2024 Diversity
Disclosure Practices

Diversity and leadership at Canadian public companies

Authors: Andrew MacDougall, John M. Valley, Joanna Cameron, and Jessie Armour

Diversity beyond gender: 2024 results for CBCA corporations

Although this year’s data shows almost no change in the representation of visible minorities, Indigenous Peoples or persons with a disability in senior leadership positions, there was one exception. At the executive officer level, the representation of visible minorities increased and, among CBCA companies, there is now on average approximately one executive officer from a visible minority per company.

Director diversity beyond gender

Corporations governed by the Canada Business Corporations Act (CBCA) with publicly traded securities are required to provide diversity disclosure regarding women on the board and senior management consistent with the requirements under Canadian securities laws, as well as corresponding disclosure respecting Indigenous Peoples, members of visible minorities and persons with disabilities. In this chapter, we provide the results of our review of disclosure provided in compliance with the CBCA Requirement.

Our data shows that little has changed for CBCA corporations with respect to the representation of visible minorities, Indigenous Peoples and persons with disabilities on boards compared to last year. For executive officers, our data shows for the first time that there is an average of approximately one executive officer who identifies as a visible minority per reporting CBCA company.

The analysis in this chapter is based on disclosure provided prior to August 1, 2024, by 317 CBCA corporations in compliance with the CBCA Requirement.

Of the 317 CBCA corporations covered by this chapter, 177 (or just over half) are TSX issuers that provided disclosure in compliance with the Diversity Disclosure Requirement at mid-year 2024. There is overlap between the two groups as we include data from CBCA corporations listed on the TSX in our chapters on 2024 diversity disclosure by TSX-listed issuers as well as in this chapter. However, since the CBCA Requirement also applies to public CBCA corporations that are listed on other stock exchanges, including the TSX Venture Exchange, a significant portion of the corporations for which the data for is included in this chapter relates to those smaller issuers.

We recognize that there are a range of terms used to reference the various diversity characteristics referred to in this chapter and elsewhere in this report. Different companies make different choices in this regard. Since our report is based on disclosure made by companies in response to legislated disclosure requirements, we have generally used the same terms as the legislation where applicable to avoid confusion. However, we have chosen to use the term “Indigenous Peoples” to include references to “Indians”, “Inuit” and “Métis” peoples covered by the term “Aboriginal peoples” in the legislation referenced by the CBCA Requirement.

Board representation of visible minorities, Indigenous peoples and persons with disabilities

	Members of visible minorities			Indigenous Peoples			Persons with disabilities
	2024	2023	2022	2024	2023	2022	2024	2023	2022
Percentage of population	27%1			5%1			27% (Ages 15 and older)2
Number of board positions3	185	191	162	18	17	17	12	12	10
Percentage of board positions3	10.2%	10.2%	8.3%	1%	0.9%	0.9%	0.7%	0.7%	0.6%
Number of companies with at least one director from the applicable designated group3	111	114	102	16	16	16	11	11	10
Average number per board3	0.76	0.75	0.60	0.08	0.07	0.06	0.05	0.05	0.04
Percentage of companies with director targets for members of the applicable designated group	2.8%	2.5%	2.1%	<1.0%	<1.0%	<1.0%	0%	0%	0%

1. Source: Statistics Canada, Census of Population, 2021.
2. Source: Statistics Canada, Canadian Survey on Disability, 2022.
3. Based on the number of companies disclosing the number of directors who are from the applicable designated group. In 2024, there were 242 such companies disclosing the number of directors who are visible minorities, 237 companies disclosing the number of directors who are Indigenous Peoples and 229 companies disclosing the number of directors who are persons with disabilities.

We also note that approximately 14% of those CBCA companies providing full or partial disclosure reported that they had directors who were members of a designated group, but did not specify which group. The proportion of companies taking this approach was broadly consistent with last year and, like last year, when disclosing designated group diversity some companies included women as part of their collective designated group disclosure, while others did not, and some included LGBTQ2S+ members. Since these companies did not provide a breakdown by designated group, we are not able to reflect these responses in the table above. As a result, there is an under-reporting of the number and percentage of directors as well as the number of companies with targets for those groups.

For purposes of the CBCA Requirement, the term “visible minorities” is defined to mean persons, other than Indigenous Peoples, who are non-Caucasian in race or non-white in colour. Statistics Canada states that the visible minority population consists mainly of the following groups: South Asian, Chinese, Black, Filipino, Latin American, Arab, Southeast Asian, West Asian, Korean and Japanese. According to data from Statistics Canada, in 2021 approximately 26.5% of Canada’s population were visible minorities. However, based on the disclosure provided by 242 CBCA corporations that disclosed the number of board members who are visible minorities, only 10.2% of directors are visible minorities. CBCA corporations averaged only 0.76 visible minority directors per board in 2024.

The term “Aboriginal peoples” is defined under the CBCA Requirement to mean persons who are “Indians”, “Inuit” or “Métis” (all as defined in the applicable statutes). According to data from Statistics Canada, in 2021 approximately 5% of Canada’s population were Indigenous Peoples. The number of board positions held by Indigenous directors was flat compared to last year, while the number of board positions held by persons with disabilities recorded no change.

On a combined basis, directors who identified as being from a visible minority or as Indigenous collectively held 11.2% of the board seats among those CBCA companies that provided full or partial disclosure. This compares favourably to Australia on racial or ethnic diversity, but lags both the U.S. and the U.K.

To make progress on diversity beyond gender, public company boards will need to change their approach to identifying and appointing directors from these designated groups. The proportion of CBCA corporations that disclosed that their written board diversity policy does relate to these designated groups is significant, but lags the proportion with diversity policies that relate to women directors.

Targets for director diversity beyond gender

It remains the case that very few CBCA corporations have adopted targets for directors from designated groups other than women. Examples of issuers that have adopted targets for visible minority directors include Enbridge Inc., George Weston Limited, Golden Activewear Inc. and Loblaw Companies Limited, while Cameco has identified a target for Indigenous representation. We did not identify any CBCA corporations that disclosed having adopted a target for persons with disabilities.

We identified a further 19 CBCA corporations that adopted collective targets for diversity. A few have established targets for the designated groups collectively with separate targets for women directors, while others have adopted an aggregate target for all designated groups. In some cases, the collective target includes LGBTQ2S+ directors. A few have adopted a collective diversity target to be applied to the board and executive officers as a group. As noted above, issuers who adopted collective targets for diversity are not included in our analysis.

Executive officers who are members of visible minorities, Indigenous Peoples and persons with disabilities

	Members of visible minorities			Indigenous Peoples			Persons with disabilities
	2024	2023	2022	2024	2023	2022	2024	2023	2022
Number of companies with at least one executive officer from the applicable designated group1	101	100	99	5	5	9	13	14	14
Average number of executive officers per company for the applicable designated group	0.96	0.88	0.68	0.02	0.09	0.03	0.08	0.03	0.06

Although a substantial portion of companies that disclose whether they consider the representation of each of these designated groups when considering executive officer appointments indicate that they do so, there continues to be significant room for improvement given the stagnant trend in the number of companies disclosing that they have at least one executive officer from the applicable designated group in the table above.

1. Based on the number of companies disclosing the number of executive officers who are from the applicable designated group. In 2024, there were 229 such companies disclosing the number of executive officers who are visible minorities, 222 companies disclosing the number of executive officers who are Indigenous Peoples and 223 companies disclosing the number of executive officers who are persons with disabilities
   

Targets for executive officer diversity beyond gender

Consistent with the results reported last year, the adoption of targets for executive officer diversity based on characteristics beyond gender remains very rare. A limited number of companies — including Enbridge Inc. — have adopted targets for executive officers from visible minorities. We did not identify any CBCA companies that disclosed that they had adopted targets for executive officers who are Indigenous or persons with a disability. A limited group — including CAE Inc., Definity Financial Corporation, Eldorado Gold Corporation, G Mining Ventures Corp., Intact Financial Corporation and Triple Flag Precious Metals Corp. — disclosed targets for representation of designated groups collectively in executive officer positions in 2024. In some cases, the collective target includes LGBTQ2S+ executive officers.

Representation of women in CBCA board and executive officer roles

Consistent with previous years’ results, on most metrics, corporations subject to the CBCA Requirement disclosed results that were below the average results for the TSX-listed issuers subject to the Diversity Disclosure Requirement. The lower results are attributable to the fact that the CBCA Requirement also applies to smaller corporations than the Diversity Disclosure Requirement does.

Women directors of CBCA corporations

	Number (%) of board seats	Average number per board	Average % per board	Written policy relating to women	Target for directors
2024	549 (27.0%)	2.00	24.0%	136 (46.3%)	87 (29.8%)
2023	549 (25.8%)	1.89	23.1%	144 (46.3%)	90 (31.8%)

Of the 2,031 board seats at the 274 companies disclosing the number of women directors on their board, 549 (27.0%) are filled by women. This represents an increase of 1.2 percentage points from mid-year 2023. The percentage of women directors at CBCA companies listed on the TSX remains lower than the 30% of total board seats held by women at all companies listed on the TSX and subject to the Diversity Disclosure Requirement that disclosed the number of women directors on their board. For CBCA companies listed on the TSX, women held 31.8% of the board seats. But for CBCA companies that are not listed on the TSX, women held only 15.0% of the board seats, which substantially lowered the percentage for CBCA issuers as a group.

CBCA companies nominated women for election to newly available board seats at a rate (31.3%) far below the rate for all TSX-listed companies subject to the Diversity Disclosure Requirement (40.4%).

All-male boards made up approximately one-fifth (22.3% or 61 corporations) of the CBCA corporation boards. Of the companies that provided disclosure in response to the CBCA Requirement, 213 corporations, or 77.7%, disclosed they had at least one woman director. Among CBCA corporations providing diversity disclosure, 66, or 24.1%, reported having one woman director and 147, or approximately 53.6%, reported having more than one woman on their board. There were 11 disclosing CBCA corporations (8.0%) that reported having 50% or more women directors. Compared to mid-year 2023, the number of all-male boards remained stagnant while the number of boards with 50% or more women directors increased slightly.

Women executive officers of CBCA corporations

	Average number of executive officers	Average % of executive officers	Number of companies considering women in executive officer appointments	Target for women executive officers
2024	1.80	19.7%	248 (88.3%)	30 (10.9%)
2023	1.72	19.7%	235 (87.4%)	29 (10.4%)

The story is the same at the executive officer level, with CBCA corporations reporting results with comparable trend lines to — but with lower results than — the TSX-listed issuers as a group.

Women CEOs, board chairs and committee chairs of CBCA corporations

Of the companies subject to the CBCA Requirement and providing full or partial disclosure in response to those requirements, 16 (approximately 5%) had a woman CEO (a slightly higher rate than the TSX-listed companies as a whole this year), 23 (approximately 7.3%) had a woman board chair and 150 (approximately 47.3%) had at least one woman committee chair.

As noted elsewhere in this report, since the number of committees varies and the identity of committee chairs is not required disclosure, in some instances the information was not readily obtainable.

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• Best practices: who has achieved gender parity, voluntary disclosure of underrepresented groups and how to increase diversity