The following letter was sent to the Competition Bureau.

We are writing in regards to the Request For Information (RFI) the Competition Bureau opened on May 1, 2023 about the proposed acquisition of HSBC Bank of Canada by RBC. This transaction is an issue the undersigned groups are paying close attention to, and we urge the Bureau to reject the acquisition after considering the consequences for efforts to mitigate climate change and the availability of sustainable financial options for consumers.

We applaud recent moves by the Competition Bureau to address the issues of misleading climate and environmental claims in advertising, aka greenwashing. Commissioner Boswell recently stated the “Bureau’s job is to protect the integrity of the marketplace, and that includes consumer confidence in the green economy.” The three current investigations the Bureau has opened relating to deceptive green marketing practices – including on RBC – are proof of this priority.

So while your RFI consultation rightly centres on issues of personal and business financial services in Canada’s highly concentrated banking sector, we believe you are missing a fundamental concern with this proposed transaction that can’t be overlooked.

RBC has a significant negative impact on our climate due to their ongoing financing of high emitting companies. RBC has financed over C$340 B in fossil fuels since the Paris Climate Agreement was signed, and in 2022 became the world’s #1 financial backer of fossil fuels. RBC has set only “emissions intensity” targets for 2030, which will allow its total financed emissions to rise. When challenged on its climate record it touts billions set aside for “sustainable finance,” but RBC deemed a $1B Enbridge oil sands pipeline loan sustainable, and a 2023 report shows RBC puts $99 of its energy finance into fossil fuels for every $1 in renewable energy.

RBC’s track record is relevant in comparison to that of HSBC Canada, a bank which has taken action to deliver on its sustainability commitments. HSBC helped issue Canada’s first green bond, had many corporate clients who valued sustainability, and consistently ranked higher than RBC in Corporate Knights Corporate Citizenship rankings. In 2022, HSBC announced a precedent setting policy to stop financing new oil and gas projects, which, while imperfect, was welcomed by UK NGOs. Importantly for your consideration, RBC had that climate policy exempted from HSBC Canada as a condition for the takeover in question. In 2022 HSBC’s global fossil fuel financing went down, and will continue to do so based on commitments made at the time, while RBC’s went up, making RBC the top global banker of fossil fuels.

Despite claims to be Net Zero by 2050 and to support clients in the energy transition, RBC’s business practices show it has no intention of cutting its financing of fossil fuels. Both the UN and International Energy Agency agree we must cut our climate emissions in half by 2030, and that there is no room in a Net Zero 2050 scenario for any new fossil fuel development. The UN Secretary General states “we must have zero tolerance for net-zero greenwashing.”

If RBC takes over the greener HSBC Canada it will remove sustainable choices from the marketplace. In a world where consumers and citizens increasingly make decisions based upon the climate impact of the products and services they consume, the loss of competitive pressure to improve climate and environmental performance in financial services is a growing problem.

Further, the loss of a competitor moving to phase down its support for fossil fuels to one that is increasing it will serve to further consolidate Canadian investment into an area at risk of becoming stranded, worsening the level of climate risk in our national economy.

There are numerous other reasons to reject this proposed transaction due to its negative impacts on mortgage rates, affordable housing and cost of living. RBC has also demonstrated significant cases of mistreatment of Indigenous Peoples and lacks meaningful policies to address the Free, Prior, and Informed Consent of Indigenous Peoples.

Commissioner Boswell has publicly stated that “climate change may be the greatest market failure we have faced.” We therefore urge you to consider the impacts of this proposed acquisition on diminished competitive pressure on green financial choices and increased climate risk, and to reject the proposed acquisition of HSBC Canada by RBC.


  • Environmental Defence Canada
  • Stand.Earth
  • LeadNow
  • Climate Action Network Canada
  • Banking on a Better Future
  • Friends of the Earth Canada
  • For Our Kids
  • Re_Generation
  • Canada
  • Coalition Sortons la Caisse du Carbone
  • Decolonial Solidarity
  • Gidim’ten Checkpoint
  • West Coast Environmental Law
  • Shift: Action for Pension Health and Planet Wealth

Representing over 1,325,000 Canadian supporters 

The above letter was delivered to the head of the Competition Bureau, as well as submitted to the Minister of Finance and Minister for Climate Change and Environment on May 25, 2023.

In a new campaign launched today, national environmental organization Environmental Defence included RBC’s CEO Dave McKay on their list of the top people most responsible for blocking progress on solving the climate crisis.

What do the CEO of Imperial Oil, the head of RBC bank and the head of Big Oil’s biggest lobby association, the Canadian Association of Petroleum Producers, all have in common?

They’re all committed to using their power to block climate action in order to profit personally from more oil and gas production. And they’re preventing efforts to build a healthy, equitable world beyond fossil fuels.

That makes them three of Canada’s top ‘climate villains’.

That’s why we’ve included them in our brand-new campaign that names and shames the key players in the fossil fuel industry who are guilty of fueling climate chaos and the tactics they use to greenwash and misinform us all.

The website puts the “focus on key individuals – by pulling back the curtain on seven of the most influential players behind Canada’s oil and gas industry who are truly to blame for the climate crisis and revealing the strategies they employ.”

In adding a bank CEO to a list filled with oil industry leaders and PR hacks, it says:

The list also includes Dave McKay, the CEO of RBC (aka Mr. Money Bags). In 2022, RBC provided more financing to oil and gas companies than any other bank in the world. RBC talks a big game about climate action and “net zero” but since the Paris Agreement was signed in 2015, RBC has poured nearly $350 billion dollars into climate-destroying fossil fuel companies.

Check out the website and meet the other climate villains at

Chatelaine calls itself as “Canada’s largest women’s brand” and its lifestyle magazine has been a stalwart of the Canadian media industry since the 1920’s. That’s why it’s a big deal to see them bring the message about RBC’s harmful investments in fossil fuels and projects that harm Indigenous people’s to hundreds of thousands of people.

In an article published today called “I switched to a credit union to help fight climate change” the authour says:

It turns out that Canada’s “big five” banks—that includes RBC as well as TD, Scotiabank, BMO and CIBC, in declining order of how much money they make—are big investors in fossil fuel projects. In 2022, out of all the world’s banks, RBC was the largest investor in fossil fuels on Earth.

If, like me, you believe we need to transition off fossil fuels ASAP to avoid the worst effects of climate change—which, let’s be honest, are already getting bad—these numbers might not make a lot of sense. Yes, some of that money helps create jobs and goes into local economies. But at what cost?

She was also savvy in response to RBC’s self-interested greeenwash:

To get their perspective for this article, I got in touch with RBC’s communications department and asked if I could speak with someone about their policies on fossil fuel investment. Instead, I received a reply to my questions via an email. The gist: Don’t worry, climate change is a big deal but RBC is on it, and while we’re aiming for net-zero eventually, and we’re investing in clean energy, we need fossil fuels to fill the gap.

“The transition will not happen overnight—without risking significant harm and disruption to lives and livelihoods.”

I mean, sure. I agree that cutting fossil fuel use down to zero tomorrow would cause chaos. But if you ask me, RBC really seems to be trying to have its cake and eat it too…thanks to our rampant and still-growing fossil fuel use, climate change is already causing significant harm and disruption to lives and livelihoods—and they’re costly, too.

She also covered the importance of the Indigenous-led divestment movement and their demands for RBC and other banks to recognize the Free, Prior and Informed Consent (FPIC) of Indigenous Peoples to this work:

Free, prior and informed consent sounds like a small ask, but time is money, after all, and we’re talking about a business culture that loves the phrase “it’s better to get forgiveness than permission.” The trouble is, forgiveness is one thing, but a damaged and polluted ecosystem is another. If you break someone’s car, or computer, or couch, you can replace it. You can’t say the same for a river or a forest.

What Gray and her colleagues at ICA are pushing for is Indigenous divestment, which she defines as very similar to fossil fuel divestment. “Environmental protections are only a small part of the issue,” she says. “It’s one thing to build a park instead of a mine. It’s another thing to not criminalize Indigenous people for being on our own territories, and to not displace Indigenous peoples for protecting our waters and lands against a pipeline without opportunity.”

Read the full article on the Chatelaine website.