On November 7, 2024, the Canadian Securities Administrators
("CSA") released CSA Staff Notice 51-365
Continuous Disclosure Review Program Activities for the fiscal
years ended March 31, 2024 and March 31, 2023
("51-365"). 51-365 notes that the CSA
have seen promotional activities by certain issuers leading to
disclosure that is either untrue or unbalanced including disclosure
and promotional campaigns that provide unbalanced or
unsubstantiated material claims about the issuer's business.
Recently, the CSA have noted that such promotional activities have
included greenwashing.
Given the rise of regulation regarding the disclosure of an
issuer's Environmental, Social and Governance practices
("ESG"), such disclosure in continuous
disclosure documents, news releases, website disclosure and
voluntary documents such as sustainability or ESG reports, has
grown rapidly in recent years.
