ESG Materiality Assessment

In 2021, ATB partnered with a third party to design and build our inaugural materiality assessment, which was used to determine which ESG topics were most important to a broad range of stakeholders. More than 3,000 stakeholders—
clients, community partners, vendors, team members and board members—were consulted.

As a part of the assessment, ATB formed an ESG advisory council consisting of senior leaders from across the organization. The council provided invaluable expertise and insights throughout.

This work will inform our management of stakeholder sentiment, establish which ESG factors are the most material for ATB and show us where we can focus our efforts to improve competitive differentiation, risk mitigation and ATB’s long-term business value.

Evolving ATB’s Disclosure Practice

As stakeholder expectations continue to evolve, so must ATB’s reporting practice. Our goal is to be transparent in disclosing our ESG performance—outcomes and impact, both positive and negative—as we meaningfully engage with ATB stakeholders about the topics that are most important to them.

By promoting understanding of ATB’s overall approach to ESG topics, we can proactively seek opportunities and mitigate risks related to anticipated policy and regulatory changes. Using global sustainability frameworks and standards, such as the GRI, we can demonstrate ATB’s performance on the ESG topics most important to our business and stakeholders. We can also provide greater comparability and benchmarking, within and across industries.

We have also begun to incorporate recommendations from the TCFD into our risk management process. 

There continue to be significant changes that are shaping the sustainability reporting landscape and influencing which metrics organizations use to report on their impacts. We are evaluating these changes and will continue to evolve our approach to effectively and meaningfully communicate our performance on the topics that matter most to our stakeholders.

International Sustainability Standards Board

Along with 40 other organizations, ATB supported a bid to establish the International Financial Reporting Standards (IFRS) Foundation’s newly formed International Sustainability Standards Board (ISSB) in Canada. 

The ISSB’s goal is to create a comprehensive and consolidated set of sustainability reporting standards for organizations to disclose their most important ESG topics—an increasingly critical decision point for investors and clients.

ATB is also engaging with the IFRS Foundation, the Government of Canada and the City of Montreal about the envisioned structure and the arrangements associated with locating the ISSB office in Canada, and we intend to play a role in setting standards. 

Our Definition and Approach

It is important that ATB operates with a foundation of trust among our team members, clients and communities.

At every opportunity, we demonstrate our commitment to ethical business practices with regards to topics such as anti-corruption, anti-bribery and conflicts of interests, which are addressed through ATB’s Code of Conduct and Ethics and our compliance training program. ATB’s Board reviews and approves our Code of Conduct with our Ethics Committee (which includes ATB’s Ethics Officer) overseeing the Code’s compliance. We endeavour to hold ourselves and our partners to the highest standards of ethical conduct and are aligned with the regulatory policies and legal requirements expected of Canadian financial institutions.

Ethics risk is also incorporated into ATB’s Risk Appetite Statement process, in which ATB has a low appetite for ethics risk and deploys significant resources to implement mitigatory processes and controls.

Compliance Training

ATB designs learning modules that equip team members to make decisions that align with regulatory requirements and with the expectations clients have of us as a trusted financial institution. These learning modules are created with stakeholder insight from across the organization.

Compliance training fosters key skills and knowledge across six domain areas: 

• Code of conduct
• Information security
• Anti-money laundering
• Business continuity planning and emergency response
• Privacy
• Occupational health and safety  

Team members are required to complete these courses as soon as they are hired, and annually thereafter. Agents and contractors are required to complete modules identified by our Risk Management teams based on the details of each contractual agreement.

All compliance modules are reviewed by stakeholders and subject matter experts and updated on a yearly basis to ensure the content is both accurate and aligned with the latest regulations. 

Reporting about progress and completion is provided to our Risk partners across business areas, ensuring that ATB’s commitment to ethics and integrity is prioritized across the organization.

ATB Transparency Report 

The Ethics Officer’s transparency report was introduced in May 2021 and has been posted quarterly since then. It contains aggregated information from reports received under our Code of Conduct—such as conflicts of interest and policy violations—with general descriptions and broad discussions of outcomes.

The information is made available to all team members in graph form on ATB’s internal Code of Conduct page. Accompanying commentary from ATB’s Ethics Officer often discusses hypothetical yet relatable situations, guidance on how to act, Code of Conduct insights and how team members can report concerns. Drafts of commentary on transparency reports are presented to the Ethics Committee for review and discussion before they are posted.

The transparency report was introduced because ATB recognizes the importance of building trust in an ethics program. It emphasizes to our team members that ATB takes these topics seriously and that reports are acted on. The ethics program itself is intended to be something team members can talk and ask about.

Ethical Use of Data 

The ethical use of data is an evolving area of thought and subject to a wide variety of considerations. ATB has identified six key principles governing our use of data:

• Fairness: Testing for and understanding bias in data.
• Safety: Data safety (i.e., secure storage) and human safety (i.e., owner consent, protection of physical and mental health).
• Robustness and security: Design that resists interference and remains consistent.
• Transparency: Internal transparency (i.e., documentation) and external transparency (i.e., informed users).
• Explainability: The ability to appropriately explain decisions.
• Accountability: Clear accountabilities for performance and the ability to “pull the plug.”

Within ATB, oversight is provided by the Data Foundations Steering Committee and the AI Model Governance Subcommittee. 

ATB has engaged world-leading organizations to strengthen our practices with respect to the responsible usage of data in AI products and to transition us from tactical to strategic use. With the subcommittee and AI Centre of Excellence, ATB is actively promoting an internal culture that embraces the ethical use of data in AI.

Moving forward, a key activity will be the enhancement of our ethical testing practices, to further increase proficiency in the depth of testing for our data.

Responsible AI Institute 

ATB won the 2021 Corporate Leader Award from the Responsible AI Institute—a non-profit dedicated to promoting responsible and ethical adoption of AI.

The award recognizes ATB’s contributions to developing AI governance tools and our commitment to the ethical use of data.