Policy Positions


Joint Canadian investor letter to the Modernization Task Force

SHARE helped to convene a group of Canada’s largest pension investors and asset management firms to present proposals to Ontario’s Capital Markets Modernization Task Force, working together to encourage Canadian regulators to take up improved environmental, social and governance (ESG) disclosure requirements, improve corporate diversity, and address climate change.

September 2020

Letter to US SEC about Rule 14a-8

SHARE CEO Kevin Thomas comments on the rules proposed by the Securities and Exchange Commission (SEC) on November 5th, 2019. SHARE believes both proposals are arbitrary, costly, counter-productive and detrimental to the workings of capital markets and the private ordering of shareholder and management relationships.

January 2020


Letter to US SEC about June 21, 2019 Rule 14a-8 Stakeholder Meeting

SHARE is concerned with the potential change in practice at the SEC in which some “no action” requests would not receive a written decision.

July 2019

Comments on the Ontario Security Commissioner’s 2019-20 Draft Statement of Priorities


SHARE offers comments and recommendations regarding the OSC’s Draft Statement of Priorities on promoting confidence in Ontario’s capital markets, reducing regulatory burden and strengthening our organizational foundation.

May 2019

Public consultation on the Pay Transparency Act for the Ontario Ministry of Labour on May 1, 2019

SHARE believes there is a clear business case for addressing the gender pay gap and recommends the Government look to other jurisdictions that have already implemented gender pay gap reporting for experience in designing effective and reasonable regulations.

April 2019

Public consultation on the supervisory guidelines on the integration of ESG factors in the investment and risk management of pension funds

SHARE responded to a consultation by the International Organisation of Pension Supervisors (IOPS) on the supervisory guidelines on the integration of ESG factors in the investment and risk management of pension funds.

March 2019

Letter to the Canadian federal government on retirement security enhancement

Following discussions with Innovation, Science and Economic Development (ISED) Canada and Finance Canada, SHARE wrote a follow-up letter proposing extending clawback provisions to allow the recovery of company dividends, executive compensation and other extraordinary payments made, in order to protect workers’ retirement savings in light of insolvencies.

January 2019


Policy submission on proposed Bill 4, Cap and Trade Cancellation Act, 2018 as posted by the Ontario Ministry of Environment, Conservation and Parks on September 11, 2018

SHARE would like to offer comments and recommendations regarding Ontario’s proposed Cap and Trade Cancellation Act. As long-term institutional investors, SHARE and our clients are taking action to address climate risks and opportunities in our portfolios and seeking ways to shift capital towards the low-carbon transition.  In order to limit the threat of severe, widespread and irreversible impacts, as well as pave the way for a sustainable and prosperous future, there is an urgent need for Ontario to reduce GHG emissions and transition to a low-carbon economy.

October 2018

Investor statement on Supply Chain Modern Slavery Legislation in Canada

A statement from a group of 129 Canadian and global institutional investors with $2.3 trillion assets under management urging the Government of Canada to enact legislation to help identify and eliminate forced labour and child labour in supply chains through effective company due diligence and disclosure.

June 2018


Letter to the Minister of Environment and Climate Change Canada

SHARE, the Interfaith Center on Corporate Responsibility (ICCR) and Ceres Investor Network on Climate Risks and Sustainability (INCR) wrote a joint statement to The Honorable Catherine McKenna MP to express support for strengthening regulations that would reduce the release of methane and certain volatile organic compounds (VOCs) from the upstream oil and gas sector.s.

July 2017

Submission to the Canadian Securities Administrators’ Climate Change Disclosure Project

SHARE and Addenda Capital wrote to the CSA to provide input into their consultation on climate change disclosures. Comments included ways in which investors are using climate-related disclosures as well as what is needed to better assess and mitigate climate-related risks in investment portfolios.

July 2017

Submission to the Ontario Securities Commission’s 2017-18 Draft Statement of Priorities

SHARE wrote to Ontario Securities Commission (OSC) to comment on its annual priorities, asking that it initiate a market-wide consultation on the practicality of requiring issuers to adopt advisory “say on pay” votes.

May 2017

Submission to the House Financial Services Committee

SHARE wrote to the US House Financial Services Committee about the draft legislation for the Financial Choice Act asking the committee to reject the seriously flawed anti-investor provisions. The bill aims to revoke various financial sector reforms introduced under the Dodd Frank act after the 2008 financial crisis.
April 2017


Submission to the Department of Finance Canada – Financial Institutions Divisions

SHARE provided input on the Interim Report, Supporting a Strong and Growing Economy: Positioning Canada’s Financial Sector for the Future. SHARE’s comments focused on opportunities for the Canadian government to use this review to more closely align Canada’s financial sector with sustainability.

November 2016

Submission to the Changing Workplaces Review (CWR)

SHARE provided comments on the Changing Workplaces Review: Special Advisors’ Interim Report and highlighted the importance of greater transparency from companies on their approaches to workplace policies and practices.

October 2016

Submission to Canadian Association of Pension Supervisory Authorities (CAPSA)

SHARE asked the Canadian Association of Pension Supervisory Authorities (CAPSA) to revise its Pension Plan Governance guidelines and related documents to better guide pension administrators on the integration of environmental, social and governance matters in investment decision-making.

June 2016

Comment to the Ontario Securities Commission’s 2016-17 Draft Statement of Priorities

SHARE commented on the Ontario Securities Commission’s (OSC) 2016-17 Draft Statement of Priorities, urging the Commission to consult with stakeholders regarding adoption of regulations requiring issuers to hold an annual “say on pay” vote, to enhance its systemic risk oversight with regard to climate change, to update guidance to issuers on disclosure of environmental considerations, and to consider whether additional diversity measures such as Aboriginal heritage should form part of future board and senior executive diversity disclosure requirements.

May 2016


Alberta Climate Policy Investor Letter

A group of 120 institutional investors representing over C$4.6 trillion in assets under management from Canada, US and Europe that invest in Alberta delivered a joint letter today to Alberta Premier Rachel Notley supporting the government of Alberta’s commitment to update and strengthen its climate policy. The letter is also available in French.

September 2015

Comment on the Ontario Securities Commission’s 2015-16 Draft Statement of Priorities

SHARE urged the Commission to: consult with stakeholders regarding adoption of regulations requiring issuers to hold an annual “say on pay” vote; provide guidance to issuers on disclosure of social considerations; study the potential for mandatory ESG reporting by issuers; extend its investor education activities; study the market-level risks created by climate change; and consider adopting greenhouse gas emissions reporting requirements including requiring energy producers to quantify the carbon price forecasts they use in capital expenditure decisions.

June 2015

Letter to the Federal Minister of Finance on Carbon Pricing

A letter on behalf of fifty-three religious institutional investors with combined assets of more than $2 billion asking that the Government of Canada establish mechanisms to set a clear, reliable and effective price for carbon emissions with the goal of reducing greenhouse gas emissions and limiting catastrophic climate change.

April 2015

CIBC v. Green Supreme Court Decision

The Supreme Court released its ruling in the case of CIBC v Green. SHARE intervened in the case to argue that investors should not be prevented from advancing their claims because of procedural difficulties related to the three-year time limit within which they were required to obtain leave to pursue legal action. The decision of the Supreme Court is a clear indication that legislatures must act to ensure clear rules for shareholder remedy and protect the transparency of capital markets.

December 2015


Submission to Review the Canadian Business Corporations Act

SHARE made a submission to Industry Canada with recommendations to improve the accountability of the board of directors to shareholders and to integrate consideration of social and environmental issues into the board’s responsibilities.

May 2014

Comments on Proposed National Policy 25-201 Guidance for Proxy Advisory Firms

SHARE commented on the CSA’s proposed voluntary guidance for proxy advisory firms. We underscored the principles of responsible investment and encouraged the CSA to focus on investor stewardship as a whole rather than solely on the activities of proxy advisory firms.

June 2014

Draft Regulation to Amend Regulation 58-101 Respecting Disclosure of Corporate Governance Practices

SHARE has made a submission to the securities commissions of Saskatchewan, Manitoba, Quebec, Nova Scotia, New Brunswick, Nfld and Labrador, and Nunavut, who are considering following Ontario’s lead in requiring issuers to disclose their approach to gender diversity on boards and in senior management. We support these jurisdictions adopting an approach consistent with that in Ontario.

August 2014

Second Comment on the Proposed Amendment to Regulation 909 under the Pension Benefits Act

SHARE made a second comment on the proposed amendments to the Ontario Pension Benefits Act regulations to require pension plans to disclose information about environmental, social and governance factors. We endorse the latest amendment which requires pension plans to disclose whether, and, if so, how, environmental, social and governance factors are incorporated into the plan’s investment policies and procedures.

October 2014

Proposed Amendment to Regulation 909 under the Pension Benefits Act

SHARE supported the Ontario government’s proposed amendments to the Pension Benefits Act to mandate ESG disclosure for Ontario pension plans.

June 2014

Submission to the Ontario Securities Commission on Board Diversity

SHARE made a second submission to the Ontario Securities Commission (OSC) in response to its consultation on gender diversity on corporate boards and in senior management. Comments include scope, disclosures, policies and more on proposed Amendments to 58-101F1 of National Instrument 58-101.

April 2014


Submission on Proposed Alberta Business Corporations Act Amendments

Addresses two issues with regard to the right of shareholders to submit proposals for voting on annual meetings: minimum shareholding requirements and word limit for shareholder proposals.
September 2013

Submission to Canadian Securities Administrator on Proxy Voting Infrastructure

SHARE recently submitted comments to the Canadian Securities Administrators (CSA) in relation to Consultation Paper 54-401: Review of the Proxy Voting Infrastructure. SHARE’s view is that the hallmarks of the proxy voting system should be transparency, reliability, and independence from any one organization or type of organization with a vested interest in the outcome.

November 2013

Submission to Cross-Country Extractive Sector Consultations

SHARE made a submission to Minister of International Trade as part of the federal government consultation process on the extractive sector. SHARE made a series of recommendations to clarify the social and environmental responsibilities of Canadian extractive companies and improve the policy framework to integrate social and environmental factors into investment decision-making.

November 2013

Comments to NRCan on Mandatory Transparency Reporting in Extractive Sector

SHARE wrote to NRCan in support of proposals for securities regulators to require mandatory reporting standards in the extractive sector.

August 2013

Submission to Ontario Securities Commission on Board Diversity

SHARE made a submission to the Ontario Securities Commission on their proposal to require TSX listed companies to provide disclosure regarding women on boards and in senior management in Ontario.

October 2013


Comments on CSA Consultation on Potential Regulation of Proxy Advisory Firms

The CSA launched this consultation “to provide a forum for discussion of certain concerns raised about the services provided by proxy advisory firms and their potential impact on Canadian capital markets and to determine if, and how, these concerns should be addressed by Canadian securities regulators.”

August 2012

Comments to Ontario Securities Commission on 2012-13 Statement of Priorities

As in past years, the Ontario Securities Commission (OSC) published a draft of its priorities for the coming year and invited feedback. SHARE took this opportunity to express support for improvements in how shareholder votes impact the election of corporate directors and for enhancements to corporate reports on vote outcomes.

May 2012


Comments on Proposed Amendments to Executive Compensation Disclosure Requirements

Proposed amendments from the CSA aimed primarily at clarifying certain existing disclosure requirements.

February 2011

Comments to OSC on Regulatory Developments on Shareholder Democracy Issues

SHARE’s comments in response to the Ontario Securities Commissions’ request for input on ‘shareholder democracy’ issues. The OSC asked if it should facilitate majority voting for directors and develop regulatory proposals to require the companies it governs to provide their shareholders with a say on pay.

March 2011


Comments on CSA Consultation Regarding the Regulation of Venture Issuers

The securities regulatory authorities in Alberta, British Columbia, Manitoba, New Brunswick, Nova Scotia and Saskatchewan have proposed changes to the regulation of Venture Issuers. The proposals are aimed at establishing an alternative continuous disclosure and governance regime for companies listed on the TSX Venture Exchange.

September 2010

Comments on the CSA’s Proposed Changes to Company Communication with Shareholders

‘Notice and access’ would allow public companies to notify shareholders that information about upcoming meetings and proxy ballots are available online instead of mailing them hardcopies of the documents.

August 2010


Comments on CSA’s Proposed Changes to Corporate Governance Guidelines

SHARE’s submitted response to the Canadian Securities Administrators (CSA) proposed comprehensive overhaul of the regulatory framework governing public company corporate governance policy and disclosure.

April 2009

Feedback on Report to the Joint Expert Panel on Pension Standards

SHARE’s submitted response to the request for feedback on the Report of the Alberta/B.C. Joint Expert Panel on Pension Standards. The feedback focuses on three of the Panel’s recommendations: Investment rules and ESG Factors, ESG Disclosure; and trustee/fiduciary education..

March 2009


Submission to AB-BC Joint Expert Panel on Pension Standards

SHARE’s submission to the Alberta/B.C. Joint Expert Panel on Pension Standards recommending clarification for trustees to consider environmental, social and governance (ESG) factors in their investment decisions.

February 2008

Submission to Finances Quebec Working Paper to Reform the Companies Act

SHARE recommends shareholder proposal mechanisms be put in place in Québec, in response to a call for comment from Finances Québec on the ministry’s Reform Working Paper on the Companies Act.

March 2008


Comments to the CSC on Executive Compensation Disclosure

SHARE provided comments to Canadian Securities Commissions on proposed amendments related to executive compensation disclosure.

June 2007

Regulating Pension Fund Disclosure of ESG Practices

SHARE’s submission to the Ontario Expert Commission on Pensions calling for regulated disclosure of environmental, social and governance (ESG) considerations in order to strengthen pension fund security and sustainability.

October 2007

PRI Joint Letter to SEC on Investor Rights

SHARE joins 46 other PRI signatories in joint letter to the SEC defending investor rights..

June 2007


Submission to National Roundtable on Corporate Social Responsibility

SHARE submission asking the Canadian government to establish clear expectations for both Canadian corporations and investors and to increase the disclosure requirements for companies and publicly regulated pension funds.

November 2006


OSC Submission on ESG Disclosure Requirements

Special memo to the Ontario Securities Commission’s Continuous Disclosure Advisory Committee on social and environmental disclosure requirements for publicly traded companies.

June 2005


Submission to CSA on Corporate Governance and Public Issuers

Submission to the Canadian Securities Administrators on a proposed policy addressing corporate governance practices of public issuers.

May 2004


Comments on Proposed Reforms to the Alberta Business Corporation Act

SHARE’s submission to the Alberta Government on proposed reforms to the Alberta Business Corporation Act. SHARE recommended several reforms to improve corporate governance.

April 2003

Comments to Finance on Reforms to Governance Framework of FIs

Submission to the Department of Finance on proposed reforms to the governance framework of financial institutions.

March 2003

Manitoba Pension Commission Proposed Amendments to Pension Benefits Act

SHARE’s submission to the Manitoba Pension Commission on their devised proposals for amendments to the Pension Benefits Act of Manitoba.

February 2003