Our governance approach to the environmental, social and governance (ESG) issues reflected in this report is integrated with our approach to corporate governance and business strategy, ensuring we have the right combination of strong oversight and operational accountability. This work includes identifying, monitoring and implementing initiatives to mitigate risk, deliver on commitments and report on key metrics and progress.
See an overview of our governance for ESG strategy, execution and factors.
Key Governance Bodies
Responsibilities Include
- Overseeing the ethical, legal and social conduct of Empire
- Overseeing the development of corporate governance policies, principles and guidelines
- Developing and monitoring compliance with Empire’s Code of Business Conduct and Ethics for directors, officers and teammates, including ethics line reporting
- Overseeing stewardship of Empire, including the strategic planning process, approval of the strategic plan, identification of principal risks and implementation of systems to manage these risks
- Encouraging a culture of ethical conduct by appointing officers of high integrity and monitoring their performance
Responsibilities Include
- Assisting the board in fulfilling its responsibilities as they relate to corporate governance and social responsibility
- Receiving and reviewing periodic reports on Empire’s policies, activities, and progress pertaining to social responsibility initiatives, including sustainability, as well as updates on regulatory and general market developments relating to such matters
Responsibilities Include
- Assisting the board with oversight of policies and practices relating to integrity of financial and regulatory reporting and the enterprise risk management (ERM) framework and process
- Reviewing the applicable metrics and information contained in the Sustainable Business Report, including climate-related data
- Reviewing the status and adequacy of Empire’s efforts to ensure our businesses are conducted and facilities are operating in an ethical, legally compliant and socially responsible way
- Receiving quarterly reports on ethics line reporting matters
Responsibilities Include
- Assisting the board in oversight of human resources strategy, policies and programs
- Monitoring, reviewing and providing guidance on people development initiatives including talent management and employment diversity
- Receiving reports on human resources related matters received through the ethics and DE&I reporting line
- Fulfilling the board’s responsibility for occupational health and safety
Responsibilities Include
- Leading business and sustainability strategy development and review
- Overseeing leadership committees and operational teams responsible for implementing sustainability strategy
Responsibilities Include
- Building and driving accountability, including ensuring sustainability key performance indicators (KPIs) are integrated with functional teams
- Providing strategic direction on sustainability activities and reporting
- Reviewing sustainability performance
- Providing updates on corporate sustainability-related commitments, reporting and emerging topics
- Aligning on sustainability gaps and opportunities to address across functional teams
Code of Conduct and Policies
Our Code of Business Conduct and Ethics provides guidance to teammates and reaffirms our commitment to the highest possible personal and corporate standards of business conduct. Directors and teammates are required to acknowledge and agree to the code on a regular basis, and we maintain an anonymous and confidential whistleblowing hotline.
The policies that guide and govern our actions include:
Executive Compensation
Our executive compensation program is designed to attract, motivate and retain a highly skilled executive team, directly aligning compensation to personal and corporate performance objectives—including ESG-related areas. In fiscal 2025, we continued to use DE&I KPIs to build broad leadership accountability for DE&I across all teams and banners. For leaders and teammates eligible for our profit-sharing plan, we use KPIs in support of our Climate Action Plan targets and food waste reduction commitment.


Enterprise Risk Management
As part of our Enterprise Risk Management process, every year we identify, assess, manage and report on key risks to the organization and our objectives. These risks are reported in Empire’s Annual Report, the Q4 F25 MD&A and F25 Annual Information Form.
Climate Risk
We recognize the potential adverse impact that climate change poses to our business. The comprehensive analysis we have undertaken to understand physical and transitional risks related to our business aligns us with the recommendations of the Task Force on Climate-Related Financial Disclosures. It also paves the way for reporting aligned with the recently released integrated Climate-related Disclosure Standards (CSDS 2) developed by the Canadian Sustainability Standards Board (CSSB). CSDS 2 largely adopts the International Sustainability Standards Board (ISSB) standards with minor modifications for the Canadian market. These standards remain voluntary for all Canadian companies, as of this report’s publication. We will continue to update our risk assessment and reporting in line with evolving standards and requirements.
Learn more in our Climate Action section and TCFD-Aligned Report.