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.”1
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.”2

Yet, in its latest Sustainability Report3, 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 Framework4 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.