The Institute of Neurodiversity, Canada (ION Canada) and the Group for Autism, Insurance, Investment and Neurodiversity (GAIN) have set a new benchmark in financial services sustainability reporting with their collaborative submission on the GRI Financial Sector Standards for Banking, Capital Markets and Insurance. While the Standards gather diverse stakeholder feedback on critical areas such as climate-related financial risks, biodiversity impacts, financial crime prevention, and human rights due diligence, the ION Canada/GAIN submission introduces a wholly new dimension: neurodiversity.
Unlike other contributions that focus primarily on traditional human rights or labour rights, ION Canada/GAIN systematically integrates neurodiversity into both workforce inclusion and capital allocation. Internally, the submission addresses non-discrimination in hiring, promotion, and workplace accommodations for neurodivergent employees, alongside occupational health and safety considerations. Externally, it calls for equitable access to capital for neurodivergent entrepreneurs, non-discriminatory investment criteria, and targeted programmes for underserved populations, ensuring that neurodiverse talent is recognised as an economic opportunity rather than only a social justice concern.
The submission submitted by Kim Shah, ION Canada Lead and Marilyn Swinney, GAIN’s Investment Chair goes further by offering actionable, line-by-line recommendations to refine the GRI draft. For example, it explicitly proposes including “neurodiversity” and “disability” in non-discrimination clauses and investment selection criteria, alongside guidance on addressing attitudinal barriers within institutions. This dual focus of internal workforce and external capital allocation sets the ION/GAIN submission apart from others, providing a comprehensive framework for financial institutions to embed neurodiversity into their sustainability reporting.
ION/GAIN also demonstrates a sophisticated understanding of identity complexities. The submission acknowledges that many neurodivergent individuals may meet disability definitions under the laws depending on the jurisdiction, even if they do not self-identify as disabled. It recognises hidden neurodivergence among entrepreneurs and emphasises that inclusive policies must work for both identified and non-identified neurodivergent individuals.
Cultural assumptions and systemic barriers are a recurring theme. ION Canada/GAIN highlights how traditional workplace norms, communication styles, and investment practices can inadvertently exclude neurodivergent individuals. By addressing these attitudinal barriers, the submission moves beyond compliance, advocating for a genuine shift in organisational culture to foster inclusion, innovation, and economic impact.
Kim Shah (She/Her), ION Canada Lead shares, “True financial inclusion means recognizing that neurodivergent individuals don’t just deserve access to capital—they deserve ownership, agency, and dignity in the economic systems that shape their lives. When we move beyond accommodations to structural transformation, we unlock not only innovation and competitive advantage, but markets built on cooperative principles where cognitive diversity becomes a foundation for shared prosperity.”
Comparatively, another leading submission focus on distinct aspects of social and human factors, Accountability Counsel addresses Indigenous rights and community impacts. ION Canada/GAIN is unique in its pioneering integration of neurodiversity across both the workforce and capital markets, connecting cognitive diversity to innovation, financial inclusion, and broader sustainability goals.
As research increasingly highlights the prevalence of neurodivergent traits among entrepreneurs and innovators, alongside systemic barriers to capital access, the ION Canada/GAIN submission positions neurodiversity as a critical dimension for financial institutions to consider. By bridging social justice, economic opportunity, and innovation, it provides a roadmap for organisations to report on their systemic economic and social impacts more comprehensively.
ION Canada and GAIN’s contribution marks a landmark moment in sustainability reporting, ensuring that financial institutions not only account for environmental and financial risks but also recognise the transformative potential of neurodiverse talent in shaping inclusive, resilient, and innovative markets.
