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Bank of America Global Wealth and Investment Management

PRI reporting framework 2020

You are in Strategy and Governance » Investment policy

Investment policy

SG 01. RI policy and coverage

New selection options have been added to this indicator. Please review your prefilled responses carefully.

01.1. Indicate if you have an investment policy that covers your responsible investment approach.

01.2. Indicate the components/types and coverage of your policy.

Select all that apply

Policy components/types

Coverage by AUM

          BoA Environmental & Social Risk Policy
        

01.3. Indicate if the investment policy covers any of the following

01.4. Describe your organisation’s investment principles and overall investment strategy, interpretation of fiduciary (or equivalent) duties,and how they consider ESG factors and real economy impact.

Our wealth management clients are increasingly interested in the role that environmental, social and governance (ESG) criteria can play in evaluating portfolio risks and long-term investment opportunities. Merrill (formerly Merrill Lynch) or Private Bank (formerly U.S. Trust) have developed an offering that provides our clients access to strategies across multiple asset classes that integrate ESG into their investment approach. We are committed to continuously providing education and thought leadership to advisors, portfolio managers and clients on the benefits of incorporating ESG. As our work in this area progresses, we take the ESRP Framework into consideration. However, we do not require all investment strategies on our platform to incorporate ESG considerations, nor do we apply these considerations to our investment recommendations or decisions or the asset allocation of Merrill or Private Bank clients unless they request us to do so.

01.5. Provide a brief description of the key elements, any variations or exceptions to your investment policy that covers your responsible investment approach. [Optional]

01.6. Additional information [Optional].

          The  Bank of America Corporation (BAC) Environmental and Social Risk Policy (ESRP) Framework provides clarity and transparency around how we approach environmental and social risks, which touch almost every aspect of our business. This ESRP Framework is aligned with our Enterprise Risk Framework, which outlines our approach to risk management and each employee’s responsibilities for risk management. As articulated in our Enterprise Risk Framework, there are seven key risk types that we face as an organization: strategic, credit, market, liquidity, operational, compliance and reputational. Increasingly, environmental and social issues impact many of these risk areas. Our initial lens has been and continues to be our seven key risk types, but our materiality assessments help us to better understand that enterprise risk also includes risks that threaten the safety, human dignity and equal treatment of our employees, clients and the communities where we do business. These broader risks include issues such as climate change and human rights. The BAC ESRP Framework guides our approach to managing material issues.

The submission to the PRI is being made on behalf of those business groups and units within certain subsidiaries of BAC that provide discretionary investment management services, solutions, products and platforms to serve client needs (the “Discretionary Investment Management Business“).  The relevant business groups and units are part of Merrill Lynch, Pierce, Fenner & Smith Incorporated (“MLPF&S”) and Bank of America, N.A. (“BANA”).  Among the discretionary investment management services, solutions, products, and platforms that serve client needs are ESG guidance, ESG thought leadership, strategies that incorporate ESG data, and ESG training, collectively known as our ‘Sustainable and Impact Investing Options’. Our Sustainable and Impact Investing Options are available to all clients in the Discretionary Investment Management Business. The entirety of our Discretionary Investment Management Business, including the Sustainable and Impact Investing Options, are covered by the ESRP Framework as all clients and financial advisors in the Discretionary Investment Management Business have access to our various Sustainable and Impact Investing Options with no additional fee. For avoidance of doubt, (1) the BAC ESRP Framework is not specific to the Discretionary Investment Management Business, but to the entirety of BAC and its affiliates, including business groups and units within MLPF&S and BANA that provide non-discretionary investment management services; and (2) the Discretionary Investment Management Business makes available investment management solutions and products that do not meet the parameters of the ESRP Guidelines.
        

SG 01 CC. Climate risk (Private)


SG 02. Publicly available RI policy or guidance documents

 

02.1. Indicate which of your investment policy documents (if any) are publicly available. Provide a URL and an attachment of the document.

02.2. Indicate if any of your investment policy components are publicly available. Provide URL and an attachment of the document.

02.3. Additional information [Optional].

The Bank of America Corporation (BAC) Environmental and Social Risk Policy (ESRP) Framework provides clarity and transparency around how we approach environmental and social risks, which touch almost every aspect of our business. This ESRP Framework is aligned with our Enterprise Risk Framework, which outlines our approach to risk management and each employee’s responsibilities for risk management. As articulated in our Enterprise Risk Framework, there are seven key risk types that we face as an organization: strategic, credit, market, liquidity, operational, compliance and reputational. Increasingly, environmental and social issues impact many of these risk areas. Our initial lens has been and continues to be our seven key risk types, but our materiality assessments help us to better understand that enterprise risk also includes risks that threaten the safety, human dignity and equal treatment of our employees, clients and the communities where we do business. These broader risks include issues such as climate change and human rights. The BAC ESRP Framework guides our approach to managing material issues.

The submission to the PRI is being made on behalf of those business groups and units within certain subsidiaries of BAC that provide discretionary investment management services, solutions, products and platforms to serve client needs (the “Discretionary Investment Management Business“).  The relevant business groups and units are part of Merrill Lynch, Pierce, Fenner & Smith Incorporated (“MLPF&S”) and Bank of America, N.A. (“BANA”).  Among the discretionary investment management services, solutions, products, and platforms that serve client needs are ESG guidance, ESG thought leadership, strategies that incorporate ESG data, and ESG training, collectively known as our ‘Sustainable and Impact Investing Options’. Our Sustainable and Impact Investing Options are available to all clients in the Discretionary Investment Management Business. The entirety of our Discretionary Investment Management Business, including the Sustainable and Impact Investing Options, are covered by the ESRP Framework as all clients and financial advisors in the Discretionary Investment Management Business have access to our various Sustainable and Impact Investing Options with no additional fee. For avoidance of doubt, (1) the BAC ESRP Framework is not specific to the Discretionary Investment Management Business, but to the entirety of BAC and its affiliates, including business groups and units within MLPF&S and BANA that provide non-discretionary investment management services; and (2) the Discretionary Investment Management Business makes available investment management solutions and products that do not meet the parameters of the ESRP Guidelines.


SG 03. Conflicts of interest

03.1. Indicate if your organisation has a policy on managing potential conflicts of interest in the investment process.

03.2. Describe your policy on managing potential conflicts of interest in the investment process.

Our parent company, Bank of America follows practices designed to manage conflicts of interest and help ensure that clients’ interests always come first. Bank of America evaluates its business activities and the actual and possible conflicts that may emerge from its activities on an ongoing basis. To the extent that existing or new business activities raise an actual conflict of interest, or the appearance of a conflict, we endeavour to provide full and clear disclosure or take appropriate action to avoid them. Bank of America also has an Enterprise Code of Conduct by which all employees are required to abide, and mandates that employees must identify and address real or perceived conflicts of interest.

03.3. Additional information. [Optional]


SG 04. Identifying incidents occurring within portfolios (Private)


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