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TD Asset Management (TDAM)

PRI reporting framework 2020

Export Public Responses

You are in Strategy and Governance » Investment policy

Investment policy

SG 01. RI policy and coverage

New selection options have been added to this indicator. Please review your prefilled responses carefully.

01.1. Indicate if you have an investment policy that covers your responsible investment approach.

01.2. Indicate the components/types and coverage of your policy.

Select all that apply

Policy components/types

Coverage by AUM

01.3. Indicate if the investment policy covers any of the following

Other description (1) Collaboration

01.4. Describe your organisation’s investment principles and overall investment strategy, interpretation of fiduciary (or equivalent) duties,and how they consider ESG factors and real economy impact.

We are committed to applying new investment thinking to address our clients' most important challenges. We use a collaborative team based approach, emphasizing quality investing and employ a comprehensive risk management discipline.

Given the focus on quality investing and prudent risk management, ESG is used to supplement traditional investment analysis by introducing a new framework to identify and analyze risks that are often not found in accounting statements, market data and management communication.

Real economic impact is considered when it is consistent with the mandate or can have a material impact on our internal valuation models.



01.5. Provide a brief description of the key elements, any variations or exceptions to your investment policy that covers your responsible investment approach. [Optional]

01.6. Additional information [Optional].


SG 01 CC. Climate risk (Private)

SG 02. Publicly available RI policy or guidance documents


02.1. Indicate which of your investment policy documents (if any) are publicly available. Provide a URL and an attachment of the document.





02.2. Indicate if any of your investment policy components are publicly available. Provide URL and an attachment of the document.

Other description (1) Collaboration

02.3. Additional information [Optional].

SG 03. Conflicts of interest

03.1. Indicate if your organisation has a policy on managing potential conflicts of interest in the investment process.

03.2. Describe your policy on managing potential conflicts of interest in the investment process.

We have a variety of potential conflicts of interest that arise in our business, including from being a wholly owned subsidiary of The Toronto-Dominion Bank. We have implemented policies and procedures to help us identify and address potential conflicts.  We have structured our business so that where possible, potential conflicts are avoided or mitigated.  Where that is not possible, we endeavour to inform our clients of the potential conflicts.  In all respects, we aim to operate our business to ensure that, in all cases, we adhere to our fiduciary duty to act in the best interest of each client account. Our potential conflicts are extensively disclosed in the relevant client disclosure document; the Statement of Policies and Client Relationship Disclosure.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios

04.1. Indicate if your organisation has a process for identifying and managing incidents that occur within investee entities.

04.2. Describe your process on managing incidents

Our investment teams (Portfolio Managers and sector analysts) will start the process as follows:

• Through meetings / conference calls with the portfolio company / sell-side analysts / industry experts, our sector analyst would lead the discovery process to understand the cause of the incidents, what actions have or will be taken and any potential implications from both a financial and non-financial perspective.

• Portfolio Managers are involved through the process and are updated on the analysts' findings, in order to make appropriate investment decisions.