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Shareholders at Suncor and Enbridge to vote on key net zero metrics

Capex and scope 3 in the spotlight

Shareholders at Suncor and Enbridge will vote on proposals filed by Investors for Paris Compliance (I4PC) regarding their net zero plans. Both resolutions focus on key metrics that indicate whether the companies are on track.

The Suncor resolution asks the company for greater disclosure regarding its commitment to devote 10 percent of its capital expenditures to investments that advance its low-carbon offerings. No rationale has been provided for this number, nor details on how it will be spent and how it adds up to meeting the company’s net zero target.

The Enbridge resolution asks the company to annually disclose its scope 3 emissions using internationally-accepted definitions and in absolute terms. Currently the company uses an incomplete definition of its scope 3 emissions that masks their scale and their growth given Enbridge is expanding fossil fuel infrastructure.

“Through these key metrics investors will get better clarity on whether these companies are committed to delivering on their net zero commitments,” said Duncan Kenyon, Director of Corporate Engagement at I4PC. “It’s no longer “ok” for these companies just to say they’re committed to net zero without following that up with actions like accurate emissions reporting and meaningful low carbon capital expenditures.” 

The resolutions will be voted on when the companies release their proxy circulars in the lead up to their annual general meetings in early May.

I4PC is a shareholder advocacy organization that works to hold Canadian publicly-listed companies accountable to their net zero commitments. It conducts research, engagement, and where appropriate works with investors to file shareholder proposals. For more on I4PC visit


For more information contact Duncan Kenyon at

Included are the resolutions as submitted

Suncor Resolution


Shareholders request that Suncor produce a report, at reasonable cost and omitting proprietary information, outlining how its capital expenditure plans align with its 2030 emissions reductions target and its 2050 net zero pledge.

Supporting Statement:

Suncor has a 2030 emissions reduction target of 10 Mt CO2e and a 2050 net zero target. Suncor indicates it is committing 10% of its annual capital budget over the medium term to “investments that advance our low-carbon energy offerings.” Suncor does not provide a rationale for this level of investment and how it aligns with its targets nor disclose specific planned investments and associated emissions reductions.

Similarly, Suncor does not disclose emissions expectations associated with the other 90% of its planned capital budget and whether these investments take the company further from its climate targets. Note that there is no baseline established for Suncor’s 2030 target, nor are Scope 3 emissions included in it, meaning that the vast majority of Suncor’s capital expenditures may contribute towards emissions expansion.

The International Energy Agency projects a three-quarters decline in oil demand in its net zero scenario and Canada’s Energy Regulator predicts oil production in Canada will peak shortly after 2030. These reductions are part of the net zero transition that is an existential threat to unprepared oil companies and is particularly acute for Suncor and other oil sands producers producing a higher cost and higher emitting source of oil than most competitors.

Considering this threat, it is critical that investors are given more clarity on how Suncor’s capital expenditure plans align with its 2030 emissions reductions target and its 2050 net zero pledge

Suncor’s climate plans rely heavily on carbon capture utilization and storage (CCUS) for meeting its climate goals. Yet the company does not disclose spending plans for CCUS, including overall cost and projections of cost-per-barrel over the medium and long term.

Climate Action 100+, a global investor initiative representing US$68 trillion in assets under management, found in its October 2022 Assessment that Suncor “does not meet any criteria” for capital alignment, medium term targets or decarbonization strategy.”

To address investor uncertainty and to manage business risk, we urge shareholders to vote FOR this proposal.

Enbridge Resolution


Shareholders request that Enbridge annually disclose all of its scope 3 emissions using accepted definitions and in absolute terms.

Supporting Statement:

The Greenhouse Gas Protocol defines scope 3 emissions as:

“All indirect emissions (not included in scope 2) that occur in the value chain of the reporting company, including both upstream and downstream emissions.”

If a company’s financial viability is dependent on scope 3 emissions being released – as is the case with Enbridge – then it is critical that investors have a full and complete picture of these emissions.

CDP is clear that midstream companies like Enbridge take responsibility for all scope 3 emissions:

“While O&G products are not directly sold by these companies, the emissions from their end use still generates Scope 3 emissions that arise as “a consequence of an organization’s operations and activities.”

Yet, in its latest Sustainability Report, Enbridge states that:

“Scope 3 GHG emissions result from our utility customers’ natural gas use, our employee business air travel, and electricity grid transmission and distribution loss (grid loss).”

This does not align with the internationally accepted Greenhouse Gas Protocol scope 3 definition because Enbridge misses both the upstream and downstream emissions from most of the products that it derives revenue from.

Enbridge does report a metric for the upstream emissions intensity “of the energy we deliver.” But, Enbridge does not take responsibility for these emissions as its scope 3 emissions. It also does not account for the downstream emissions of the energy and does not report the numbers in absolute terms so that investors can see their scale.

Enbridge claims a “contribution to avoidance of third-party emissions” via various green projects without also disclosing the other side of the ledger – the projects it is building that expand fossil fuel delivery that thereby expand scope 3 emissions.

Enbridge takes the same approach to scope 3 emissions in its Sustainability-Linked Bond Framework that it published as part of bond issuances, saying “we are doing our part to reduce scope 3 emissions,” while again using an incomplete definition of scope 3 emissions and not disclosing increased scope 3 emissions from expansion of fossil fuel delivery.

Investors in Enbridge equities and bonds are thereby left uninformed regarding the true nature of the company’s scope 3 emissions and the implications both for Enbridge’s role in the energy transition and for meeting its stated net zero by 2050 commitment.

To address this uncertainty, investors request a full and transparent annual accounting in absolute emissions terms of all of Enbridge’s scope 3 emissions using accepted definitions.

We respectfully request that shareholders vote FOR this proposal.








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