of what constitutes material information, is therefore an important step towards creating a stable financial system that advances sustainable economic growth. For your reference, we, the undersigned investors, representing over USD $10 trillion in assets under management, and companies, with over USD $400 billion in market capitalization, are writing to all exchanges requesting they take the important step of creating a guidance for companies on reporting ESG information. We are writing to you to applaud your existing guidance, and encourage you to continue to engage with companies and investors on sustainability issues. We commend TSX for having already issued its own guidance on ESG reporting, the Primer for Environmental & Social Disclosure. We are thankful for the time and effort TSX contributed recently to consultations on the attached United Nations SSE initiative Voluntary Model Reporting Guidance. We hope that it will prove to be a useful resource when TSX updates its own guidance. Representatives of the signatories are at your disposal to assist in this process. 1 Data per the 2015 Corporate Knights Capital report, Measuring Sustainability Disclosure: Ranking the World s Stock Exchanges found only 3 % of the world s largest 4,696 listed companies disclose standard sustainability indicators. Standard sustainability indicators considered in the report were: employee turnover, energy, greenhouse gas emissions, injury rate, payroll, waste, and water.
We would also like to commend TSX for its continuing engagement with signatories participating in the SSE initiative. Through this engagement we have become aware of other ESG activities by the exchange, including educational events for issuers and collaborations with the Principles for Responsible Investment, CDP and the Global Reporting Initiative. We encourage TSX to explore ways to communicate more widely on these efforts. We encourage TSX to continue to engage with companies and investors on sustainability issues. If you have any questions regarding this letter or would like to update us on your sustainability plans, we ask your team to contact our representatives by 30 November, 2015, so that they can provide feedback to the signatories. Michelle de Cordova, Director, Corporate Engagement & Public Policy, NEI Investments mdecordova@neiinvestments.com 604 742 8319 Jennifer Coulson, Senior Manager, Shareholder Engagement, bcimc jennifer.coulson@bcimc.com Marissa Blankenship, Allianz Global Investors marissa.blankenship@allianzgi.com We thank you for your time and consideration, and we look forward to working together to create more sustainable capital markets. Sincerely, Alex Shaik Partner; General Counsel Alison Schneider Director, Responsible Investment Pascal Blanqué Global CIO and Head of Institutional Investors & Third Party Distributors Rebecca Lewis Investment Analyst Adam Seitchik Chief Investment Officer Dennis van der Putten Head ESG Research Peter Lundkvist Head of Corporate Governance Andrew Affleck Founder and Managing Partner
Brian Minns Manager, Sustainable Investing Charlotta Dawidowski Sydstrand ESG Manager André Veneman AkzoNobel Corporate Director, Sustainability & HSE Mariana Bozesan Founder David Schofield Valdur Jaht Jay Ralph Group Head of Corporate Responsibility Member of the Management Board Member of the Board of Management Annelie Gotbring Head of RI Steve Waygood Head of Sustainability Research & Engagement Maria Isabel Echeverri Sustainability Vice President Katherine Garrett-Cox Phil Vernon Managing Director Arne Lööw Head of Corporate Governance Ulrika Danielson Head of Communications/ Coordinator Corporate Governance
André Heimrich CIO My-Linh Ngo Senior ESG Analyst Bryan Thomson SVP Public Equities Carlos Massaru Takahashi Helena Viñes Fiestas Head of Sustainability Research Vicki Bakhshi Head, Governance and Sustainable Investment Lauren Compere Director of Shareowner Engagement Reinaldo Le Grazie Curtis Ravenel Stephanie Leaist Global Head, Sustainable Business & Finance Managing Director, Head of Sustainable Investing Erik Amcoff Head of Communications Tim Macready Chief Investment Officer and Member of the Group Executive Committee Annamaria Trovò Chairman
Naïm Abou-Jaoude Kristian Fok Executive Manager, Investment Strategy Angela de Wolff Founding Partner Ginette Depelteau Senior Vice-President, Compliance and Responsible Investment Jukka Keskitalo Director General Gunnela Hahn Head of Responsible Investment Andrew Brown Chief Executive Sebastien Thevoux-Chabuel Head of ESG Research Erika Karp Iain Richards Head of Responsible Investment, EMEA Frank Hagenstein Managing Director, CIO, Head of Investment Strategy Active Asset Management James Dilworth Managing Director and Neil Brown Senior Partner
Alessandra Viscovi Susan Vickers VP Corporate Responsibility Thomas von Koch Managing Partner Francesco Starace Geoffrey Mazullo Principal Emerging Markets ESG Vincent Kaufmann Neville White Head of SRI Policy and Research Roberto Conte Chairman of the Pension Scheme Lorenzo Nogales Founding Partner Antony Marsden Head of Governance and Responsible Investment Vital Proulx President and Chief Investment Officer Saker Nusseibeh Chief Executive Officer Elisabet Jamal Bergström Head of Corporate Governance & Responsible Investments Carlo Petagna Director General
Lisa Beauvilain Head of Sustainability & ESG Pierin Menzli Head Sustainable Investment Research Dermot Courtier Secretary to the Trustee ESG Committee Robert De Guigné Head of SRI Meryam Omi Head of Sustainability Christina Kusoffsky Hillesöy Christian Godin Head of Responsible Investments, Asset Management Senior Vice President, Head of Equities Susan Makos Vice President of Social Responsibility Narina Mnatsakanian Senior Advisor Responsible Investment & Governance Peter Wallach Head of Merseyside Pension Fund Luan Steinhilber Director of Operations and Shareholder Advocacy Hervé Guez Director, Responsible Investment Research
Adrian Orr Mark Fawcett Chief Investment Officer Hervé Guez Director, Responsible Investment Research David Murphy Chief Executive and Secretary Janet Voûte Chair of the Nestlé Creating Shared Value Council John Kearns Barney Crockett Pension Committee Convener Fredric Nyström Head of Responsible Investment Christian Stracke Marcel Jeucken Julie Gorte Managing Director, Global Head of Credit Research Managing Director Responsible Investment Senior Vice President for Sustainable Investing Andrée Mayrand Director, Investment Management Michael Baldinger Rockefeller Asset Management Sustainability and Impact Investing Group Per Lindgren Head of Manager Selection and Acting Head of Governance
Luciane Ribeiro Marcel Snijders Director of the Executive Office Eric Holterhues Head of SRI Ingo Speich Head of Sustainability and Engagement Elizabeth Fernando Head of Equities Patricia Farrar-Rivas Partner and Vania Somavilla Executive Director of Human Resources, Health and Safety, Sustainability and Energy Timothy Smith Director of Environmental, Social & Governance Shareowner Engagement Kirsty Jenkinson Managing Director, Sustainable Investment Strategies Urban Angehrn Chief Investment Officer and Member of the Group Executive Committee