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.