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These reviews are intended to provide a mechanism forassessing company policies and programs through a racial equity lens and to identify opportunities where organizations can enhance efforts to be more equitable and inclusive.

The report by law firms Covington & Burling LLP and WeirFoulds LLP found TD has numerous initiatives and programs in place on diversity and inclusion and "committed leadership" across the bank.

However, the bank could improve in areas like more centralized, enterprise-level communications about diversity and inclusion work, improved awareness of development opportunities for employees and more consistency in implementing policies.

The report also said 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," the report said.

The racial equity audit didn't go far enough, said Emma Pullman, head of shareholder engagement at the British Columbia General Employees' Union (BCGEU), one of the shareholders that pressed TD to complete the assessment.

It it was impressive and important that TD went ahead with the audit and the report shows numerous worthwhile initiatives, she said, but there were notable deficiencies including limiting the assessment to employment practices, and the lack of data in the report.

"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 noted that both RBC and BMO 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 Citibank, which set a goal to assess the bank's efforts to "help address the racial wealth gap."

TD's audit was largely limited to questions around the bank's efforts to provide a racially equitable and non-discriminatory workplace.

The bank said in an internal letter on the results that it has a longstanding commitment to diversity and inclusion 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.

This report by 好色tvwas first published Dec. 18, 2023.

Companies in this story: (TSX:TD; TSX:RY; TSX:BMO)