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Responding department: Corporate Social Responsibility

Stock Exchange Symbol: (BAC:US)

Does your company have a publicly available commitment to respect human rights?

Yes, stand-alone human rights policy [link]

Vendor Code of Conduct [link]

How are human rights governed in your company?

In 2014, we established a new Global CSR Committee reporting to the CEO. The Committee provides a forum for dialogue around emerging CSR issues, including concerns raised by advocates, regulators and influencers. Having the Committee reporting to the CEO ensures that CSR continues to be integrated into our core business decisions and that CSR-related issues are considered and debated at the highest levels within our company, including the Corporate Governance Committee of the Board. Made up of senior leaders from business and support groups across the company, our Global Chief Strategy and Marketing Officer chairs the Global CSR Committee and serves as its liaison to the Board. The Committee will meet quarterly and report out at least annually to the Corporate Governance Committee of the board of directors. The Committee’s membership includes representatives from the company’s business and operations.

Two subcommittees have been established: The Community Reinvestment Act (“CRA”) Subcommittee oversees the Company’s lending, investment and service activities to low- and moderate-income individuals and areas, and the Company’s CRA initiatives, goals, performance, and regulatory evaluations and ratings.

The Global Environmental Operations subcommittee oversees the Company’s environmental operational goals and is responsible for developing strategy and implementing initiatives to ensure successful achievement of these goals. The CSR Committee will be an integration point for various internal working groups with responsibility for environmental and social issues. Those groups will report to the Committee. Examples of these working groups are the new Global Environmental Operations Group, the Low-Carbon Banking Group, and the GWIM Environmental/Social/Governance Council.

How are human rights managed within your company?

Bank of America has policies to prevent the illegal use of our products and services, including abuse that may result in human rights violations. These policies include a rigorous Customer Due Diligence process, compliance with U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act, as well as anti-money laundering controls. All employees are required to complete annual training on these subjects, as well as acknowledge our Code of Conduct.

We have endorsed a number of international charters, principles and initiatives that address social and environmental issues,including the United Nations Principles for Responsible Investment, the Equator Principles, Carbon Principles, and CERES Principles. We also maintain policies that address social and environmental issues, including a Developing Country Lending Policy, which ensures that we consider the purpose of the transaction and the impact on the local population. Our environmental and social guidelines are reviewed as a part of our internal audit process, which evaluates our adherence to all policies in place within each of our lines of business. Bank of America strives to work with vendors whose policies and practices regarding human rights are consistent with our own. We have set out clear expectations for our vendors in their management of human rights and other key areas in the bank’s Vendor Code of Conduct.

What is the company’s approach to the engagement of stakeholders (including workers, and local communities impacted by the company’s activities), on human rights issues?

We also maintain policies that address social and environmental issues, including a Developing Country Lending Policy, which ensures that we consider the purpose of the transaction and the impact on the local population.

Priority human rights issues: What are some of the priority human rights issues for your company?

The company selected the following from a check list:

  • Workplace diversity / non-discrimination
  • Forced labour and human trafficking
  • (including in supply chains)
  • Access to water  
  • Housing
  • Product misuse

How are human rights commitments and information about how the company addresses its human rights impacts communicated, internally and externally?

Our policy is available publicly on our website:

[link]

Which external and collaborative human rights initiatives does your company participate in, and what is the nature of your involvement?

We have endorsed a number of international charters, principles and initiatives that address social and environmental issues, including the United Nations Principles for Responsible Investment, the Equator Principles, Carbon Principles, nd CERES Principles.