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Jennifer Reynolds is chief executive officer of Women in Capital Markets.

Much debate preceded the implementation of the Ontario Securities Commission's new disclosure requirements regarding women on boards and in senior executive roles in public issuers in Canada. The "comply or explain" approach aimed to ensure that gender diversity in leadership was on the board agenda and to encourage companies to make progress on increasing the proportion of women on their board and in senior management.

While many countries around the globe chose the more heavy-handed approach of quotas, the OSC opted for comply or explain in order to allow companies to develop an individual approach to improving gender diversity in their organization. The question many asked, and continue to debate, is if transparency is enough of a push to Canada's boards to make progress on gender diversity in leadership.

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Simply put, the disclosure requirements ask boards to report on how many directors and executive officers are women, whether they have a written policy for the representation of women on the board, do they consider it in board and executive appointments, and do they have targets for the proportion of women in these roles. If they don't have policies or consider gender representation, explain why not. The goal being that when forced to report on the numbers, boards will feel compelled (and perhaps a little shamed) into developing policies and initiatives to address the lack of female talent at the top.

So does transparency work? While it is still very early days for this disclosure requirement, a recent report by Torys LLP indicates that a large proportion of Corporate Canada did not have any policies or initiatives to advance women into leadership roles in their organization. The study included a review of this year's disclosure of 179 issuers in the S&P/TSX index (71 per cent of the index), and revealed that close to half did not have any policies relating to women on the board. Furthermore, only 13 per cent had adopted any kind of measurable targets.

Based on early results, one could conclude that a significant proportion of Corporate Canada does not want to put this topic on the board agenda or include it in the strategic objectives of the organization. According to the report, the most commonly cited reason for not having a policy on considering gender is that candidates are selected on "merit."

Women have been 50 per cent of the university graduates in Canada for 30 years (62 per cent today). Women also earn 50 per cent of master's degrees in business and administration in Canada. The reality is that women have been abundantly represented in middle management roles for decades, yet that has not translated into increased numbers on executive teams or boards.

The challenge for boards and CEOs today is fixing the "meritocracy" and developing effective policies and initiatives that result in talented women rising into leadership roles, along with talented men.

There is a vast pool of talent for the leadership of our economy that is not being accessed by the leaders of Corporate Canada. Disclosure may provide transparency, but bold leadership on this issue from Canada's corporate directors will be the defining factor in the success or failure of comply or explain in Canada.

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