Local impact. Global momentum. 2011 Corporate SoCial reSponSibility report Table of Contents
1 Welcome ...... 3 Letter from Brian Moynihan Letter from Anne Finucane Corporate Social Responsibility at Bank of America
2 Global Profle ...... 6
3 Our Global Workforce ...... 13
4 Responsible Business Practices ...... 21
5 Strong Economies ...... 33
6 En vironmental Sustainability ...... 53
7 Leadership & Service ...... 75
8 Ar ts & Culture ...... 83
9 Diver sity & Inclusion ...... 91
10 Global Awards and Recognition ...... 97
11 Global Reporting Initiative Disclosures ...... 101
12 About This Report ...... 115
13 Contacts and General Information ...... 121
Cover images
Last year, our employees volunteered over Our funding supports energy-effcient programs 1.5 million hours at nonprofts and community like Dumont Green in NYC, as part of our 10-year, organizations like Free Arts NYC. $50 billion environmental business initiative.
We lend and invest in small businesses Strong leaders are vital to healthy communities, that are the backbone of our economy, like and we’re committed to supporting them with Pizza Port in San Diego. initiatives like the Global Ambassadors Program.
2 Welcome “We connect the people and businesses we serve with the products, tools and resources they need to accomplish their goals, drive economic growth and make communities and the world better.”
To our customers, shareholders, neighbors and teammates: Our
I am pleased to share Bank of America’s 2011 Corporate Social Responsibility Bank of America employees around the (CSR) Report. Our work in CSR fows from the values of our company and world share a common set of values that demonstrates leadership, helps attract and retain top talent, and enables us guide our work — both what we do and to deliver the fnancial services and products our customers want. how we do it — every day.
•Deliverforourcustomers,clients Acting responsibly is critical to our business. We expect to achieve our and shareholders business goals while helping to address both local and global challenges. Since •Trustinourteam 2010, we have sharpened the focus of our company to better serve customers •Embracethepowerofourpeople and clients and strengthened the foundation of the company with record capital •Actresponsibly and liquidity. In doing so, we are achieving business results that create value •Promoteopportunity for our shareholders, customers, clients and the communities we serve.
On a wide range of issues from the environment to community stabilization to lending and investing, I’m proud of the record we’ve built and hope this report will provide you with insight into the progress made and results achieved over the past year.
Sincerely,
Brian T. Moynihan Chief Executive Offcer Stakeholders:
Thank you for your interest in Bank of America and our We are focused on strengthening and simplifying our business. 2011 Corporate Social Responsibility report. We have made signifcant changes in our policies and practices — our position on overdrafts, our clarity commitment and our The world, the fnancial sector, and our business continued loan modifcation programs to name a few. And we are moving to face unprecedented challenges through 2011 and so we forward with energy and optimism. This is how we will grow asked ourselves: “What is it that we can do? How can we do and, as importantly, restore confdence in our company. better — better by our customers, better by our communities, better by our shareholders, and better by our employees?” As you will read in this report, we spent 2011 working toward this commitment. We have made signifcant progress, but I speak on behalf of the full management team in sharing much still needs to be done. We believe that Bank of America Bank of America’s commitment to doing better. We can and has the right strategy, plan and talent in place to responsibly will do better by building on and refning our current efforts; meet these and other challenges ahead. And I know we have deepening our connections with customers, clients and the commitment. communities by listening, collaborating, helping and responding to their needs; and by continuing to connect Sincerely, them to the right fnancial solutions, expertise and resources.
Being a responsible company means making a positive Anne Finucane impact on society at large, demonstrating our value to each Global Strategy and Marketing Offcer and every stakeholder, while holding ourselves accountable.
“ We can and will do better by deepening our connections with customers, clients and communities, and by listening, collaborating, helping and responding to their needs.” Corporate Social Responsibility at Bank of America
“Promoting strong and vibrant communities, economies and markets has always been part of our mission. It is critical to the success of our business and the success of everyone we serve. By pursuing this mission responsibly, we can better meet the needs of our customers and clients; attract and retain diverse talent; position our bank for sustainable growth; and deliver value. All this must be based on sound policies and practices that strengthen trust among customers, clients, communities and investors, as well as ensure the stability of our business.”
— Andrew Plepler, Global Corporate Social Responsibility and Consumer Policy Executive
Stakeholders increasingly expect companies to have a Our stakeholders identifed a number of issues of materiality robust and transparent approach to CSR. While our values for this report. Many fall within our focus on Responsible remain at the core of everything we do, in 2011 we evolved Business Practices, Strong Economies and Environmental our perspective on CSR. As part of this evolution, we have Sustainability. Our impact is expanded and strengthened by been guided by the idea of “shared value,” a belief that we programs and outreach efforts in Leadership & Service, Arts can fnd business opportunities while addressing social, & Culture and Diversity & Inclusion, through which we can economic and environmental priorities of society at large. engage more broadly with our stakeholders around the world, supporting their interests and priorities. Our work in each With this in mind, in 2011 we revised our defnition of CSR area has been ongoing for many years, but this evolved and how we operationalize it. We have six CSR focus areas: structure will help us better organize ourselves, identify new Responsible Business Practices; Strong Economies; opportunities, track progress and be more accountable and Environmental Sustainability; Leadership & Service; Arts & responsive to stakeholders. Culture; and Diversity & Inclusion. These areas are defned on the next two pages and throughout this report.
Welcome 5 Corporate Social Responsibility Focus Areas
We put our values into practice every day as we continuously work to integrate CSR into our daily operations, focusing where we can have the greatest impact.
We rigorously review our business Vibrant economies are the backbone We are working to fnance the practices and policies, including our of strong communities. By partnering transition to a lower-carbon future — risk and compliance frameworks, with large and small organizations managing our own efforts and helping to ensure that we meet our through lending, investing and giving, customers and communities navigate responsibility to our employees, we help fuel economic growth. In toward an economy built on more customers, clients and addition, we focus our charitable sustainable business practices. shareholders. giving on addressing critical needs such as housing, hunger and jobs.
6 Welcome We have a long-standing commitment We are committed to a diverse We value our differences — in to global leadership development of program of cultural support — thought, style, culture, ethnicity and individuals and organizations that enriching society, helping arts experience — understanding that advance economies and society. Our organizations thrive and promoting diversity and inclusion are good employees worldwide play a critical cultural understanding through for business and allow our company role in contributing to communities the arts. to better serve our employees, through volunteer service. customers, clients and shareholders.
Welcome 7 Our Reporting Priorities
Our objective for this 2011 CSR report is to address the Process for Analyzing Materiality issues most important to our stakeholders. Based on In 2011, we went through a four-step feedback received from external and internal stakeholders process to identify and prioritize material on our 2010 CSR report, our senior leadership agreed that issues that included: our 2011 materiality assessment process should be both 1. Developed a common standard of more formal and more inclusive this year. materiality for Bank of America with respect to CSR activities For clarity, we have structured this report around our six CSR focus areas. 2. Analyzed external media and analyst Within these six areas, the materiality analysis helped prioritize issues commentary of the bank’s operations and give them appropriate attention and weighting. The material issues and management identifed include: 3. Conducted interviews with internal subject-matter experts, communication •Theoverallstrengthandstabilityofthebank,includingbuilding team members and senior executives capital and addressing risk, litigation and regulatory reform 4. Gained external feedback from •Interactingwithcustomers,clientsandstakeholdersinafairand various stakeholders transparent manner and providing value for the products and services the bank offers We applied the Global Reporting •Workingwithcustomerstoaddressmortgageissuesandhelp Initiative’s G3 guidelines and used in strengthening the U.S. housing market its Financial Services Supplement. Additional information on the materiality •Contributionstothecommunitiesthebankservesthrough and reporting process can be found in investing, lending and philanthropic efforts Chapter 12. •Thebank’simpactontheenvironment,includinginformation on the projects fnanced and the bank’s own operations
8 Welcome CHAPTER 2 Global Profle Bank of America Global Profile
OPERATIONS 40 50 5,770 17,750 25,912 Countries U.S. States and the Banking Centers ATMs Global Ofÿces District of Columbia in the U.S. and Facilities
Europe, Middle East, North America Africa Asia Paciÿc
Latin America, Caribbean Countries with Bank of America operations
Countries without Bank of America operations
OUR GLOBAL FOOTPRINT
Europe, Latin America North America Middle East, Africa and Caribbean Asia Pacific
2011 Total Revenue, Net of Interest Expense $73,613 Million $7,320 Million $1,631 Million $10,890 Million*
2011 Total Income (Loss) Before Income Taxes ($9,261 Million) $1,009 Million $424 Million $7,598 Million* 2011 Philanthropic Giving $196,693,650 $6,909,845 $1,574,042 $3,246,039
GHG Emissions (Scope 1, 2) Metric tons CO2e 1,503,297 97,829 3,959 104,805
Business Operations
Bank of America Bank of America Bank of America Bank of America Merrill Lynch Merrill Lynch Merrill Lynch Merrill Lynch Merrill Lynch Global Wealth & Wealth Management Investment Management U.S. Trust Bank of America Merrill Lynch *Amounts include pre-tax gain of $6.5 Billion on the sale of common shares in the corporation’s investment in China Construction Bank. CUSTOMERS AND CLIENTS 57 Million 287,000+ 12,000+ 3.5 Million Consumer and Small-Business Commercial Banking Clients Institutional Clients Global Wealth & Investment Relationships Management Clients
REVENUE AND INCOME ASSETS
Total Net Revenue (FTE Basis) (Loss) in Millions Total Net Income (Loss) in Millions $2.1 Trillion in corporate assets
$12,689 Deposits $1,192 $557 Billion in total credit extended $18,143 Card Services $5,788
($3,154) $1.03 Trillion Consumer Real Estate ($19,529) in total deposits
$10,553 Global Commercial Banking $4,402 $474 Billion in average trading-related assets $23,618 Global Banking & Markets $2,967
$17,376 $2.14 Trillion Global Wealth & Global Wealth & Investment Management Investment Management $1,635 Total Client Balances (includes assets under management, client brokerage assets, assets in custody, client deposits, and loans and leases) $73,613 Million EMPLOYEES SHARES AND SHAREHOLDERS
Average Diluted Common 282,000 10,254,824 shares outstanding, as of 12/31/11 Global full-time employees 53.1% Held by institutional investors
Registered shareholders 237,902 of common stock, as of 2/17/12
Bank of America Bank of America Bank of America Bank of America Merrill Lynch Merrill Lynch Merrill Lynch Merrill Lynch BRANDS Merrill Lynch Global Wealth & Wealth Management Investment Management U.S. Trust Bank of America Merrill Lynch Additional information is available in our 2011 10-K fling as well as on our website. 12 Global Profile CHAPTER 3 Our Global Workforce 3 | OuR GLOBAL WORkfORCE
To be successful, Bank of America must have a strong, diverse, talented team of people who are committed to the values and vision of the company. We are fortunate to have such a team in place. Our employees continue to fnd the bank a place where they can build dynamic careers in a culture of mutual respect.
WORKFORCE PROFILE 2010 2011 Data based on full-time employees
TOTAL DIVERSITY AMONG WORKFORCE U.S. WORKFORCE PARTICIPATING IN Percentage of people of diverse races RETIREMENT PLANS 15.2% and ethnic backgrounds 288,000 outside the U.S. 43% 29% 86% 88% 84.8% 282,000 in the U.S. U.S. workforce Global management level
MALE/FEMALE Male Female EDUCATION REIMBURSEMENT PROGRAM (approximation) 2010 2011
61% 39% 43% 57% 60% 40% 56% 44% 33% 66%
9,700 9,600 participants participants
In the U.S. Global In the U.S. Outside Global Management Team the U.S. Management Team ANNUAL PERFORMANCE REVIEWS Percentage of participation NUMBER OF AFFINITY GROUPS TRAINING AND PARTICIPANTS Diversity, inclusion and aspects of human rights
over 200 employee networks 97% 98% with 20% participation level
14 Our Global Workforce “Every day our employees around the world help families, business and communities manage their fnancial needs. To ensure their success, we are focused on creating an environment where every employee has the opportunity to make a difference, grow in their career and achieve their goals.”
— Andrea Smith, Global Head of Human Resources
Our Global Workforce 15 Building a Global Team
Open Dialogue Diversity & Inclusion Key to building and maintaining an effective team is ensuring A diverse workforce and inclusive environment is essential open and direct two-way dialogue between employees and to attracting and retaining the best talent in the sector. senior leadership teams. In addition to quarterly town-hall Bank of America continues to be widely recognized for our meetings and direct response to employee emails by senior diversity and inclusion policies and initiatives as well as the executives, we have developed a variety of vehicles through internal structure and oversight that guide our practices. which employees voice their concerns, ask questions and For a more comprehensive discussion of our diversity and share ideas. For example, employees have used Speak Up!, inclusion efforts, please see Chapter 9 of this report. an internal information sharing platform, to submit their ideas and recommendations to improve the company. In 2011 employees submitted thousands of ideas aimed at helping Bank of America become a more effcient, effective and customer-driven company.
CASE STuDY: GBAM GLOBAL WOMEN’S CONFERENCE
In 2011, we held the frst annual Global Banking Sponsored by the Global Banking and Markets Diversity and Markets (GBAM) Global Women’s Conference — and Inclusion Council and the Women’s Leadership designed to celebrate and highlight the achievements Council, the Conference was held at nine live locations of women as well as promote the frm’s commitment to around the world including Charlotte, Hong Kong, diversity and inclusion. London, Mumbai, New York, Seoul, Singapore, Sydney, and Tokyo. It was attended in-person and via live Tom Montag, President of Global Banking and Markets, webcast by nearly 750 employees. emphasized the need for diversity and inclusion: “We are a global company, and as we continue to enhance our global presence, our need for a more diverse workforce “We are a remarkable and successful is essential to our continued success. In an 18-month group of women and we have a time period, we have hired 28 female managing directors tremendous impact on our business.” around the world. We need to continue to build a strong female network and this event helps to underscore our — Lisa Carnoy, Co-head of Global Capital commitment and dedication to this effort.”
16 Our Global Workforce “Each year is a story of success for all employees. We are given a chance to establish a career, to make sound judgments related to our job, and get to know our peers, clients and customers.”
— Macky Canillas, Global Technology & Operations, Asia Pacifc
Supporting Our People
Benefts Overall, the bank continues to pay most of the cost for Our objective is to provide beneft options that best meet employees’ medical coverage. In 2011, the bank decided the range of needs and interests of our employees around to reduce copayments for generic prescription drugs and the world. Benefts offered to our employees are competitive keep low, fxed copayments for doctor visits under the and comprehensive, and tailored to each local market. Comprehensive Traditional Plans to help ensure medical Last year, approximately 207,000 employees participated care and services remain accessible in 2012. in our benefts program. Through our Benefts Education & Planning Center, U.S. In our 2010 CSR report, we discussed a range of employees now receive free, confdential fnancial advice benefts offered to U.S. employees — from adoption from independent fnancial planners. In 2011, our employee and child-care reimbursement programs, to health and interactions with this service increased 246 percent to wellness, compensation and retirement to work-life over 79,000, demonstrating our commitment to helping balance opportunities. The details of these benefts employees plan and save for their futures. can be found in our 2010 CSR report.
The rapidly rising cost of health care remains a top concern of U.S. employees. The bank provides access to quality healthcare coverage through a comprehensive and competitive benefts package. Our benefts include Health Advocate, Condition Management and Healthy Lifestyle Coaching programs, which provide access to registered nurses and one-on-one assistance to coordinate care for complex healthcare needs.
Our Global Workforce 17 Training and Career Development Employee Safety Creating opportunities for our employees to advance We have developed an industry-leading Occupational Health their skills and careers helps us work toward our goal and Safety (OSHA) program, which aims to reduce injury of becoming the world’s fnest fnancial institution. As rates in addition to providing a safe and secure workplace part of this effort, our performance management process and emergency evacuation procedures for employees. Our provides measurable goals and coaching for all employees. Safety and Injury Prevention Department has conducted In 2011, more than 30,000 employees found new extensive research to identify and address problems — opportunities within the company. particularly those related to slip and trip hazards and muscular-skeletal disorders, including repetitive stress Through global learning programs, we aim to ensure that injuries such as carpal tunnel syndrome. Since 2005, we employees are profcient in the skills they need for their job have trained nearly 6,000 managers to prevent injury and and can develop skills to grow into future roles. In 2011 manage costs. We have established ergonomic design our employees logged more than 10 million training hours — standards for our branches, offces and facilities, and have taking advantage of the thousands of courses offered through initiated over 100 safety committees to date. our employee learning curriculum. We also continue to offer our tuition reimbursement program, which provides up to $5,250 per year for U.S. employees for both undergraduate and graduate courses that are job-related. Similar programs are offered in other countries.
In the event that an employee’s job is impacted, eligible employees may receive assistance to support them in fnding other employment opportunities within or outside the company.
“You can go as far as your desire and talent take you. After 15 years of off-and-on night school, half of which was fnanced by the bank’s tuition assistance program, I did get that degree. Every step of the way I was able to apply and enhance what I was learning in the classroom with my real-world experience.”
— Jeanette Hood, Global Consumer and Small Business Banking, U.S.
18 Our Global Workforce Impact of Our Employees
Employee Volunteerism EMPLOYEE HOuRS VOLunTEERED Our employees champion our commitment to strengthening communities. Their efforts align with the bank’s philanthropic priorities, including housing, hunger and job-training programs. VOLUNTEER VOLUNTEER VOLUNTEER VOLUNTEER Employee volunteer hours rose by 15% from 1.3 million in 2010
to 1.5 million in 2011. This was driven by our leadership’s VOLUNTEER VOLUNTEER VOLUNTEER VOLUNTEER VOLUNTEER VOLUNTEER commitment to the program, line of business engagement, call to action to volunteer and strategic partnerships that VOLUNTEER VOLUNTEER VOLUNTEER VOLUNTEER VOLUNTEER VOLUNTEER provided local opportunities. See Chapter 7 for additional information on employee volunteering. VOLUNTEER VOLUNTEER VOLUNTEER VOLUNTEER VOLUNTEER VOLUNTEER
Employee Donations/Matching Gifts VOLUNTEER VOLUNTEER VOLUNTEER VOLUNTEER VOLUNTEER VOLUNTEER To further the impact of our employees, the Bank of America Charitable Foundation has continued to award volunteer grants and offer its matching gift program. In 2011, our 1.3 million 1.5 million employees contributed more than $25 million in donations 2010 2011 to support nonproft organizations, which in conjunction with donations through the company’s matching gift program, resulted in more than $50 million of impact.
Our Global Workforce 19 THInkInG AHEAD
Our people will always be our most important asset. To Focus areas will include: succeed in the global fnancial marketplace, we must 1. Recruitment — propelling Bank of America forward as continue to attract and retain employees who understand, an Employer of Choice support and contribute to the overall vision of the company. In 2012, we have already instituted some changes to 2. Professional Development — fostering an environment achieve this goal: where employees have an opportunity to learn and grow in their career •Beginningin2012,anyeligibleemployeebasedinthe U.S. who elected to cover a same-sex domestic partner 3. Workplace Environment — supporting Bank of America’s and/or same-sex domestic partner’s children through the operating principle: “We will be the best place for people company’s insurance plans is eligible for a reimbursement to work” to offset the additional required tax paid by the employee 4. Business Strategy — enhancing our efforts to meet for that coverage. the diverse needs of customers around the world •In2012,thecompanyexpectstolaunchrobusttechnology 5. Community Involvement — strengthening the and tools, refned processes, increased communication and communities we serve through philanthropy and recognition to better support the Employee Networks — volunteerism with the primary objectives of simplifying administrative tasks and allowing for more autonomy. The Network leaders will be introduced to fve core focus areas that will enable a stronger, more consistent story of the measurable impact they drive for the company. Employee Network leaders will design initiatives that ft within one or more of these fve focus areas, which will support their goals as an Employee Network on a local and regional level.
20 Our Global Workforce CHAPTER 4 Responsible Business Practices 4 | RESPOnSIBLE BuSInESS PRACTICES
We rigorously review our business practices and policies, including our risk and compliance frameworks, to ensure that we meet our responsibility to our employees, customers, clients and shareholders.
In 2011, we worked to restore trust and the public’s confdence in the bank by: ensuring our products and services are fairly valued, being more transparent in our interactions, strengthening and streamlining the bank and continuing to act responsibly and ethically in everything we do.
Fairness, Transparency and Value
By focusing on satisfying the fnancial needs of our customers We ask ourselves these questions, and we also ask our and clients, we work to offer solutions that are fair, easy to customers and clients through surveys, focus groups and understand, seamless and effcient. We strive to understand other outreach efforts. Their opinions guide us in providing what products and services the customer wants, how he or the broad range of Consumer Banking products they need she wants to interact with our bank, and the value of the and want in every phase of their fnancial life at price points products, solutions, services and advice the bank provides. that refect the value of the solution delivered.
Our goal is to build long-lasting relationships with our Last year we reported on our decision to help customers customers and clients. To achieve that with our Consumer avoid unexpected overdraft fees by authorizing debit card Banking customers, for instance, we must deliver banking transactions at the point of sale only if customers have products and services they want, at a cost that is fair and enough money in their checking or Overdraft Protection equitable, with terms they understand. A few questions account. The response from customers, consumer quickly surface: What is a fair fee to charge for a service? advocates and policymakers was very positive. As we Are customers who have broad and deep relationships with continue to focus on delivering value, we remain dedicated the bank being properly rewarded? If technology drives down to being clear, consistent and concise, in language that is costs, should we encourage customers to use more of the understandable, about the terms and conditions associated technology platforms we develop? with our offerings. We will continue to make it easier for clients to understand their investment and banking options and to ensure they have a positive overall experience. This value exchange guides our customer- and client-driven strategy and our efforts to be a company that is transparent, straightforward and easy to do business with.
22 Responsible Business Practices Debit Card fees Value Through Investment Choices For the past two years, the fnancial industry has been In 2011, through our Global Wealth & Investment assessing, and in some cases realigning, the products Management division, we continued to provide investment and services it offers with the fees it charges. Debit card choices for clients who want to put their money where usage fee is one example. In 2011, many of our competitors their beliefs are. We offered a robust platform of socially implemented new fees or were in the process of testing responsible investments (SRI) for clients, including the idea with their customers. We were still in the planning approximately $360 million in assets under management process, but it was our intention to start charging debit card (AUM) in SRI mutual funds and $22 million in AUM in SRI users a monthly fee, which would have gone into effect exchange-traded funds (ETFs) in Merrill Lynch as of year- in 2012. end. U.S. Trust held more than $313 million in AUM in SRI solutions, also as of year-end. Bank of America received signifcant media coverage, and the reaction from our customers and others was immediate. The Socially Innovative Investing Strategy (S2I), U.S. Because we listen and respond to what customers tell us, Trust’s proprietary, socially responsible investment strategy we made the decision to end the planning process and not launched in 2010, continued to gain traction with clients. By to implement the fee. Several other fnancial institutions also year-end 2011, the portfolio’s AUM grew to approximately chose not to move forward with the fee. $300 million. S2I is based on the principles of shared value — policies and management practices that simultaneously We will continue to work to understand what customers want enhance a company’s performance while addressing social and what they are willing to pay for. And most important of and environmental issues. all, we will maintain an ongoing dialogue with our customers and clients.
Responsible Business Practices 23 Choices in Banking Bank of America is employing new technologies for our customers in order to make banking and investing more Customer and Client Satisfaction convenient, accessible and cost-effective. Bank of America continually surveys customers and employees. Through these surveys, in 2011 we observed: One such example is in mobile banking: previously, Bank of America’s mobile web and hybrid downloadable app •OverallCustomerSatisfactionmetricsweresteady solutions for Mobile Banking, though extremely successful through August 2011 before a confuence of negative and highly rated, were slow for our customers and did not news stories and experience challenges caused support the next generation of mobile functionality. In 2011, some decline. we launched the new Mobile Downloadable native apps that •SatisfactionwithMerrillLynchFinancialAdvisors have enabled a better customer experience and expanded remained at or near all-time highs. mobile banking capabilities setting the foundation for the •ChannelSatisfactionwithBankingCenters,Call future. The new enhanced app is also tailored to support Centers and Online experiences all fnished 2011 more mobile devices. The customer now experiences a near where they started. faster app and a more intuitive menu that provides easier navigation with the same security that customers have come to expect from us.
24 Responsible Business Practices Enhanced Value for Customers and Clients BankAmericard Cash Rewards™ Bank of America strives to recognize and reward customers As another example of how we respond to our customers’ and clients, regardless of how they choose to do business needs, when customers told us they wanted to be rewarded with us. With our reach and expertise, we are able to deliver for where they use their cards the most, we introduced the across our customers’ and clients’ needs, including cash new BankAmericard Cash Rewards™ and Cash Rewards and transaction accounts, home lending, borrowing, savings for Business MasterCard® credit cards in 2011 to give and investments. our customers the opportunity to earn cash rewards for purchases made with a Bank of America credit card. We are teaming specialists—including Merrill Edge Financial Solutions Advisors and Bank of America Small Business BankAmericard Cash Rewards customers earn 1 percent Bankers and Mortgage Loan Specialists—with personal cash back on all purchases, 2 percent on grocery purchases bankers to offer our customers and clients in-person and 3 percent on gas purchases. In addition, customers expertise and advice. We have grown the specialized sales get a 10 percent bonus when they deposit their cash force to nearly 5,400 employees so far. rewards into their Bank of America checking or savings account. Small Business Cash Rewards credit card clients In addition, Merrill Edge offers the investment insights earn 1 percent cash back on purchases, 2 percent on of Merrill Lynch and the banking convenience of restaurant purchases and 3 percent on offce supplies, Bank of America. Clients can have access to a full range gas and computer network service purchases. of investment solutions from Merrill Edge and banking products from Bank of America. Merrill Edge offers clients Very quickly these card programs have become popular as the ability to view and access their Merrill Edge investment more than 1 million customers and clients enjoy the benefts accounts and Bank of America banking accounts online at of BankAmericard Cash Rewards. merrilledge.com. Clients that choose to invest on their own can open a Merrill Edge self-directed account. Should they Transparency in Customer Communications seek guidance, clients can open an account with the When frst introduced to the public in 2009, Bank of America’s Merrill Edge Advisory Center and work with a Financial Clarity Commitment® Statement for Home Loans was upheld Solutions Advisor who can help them identify fnancial goals as a model for the mortgage lending industry by industry and develop investment strategies to help pursue them. associations and national media. Similar clarity statements for card and deposit products have since been released, allowing our clients and customers to easily understand our products and services. Merrill Edge is available through MLPF&S, and consists of the Merrill Edge Advisory Center (investment guidance) and self-directed online investing. In 2011, we continued to refne and improve our efforts MLPF&S is a registered broker-dealer, Member SIPC and to be clear, consistent and concise with the goal of a wholly owned subsidiary of Bank of America Corporation. Investment products: facilitating a better client experience. For example, in our Global Wealth & Investment Management business, we Are Not FDIC Insured Are Not Bank Guaranteed May Lose Value rewrote 43 Merrill Lynch service notice templates in plain language, representing 90% of the annual volume produced. We also enhanced several key account-opening documents to make them more client-friendly by rewriting them in plain language and formatting them cleanly, making it easier for clients to provide us with information and enabling us to reduce paper use. The Global Wealth & Investment Management division’s retirement business also streamlined and simplifed its participant communications.
Responsible Business Practices 25 “Through the strategic transformation we began in 2010, we are becoming a more streamlined company, sharply focused on deepening client relationships through our core businesses and operating with less complexity, more transparency and lower risk.”
— Brian Moynihan, Chief Executive Offcer
Strength & Stability
If the past four years have taught us anything, responsible business practices must start with our own strength and INCREASED TIER 1 COMMON stability. In 2011, we focused on three core areas to help us CAPITAL RATIO TO A RECORD become a signifcantly stronger bank than we were before the fnancial crisis. These areas are: 9.86% •CapitalReserves CREDIT ExTENDED IN 2011: •RiskManagement •CorporateGovernance $557 billion
ORIGINATED NEW SMALL-BUSINESS LOANS AND COMMITMENTS TOTALING $6.4 billion
26 Responsible Business Practices Capital Reserves Risk Management A strong company is founded on a strong balance sheet. Risk is inherent in all of our material business activities. In 2011, Bank of America continued to build on efforts to We manage seven key types of risk in our daily operations: develop a “fortress balance sheet” by increasing capital, Strategic Risk, Credit Risk, Market Risk, Liquidity Risk, including the selling of noncore assets, strengthening credit Operational Risk, Compliance Risk and Reputational Risk. reserves, building liquidity and reducing debt. Some notable achievements in 2011 include: We take a comprehensive approach to risk management, •OurTier1commoncapitalratioincreasedtoarecord9.86 fully integrating risk management with strategic, fnancial and percent on December 31, 2011, up from 8.6 percent at customer-client planning so that goals and responsibilities the end of 2010. align across the company. We also ensure that risk appetite •Ourglobalexcessliquiditysourcesincreasedto and risk are commensurate with capital. $378 billion on December 31, 2011, up from $336 billion on December 31, 2010. Our risk framework, launched in early 2010, further •Ourlong-termdebtdeclinedto$372billionatDecember demonstrates our commitment to maintaining strong, 31, 2011 from $448 billion at December 31, 2010. consistent risk-management practices across our •Time-to-requiredfunding,whichmeasuresthenumberof businesses, geographies and employees. Managing risk at months our holding company can continue to meet its Bank of America is guided by the following approach: unsecured contractual obligations using only global excess liquidity sources, increased to 29 months at the end of Risk Culture: We consider risk in all business decisions. 2011 from 24 months one year earlier. Risk Appetite and Philosophy: We apply both quantitative •SaleofsharesinChinaConstructionBank:Thisdecision and qualitative terms to measure risk appetite. was consistent with our stated objective of continuing to Risk Governance and Organization: Governance and build a strong balance sheet and further strengthened our organization ensure that risk management is considered in Tier 1 common capital. all business activities. •SaleofconsumercreditcardbusinessinCanada:While Risk Transparency and Reporting: We understand our the credit card remains a fundamental core product for current risk profle and report accordingly. our U.S. customers, an international consumer card business under another brand is not consistent with our In 2011, we took these efforts to the next level by enhancing strategy to deliver the Bank of America franchise to our our focus on strengthening the risk culture and deepening core customer groups. accountability in the business units.
With these actions, Bank of America has been able to A strong risk culture is critical to the future success of strengthen the capital foundation of the company while Bank of America and is a clear expectation of our executive increasing our ability to serve customers and clients around management team, board of directors and regulators. the world. As a result, we: Each employee, whether part of a business unit or enterprise control function, is accountable for managing risk •Extendedapproximately$557billionincreditin2011. proactively. Our daily decisions and actions directly affect our •Helpedmorethan693,000homeownerseitherpurchase shareholders, our customers and clients, and our company’s a home or refnance an existing mortgage. reputation. That is why we must hold ourselves and each •Originated$6.4billioninnewsmall-businessloans. other accountable for demonstrating our core values and •Raised$644billionincapitalforclientstohelpsupport acting responsibly. the economy. Further information about how we mitigate risk can be found in our 10-K fling.
Responsible Business Practices 27 Eurozone Crisis Corporate Governance The fnancial environment across Europe continues to Efforts to strengthen the bank are supported by our strong challenge governments, fnancial institutions, investors and corporate governance structure (detailed information about consumers. Bank of America has been carefully managing our corporate governance guidelines is available on our its exposure to Greece, Ireland, Italy, Portugal and Spain, website). Our board of directors provides oversight of the while continuing to serve customers and clients in those company’s affairs and constantly works to improve and countries. Our total sovereign and nonsovereign exposure build on the company’s strong corporate governance to these European countries was $15.3 billion on December practices. Our management processes, structures and 31, 2011 compared to $16.6 billion on December 31, policies help ensure compliance with laws and regulations, 2010. Our total net sovereign and nonsovereign exposure including anti-corruption and anti-bribery laws, and provide to these countries was $10.5 billion on December 31, 2011 clear lines of sight for decision-making and accountability. compared to $12.4 billion on December 31, 2010, after In addition, our Core Values and Code of Ethics are designed taking into account net credit default protection. to foster a culture of openness, in which healthy debate is encouraged and employees are expected and required to We will continue to monitor conditions in these countries, report improper activity. taking appropriate steps to manage our exposure while serving customers and clients. We have a global presence, We appointed a new chief data offcer responsible for the see opportunity on a global scale and intend to pursue bank’s data management strategy, policy and governance. it prudently. This appointment further demonstrates the importance we place on customer privacy and data security, and the integral Challenges in Asia role they play in ensuring that we operate in a secure and Japan was marked by the trauma of a massive earthquake, effcient manner. tsunami and nuclear incident in early 2011. We are committed to helping our customers, clients and team members who live and work in Japan to overcome this tragedy, and we continue to view Japan as an important market. Our In response to the devastation, Bank of America and our profle in 2011: employees volunteered time and donated resources to support the recovery of communities in Japan. In addition, Board Membership: 13 members, 11 of whom we hosted the Eighth Bank of America Merrill Lynch Japan are independent Conference in Tokyo with the focus on “The Road Ahead — Independent Chairman of the Board: Opportunities Beyond the Earthquake.” We are optimistic Charles O. Holliday, Jr. was elected to that role about Japan’s economy continuing on a path to growth. The in April 2010 region remains a key component of our international presence Six Board Committees: Audit, Compensation and as we aim to strategically operate in the global economy. Benefts, Corporate Governance, Credit, Enterprise Risk and Executive Committees Litigation-Related Matters We are committed to addressing litigation in a manner that Board Meetings: 10 full board meetings, between will beneft our shareholders, customers and employees. nine and 21 meetings of individual committees A comprehensive review of litigation-related matters can and regular briefngs and conference calls among be found in our 10-K fling. members and management Board Diversity: Two female directors; eight directors with experience outside the fnancial services industry Board Evaluations: Yes, annually
28 Responsible Business Practices CASE STuDY: PROJECT NEW BAC
In 2011, Bank of America launched the Project New BAC New BAC has played an important role in driving our review as a new way for employees to help support our customer-focused strategy by helping us: customer-focused strategy. Through this effort, teammates •Alignallofourresourcestoserveourcustomers; from around the world participated in a yearlong review of •Removeobstaclesinternallysothatteammatescanwork the company to identify new ways to focus resources on better together; serving individuals, companies and institutional investors. •Improvethecustomerandclientexperiencebyinvesting in enhancements; and Every Bank of America employee had the opportunity to •Focusandstreamlineourcompany. contribute to this effort by sharing ideas on how to increase revenue, simplify and streamline work, and align expenses. A key component of New BAC is that it’s an employee-driven More than 200,000 ideas were collected through internal process, which means the ideas come from the employees who forums and communication channels. Each idea was are serving customers and clients every day. For example, in then carefully analyzed and those suggestions that best Consumer Banking, employee knowledge and feedback have supported our strategy were approved for implementation. helped us improve our proprietary customer problem-tracking and escalation tool “Commit” by expanding it to online banking. The rollout of approved ideas began in 2011, and we expect to continue into 2014. As the company implements Other examples of New BAC initiatives include: recommendations evolving from this process, we will •Transformingourdatastorageinfrastructure; become a more focused, effcient, leaner company, providing •Conservingresourcesandreducingwastethrough customers and clients with the best fnancial services, green initiatives; generating strong revenues, carefully managing expenses •Improvingcustomeranalyticstoincreasefraudprotection;and and risks, and delivering long-term value for shareholders. •Streamliningdepositplatforms. Global Policies
As part of our responsible business practices, •Formalandmandatedengagements,forexamplethrough Bank of America has established global policies that help our shareholder discussions and voting processes, us live by the core values of the company across all of our responding to customer enquiries and engaging with businesses and activities. regulators. •Voluntaryengagementwithexternalbodiesandadvisors, such as with our U.S. National Consumer Advisory Council, The Bank of America Code of Ethics outlines the business as well as many associations, nonproft groups and practices and policies, as well as the professional and independent advisors, some of which are highlighted in personal conduct, that all employees are expected to adopt this report. and uphold. The Code, which is grounded in our core values, guides how we expect to meet our responsibility to our Suppliers and Procurement customers, clients, shareholders and fellow employees. In Supplier Diversity: At Bank of America, Supplier Diversity 2011 the Code was amended to help further apply these encourages the use of underutilized diverse and small ideas to everyday situations. We also added new information suppliers, based on the categories of goods and services relating to CSR; discrimination and harassment and diversity; we purchase in the communities we serve. The program responding to the media; the new risk framework; workplace managers collaborate with many stakeholders within the safety; and the special obligations of managers to lead by company to ensure that we include diverse suppliers across example. Additional information can be found in our Code of all of our “sourceable” spend base. Some examples of Ethics Disclosure document and on our website. diverse suppliers include minority-owned businesses, those who are geographically or socioeconomically underutilized, Human Rights or businesses owned by veterans, women or individuals who We support the fundamental principles of human rights are lesbian, gay, bisexual or transgender. that are refected throughout all of our Human Resources, hiring and workforce policies and practices including those In 2011, Bank of America spent $2.36 billion with diverse covering discrimination, harassment and diversity and suppliers, an increase from $2.33 billion in 2010 and inclusion. It is also demonstrated through the training of our $1.87 billion in 2009. contract security personnel. Every uniformed security offcer undergoes 40 hours of training, during which human rights SPEnDInG WITH DIVERSE SuPPLIERS are covered, along with training on Bank of America’s other (In Billions) policies and procedures relating to our operations. In 2011, 100 percent of new security offcers underwent this training. 2.5
2 Stakeholder Engagement As a large, international and diverse company, Bank of America 1.5 engages with stakeholders and their representatives every
day throughout the 40 countries in which we do business. 1 $1.87 $2.33 $2.36 Our stakeholders include shareholders, employees, customers and clients, suppliers, community neighbors and partners and .5 regulators. We discuss our work with each stakeholder group throughout this report. We manage our engagement with these 0 2009 2010 2011 groups through:
30 Responsible Business Practices Suppliers and the Environment: We built on our momentum Executive Compensation from the previous year, by working with 164 of our largest Our executive compensation program ties pay for our suppliers to encourage participation in the 2011 Carbon executives to the performance of our company, its lines Disclosure Project (CDP) survey. Robust communication with of business and each individual executive offcer over the suppliers, often from senior bank leadership, helped drive short and long term. Consistent with our compensation participation, and monthly communications and webinars principles, our executive compensation program provides provided suppliers assistance with their responses. a mix of salary, benefts and incentives paid over time that One hundred thirty six of the bank’s largest suppliers, we believe properly align the interests of our executive or 83 percent, responded, which was the highest offcers with the interests of our shareholders. We take into participation rate in our CDP peer group. By encouraging account the manner in which results are achieved, including suppliers to respond to CDP, we are helping to promote the an evaluation of adherence to risk and compliance policies development and implementation of their own effciency and and other core values of our company. Furthermore, we GHG reduction programs and working to reduce the bank’s continually evaluate our compensation policies and practices overall environmental footprint. in light of ongoing developments and best practices in the area of incentive compensation. Environmental Risk and Performance Our Board of Directors reviews and evaluates important The Compensation and Benefts Committee of our Board risks and opportunities faced by the company, which actively engages in its duties and follows procedures from time to time include social and environmental factors intended to promote excellence in the governance of and issues. There are well-established processes for the our pay-for-performance philosophy. We believe that board to execute these responsibilities, including through Bank of America applies prudent risk-management board committees such as the Enterprise Risk and practices to its incentive compensation programs across Audit Committees. the enterprise. Our Compensation and Benefts Committee is committed to a compensation governance structure The annual proxy process allows shareholders to highlight that effectively contributes to our company’s broader risk- social and environmental concerns to the board and management policies. We believe that our compensation management. Internally, management considers social policies and practices appropriately balance risks and rewards and environmental risk factors when making business in a way that does not encourage imprudent risk-taking. decisions, and is guided by a number of applicable policies Additional information on Board and executive compensation and guidelines, including our Credit Policy, Energy Policy, program and compensation governance and risk-management Developing Country Lending Criteria and the Equator practices can be found in our 2012 Proxy Statement. Principles and Climate Change Policy. We also try to guard against corrupt practices through our compliance program. Regulatory Reform We conduct companywide audits to ensure compliance with In the aftermath of the 2008 fnancial crisis, we bank policies, including social- and environment-related understood and supported the need for change and took policies, as well as with our code of conduct. action to respond to stakeholder expectations. In 2011, governments around the world continued to enact new Taxes legislation and regulation in response to the global fnancial In 2011 we paid approximately $2.7 billion in taxes in more crisis. Bank of America continued to play an active role with than 100 jurisdictions globally. Of this amount, we paid government offcials and civil servants to build a stronger approximately $2 billion in income, state and local, payroll, global fnancial system. Detailed information on regulatory property, sales and use and other U.S. taxes. matters is available in our 2011 10-K.
Responsible Business Practices 31 Political Involvement In the U.S., Bank of America does not provide corporate u.S. memberships included: contributions to candidates for public offce. The bank •AmericanBankersAssociation may make contributions to state or local ballot measures, •AmericanSecuritizationForum noncandidate organizations such as political convention •BusinessRoundtable host committees, organizations under Section 527 of •CenterforStrategicandInternationalStudies the Internal Revenue Code and presidential inaugural •TheClearingHouseAssociation committees to the extent permitted by applicable law. •ConsumerBankersAssociation •CouncilonForeignRelations Bank of America maintains a nonpartisan Political Action •CouncilofStateGovernments Committee (PAC) program in the U.S. to allow the company •ElectronicPaymentsCoalition and its employees to be fully engaged in the political and •TheEuropeanInstitute legislative process. Under federal law, the bank is allowed •FinancialServicesForum to pay the costs of administering the PAC program; however, •FinancialServicesRoundtable the company is prohibited from directly contributing to the •FuturesIndustryAssociation PAC. Employees may choose to support the PAC through •GlobalCoalitiononAging their voluntary personal contributions. •InternationalSwapsandDerivativesAssociation •InvestmentCompanyInstitute Outside the U.S., we have a policy of not making •MortgageBankers’Association contributions to any political party or candidate but do, •NationalBusinessCoalitiononE-Commerce&Privacy when appropriate, engage with political parties in our •Statebankers’associations legislative outreach. •SecuritiesIndustryandFinancialMarketsAssociation •U.S.ChamberofCommerce Advocacy and Memberships Bank of America often shares interests with and therefore is an active member of a number of groups that advocate THInkInG AHEAD and shape public policy positions on certain issues. Bank of America is committed to making further Memberships outside the u.S. included: enhancements to our products and services in response •AmericanChamberofCommercetotheEU to better understanding what customers want and need, •AsiaSecuritiesIndustryandFinancialMarkets and translating that knowledge into practical and effcient Association solutions that provide them with more choice and control •AssociationforFinancialMarketsinEurope over fnancial decisions. •BritishBankers’Association •CentreforEuropeanPolicyStudies For 2012, our focus is to continue to build capital and •Eurofi–FinancialServicesinEurope liquidity, manage expenses and ensure that the needs of our •FinanceandLeasingAssociation customers are being met. With stronger capital, liquidity and •FuturesandOptionsAssociation reserves, we are confdent that we will continue to succeed •GlobalFinancialMarketsAssociation in the ever-changing global business environment. •InternationalCapitalMarketAssociation •InternationalSwapsandDerivativesAssociation •U.K.’sAssociationofForeignBanks •U.K.CardsAssociation
32 Responsible Business Practices CHAPTER 5 Strong Economies 5 | STROnG ECOnOMIES
Vibrant economies are the backbone of strong communities. By partnering with large and small organizations through lending, investing and giving, we help fuel economic growth. In addition, we focus our charitable giving on addressing critical needs, such as housing, hunger and jobs.
At Bank of America, strengthening economies means Lending and Investing extending credit to individuals, local businesses and nonproft organizations while yielding a fair return for our shareholders. Bank of America has targeted programs through which we Our philanthropic investments are also a powerful tool to help extend credit to help address local issues and support low- local programs and services strengthen their communities. and moderate-income (LMI) individuals and in communities In 2011 we continued to make progress toward our long- where our strength and resources are needed most. term goals, initiated in 2009, to strengthen the social and economic health of the communities we serve: During 2011, we extended approximately $557 billion in total credit, of which $126.9 billion was for community- development lending and investments. This includes Community Development Banking and commercial and Lending & Investing: real-estate lending, which help provide affordable housing to support revitalization efforts in local communities. Also, $463 billion of $1.5 trillion we extended more than $48.9 billion in credit to nonproft, $463 BILLION SINCE 2009 TOWARD OUR 10-YEAR, $1.5 TRILLION government and anchor institutions to support vital COMMUNITY DEVELOPMENT LENDING AND INVESTING GOAL community resources.
Philanthropy: $600 million of $2 billion $600 MILLION SINCE 2009 TOWARD OUR 10-YEAR, $2 BILLION CHARITABLE GIVING GOAL
34 Strong Economies Strong Economies 35 CHERRY GARDENS Our fnancing of the safe, affordable and green Cherry Gardens apartments is helping to keep this Charlotte neighborhood vibrant.
Community Development Banking Community Development Banking is a key business line Bank of America works with our National Community that helps create stronger economies. We are recognized as Advisory Council (NCAC), a group of 29 independent one of the industry’s largest, most active affordable-housing community leaders and consumer advocates who lenders in the U.S., and through the Bank of America meet periodically to share their insights and provide Community Development Corporation, we are one of the few counsel. Through our NCAC, we work closely with fnancial institutions to act as a direct real estate developer prominent leaders in community development and of affordable housing. In 2011, we invested more than consumer policy to discuss critical issues to promote $1.6 billion to help create more than 11,000 affordable the revitalization of underserved communities housing units including those for families, seniors, veterans throughout the U.S. and people with special needs. Since 2005, we have fnanced and invested in the creation of more than 100,000 affordable housing units across the U.S.
In 2011, additional investments by Community Development Banking included: •Morethan$2.2billionincommercialrealestate-based lending; •Morethan$700millionintaxcreditinvestmentsincluding: –Nearly$655millioninlow-incomehousing –Morethan$44millioninhistoric,newmarketsandsolar
36 Strong Economies COMMUNITY DEVELOPMENT LENDING AND INVESTING As part of our community-development lending and investing
In Billions programs, we’ve made hundreds of individual loans and $1.6 investments creating affordable housing and promoting local $2.9 economic growth across the U.S. in 2011. $12.7
$109.7 For example:
Total •Tohelpcreateaffordablehousingneartheworkplace, $126.9 2011 we provided more than $21 million in loans and made a direct equity investment of $18.4 million to fnance Metro 510 in Tampa, Florida. With 120 units, the Metro 510 project became the frst workforce housing community in Total $463.6 $407.9 downtown Tampa. It also preserved the historic St. Paul 2009–2011 African Methodist Episcopal Church building, which was transformed into a community ftness center.
•Tohelpaddresstheneedforsafehousingoptionsforthe homeless, we provided $103 million in debt and equity, creating 368 housing units in California, New York and Washington state. In Los Angeles, we provided $55 million in debt and equity to help create 147 affordable housing Affordable Housing Economic Development units for homeless and disabled veterans. Residents also Small Business Consumer Lending will have access to supportive services including mental health care, case management, health and dental care, job services and life-skill workshops. The structure additionally meets LEED Silver certifcation standards.
“We really are making a difference.”
— Valerie A. Williams, Global Commercial Banking, U.S.
“We recently fnanced an affordable housing property that is providing housing for 150 families, many of whom were previously homeless. The multifamily property is Platinum LEED Certifed. It includes an onsite learning center and childcare facility. This is just one example of how we are fnancing and investing in housing to meet the needs of those at or below moderate income levels. We really are making a difference.”
Strong Economies 37 Community Reinvestment Act Capital Raising for Companies We are committed to meeting the credit needs of our Bank of America helped raise $644 billion in capital for customers, including our LMI individual and neighborhood clients in 2011 to help support the economy’s expansion. customers, as well as small businesses and small farms. Examples of how we helped companies of all sizes, worldwide, This commitment is refected in our core values and the through all phases of growth include: business units that work together to serve our customers •HelpingFarwestSteel,afabrication,processing, and clients, achieving positive community impact and warehousing and distribution facility in Vancouver, complying with the Community Reinvestment Act (CRA). Washington, to fnance the purchase of cranes and other machinery by increasing a line of credit and Using the Community Reinvestment Act as a guide, we providing $3 million of equity. This is expected to create extend credit and make investments that help address or retain more than 200 permanent family-wage jobs. the needs of LMI communities such as small businesses, •ActingasthefinancialadvisortoSilvinitonitssaleto affordable housing and community facilities. Our efforts have Uralkali for $9.5 billion, the largest M&A deal in Russia been recognized by U.S. bank regulators and are reaffrmed in 2011 and the largest merger of two companies in by our current “outstanding” CRA exam rating — the seventh Russian history. The combination created one of the consecutive for lending, investments and services. As part world’s leading potash companies, a leading global of our commitment, we also collaborate with nonprofts to fertilizer producer and one of Russia’s leading mineral help address credit needs for underserved individuals and resource companies. communities across the U.S. •Beingthelead-leftbookrunneronthe$4.4billioninitial public offering (IPO) of HCA Holdings Inc., the largest In 2011, our U.S. retail franchise continued to work to sponsor-backed IPO and the ninth largest U.S. IPO ever. provide access to fnancial services for LMI customers. HCA is the nation’s leading provider of healthcare services We operated 1,552 banking centers in underserved that includes about 163 hospitals and 110 freestanding neighborhoods, equal to 27 percent of our total U.S. banking surgery centers and employs approximately 199,000 people. centers. Forty-one percent of our banking centers were either in, or within a half-mile of, LMI communities.
CASE STuDY: CAREER TRAINING ACADEMY
The Bank of America Merrill Lynch Capital Access begin a professional career in the healthcare feld in Funds facilitated the fow of capital from institutional less than a year. CTA is accredited by the Accrediting investors to the Career Training Academy® (CTA) in Commission of Career Schools and Colleges and Pittsburgh, Pennsylvania. CTA is a career school licensed by The State Board of Private Licensed offering programs in Medical and Dental Assisting, Schools, Pennsylvania Department of Education. Medical Billing and Coding, Pharmacy Technician and Through our investment, we help CTA provide workforce Massage Therapy. These programs are designed for development programs that enable individuals to be individuals interested in gaining necessary skills to valuable contributors to their communities and beyond.
38 Strong Economies TRIBECA RADIATION Doctor Tracy Ng decided to leave his uptown practice in New York City to serve the underserved population of the Chinatown neighborhood, who were often reluctant to leave the area for cancer treatment. Dr. Ng turned to Bank of America to open a downtown practice. With the bank’s fnancial assistance, Dr. Ng built TriBeCa Radiation, a state-of-the-art radiation cancer treatment facility, to provide advanced and convenient care to Chinatown residents.
Small Business Lending 2010 2011 According to the U.S. Small Business Administration, America’s 30 million small and micro businesses are the New Originations and Commitments to Small Businesses chief generators of new jobs, creating two out of every three < $20 million in revenue new jobs across the country. The fnancial condition and $5.3 Billion performance of small businesses is improving, albeit slowly, with the leveling off of the economy, so more businesses are $6.4 Billion +20% eligible and requesting new credit.
Lending to Small Business To help small businesses be successful, in 2011 we < $20 million in revenue increased new credit loans and lines of credit for U.S. small businesses, including companies located in LMI $18.7 Billion communities, and provided funding for small-business investment companies. $17.7 Billion –5%
We are among 13 banks that have pledged to the White Originations in First- and Second-Trust Deed Loans Through House and the Small Business Administration (SBA) to the SBA 504 Program increase small-business lending by a total of $20 billion $524 Million over the next three years. In 2011, the bank met its pledge to increase new small-business lending by $1 billion. $589 Million +11%
Strong Economies 39 Community Development financial Institutions We partner with Community Development Financial We additionally partner with CDFIs to create affordable Institutions (CDFIs) to provide low-cost capital, liquidity and housing in underserved areas. To date, we have invested technical assistance that promote economic development in more than $466 million in CDFIs that primarily fund traditionally low- and moderate-income neighborhoods. We affordable housing initiatives across the U.S. are the largest investor in CDFIs, with more than $1 billion in capital in more than 200 CDFIs in 40 U.S. states, the Socially Responsible Private Equity District of Columbia and Puerto Rico, fnancing affordable By the end of 2011, our Socially Responsible Private Equity housing, community facilities, nonprofts, small businesses group invested in 357 small companies located across 38 and microenterprises. U.S. states and 239 cities. Of the companies that comprise the portfolio (as of December 31, 2009): Part of our CDFI investment — more than $200 million — •Morethanhalfgeneratedbetween$1millionand is dedicated to supporting small businesses, including low- $25 million in revenues annually, collectively paid cost capital for businesses that do not qualify for traditional out $1.7 billion in salary and generated more than loans. For example, our CDFI loan loss reserve grant program 83,000 jobs. has provided more than $9.4 million in grants to CDFIs to •54%hadsomeethnicminorityownershipandmore leverage more than $93 million in low-cost, long-term loan than 35% had some female ownership. capital, serving more than 8,700 local businesses and •Morethan53%oftheworkforcewasrepresented helping to create and retain more than 13,000 jobs. by ethnic minorities or women. We are also the frst bank to provide capital in the SBA’s Community Advantage Program, which supports CDFIs that lend to small businesses.
CASE STuDY: LEARN CHARTER SCHOOL
In 2011, Bank of America partnered with nonproft “It’s a great school, and they should lender and real estate consultant IFF to provide LEARN Charter School Network with a $1 million, 15-year loan be proud of the education that is from its energy effciency loan fund to renovate a vacant going on in a neighborhood that 29,800-square-foot parochial school building. Located desperately needed high-quality in Chicago’s Auburn Gresham neighborhood, LEARN public education.” Charter School serves nearly 2,000 students and plans to expand its reach to 8,000 low-income students over — Bryce Bowman, Director of Operations and Real Estate, the next decade. Improvements to LEARN’s school LEARN Charter School Network include high-performance lighting fxtures, energy- effcient windows and a building automation system that controls the lighting and mechanical systems to reduce unnecessary energy use. LEARN expects to save between $3,000 and $6,000 a year on utility costs by making these energy-effcient upgrades. The building renovations include 21 classrooms, a multipurpose room for athletics, assembly space, a cafeteria and an administrative area.
40 Strong Economies Support for U.S. Service Members
Bank of America recognizes the signifcant sacrifces military Employee Engagement members and their families make every day, and continues The Military Support & Assistance Group is an employee our commitment to supporting active and veteran members resource network of 23 chapters across the U.S. that and their families through a variety of outreach programs: provides opportunities for employee advancement and leadership development through networking, mentoring Hiring and information forums. See Chapter 9 for more information. More than 5,000 U.S. military service members and veterans work for Bank of America; we have a dedicated Housing team of employees focused on recruiting and retaining We offer specialized mortgage support and programs for military veterans. military customers and their families, including a dedicated servicing unit. In 2011 we provided $3.5 billion in Veterans Banking Administration (VA) mortgages to veterans. We provide full-service banking, including special rates, mortgage assistance and other products and services, to more than two million active and retired military households.
Philanthropy We have partnered with a variety of organizations to provide philanthropic and volunteer support including ongoing partnerships with the USO, Wounded Warrior Project and ServiceNation’s Mission Serve.
Strong Economies 41 Supporting the Housing Market
Bank of America is committed to supporting the needs of In 2011, our efforts focused on: homeowners and the recovery of the U.S. housing market. •Providingcustomerswithavarietyofsolutionstohelp This includes helping to provide solutions to homeowners them remain in their homes or otherwise avoid foreclosure in need of assistance, partnering to stabilize and revitalize •Implementingacasemanagementservicemodeland communities that have been hit hard by the housing crisis, expanding our in-person outreach through Customer and responsibly extending mortgage credit. Assistance Centers and servicer events •Partneringwithnonprofitorganizationsandcommunity groups to support the recovery of neighborhoods through property donation and preservation activities •Extendingmortgagecreditdirectlytoqualifiedconsumers
42 Strong Economies Mortgage Production In 2011, we exited third-party mortgage channels to better Profle of Mortgage focus our lending efforts directly to consumers, extending $151 billion in mortgage credit to customers. Businesses in 2011 We are fully committed to providing our customers with the •Approximately$1.8trillionservicingaportfolio benefts of refnancing through our continued execution of of 11.7 million home loans the U.S. Government’s Home Affordable Refnance Program •Salesforceofmorethan3,000retailand (HARP). Since 2009, Bank of America has funded more than centralized mortgage loan professionals, offering 200,000 HARP loans. In 2011 Bank of America implemented loan products through a national centralized new elements of the HARP program to help customers who program and via 500 retail home loan locations, were previously unable to refnance their homes. These buttressed by processing and underwriting features, including improved pricing and the ability to services available through 62 fulfllment sites. refnance a fxed-rate loan with any loan-to-value (LTV) above •Morethan40,000employeeshelpingmortgage 80 percent, will expand the benefts of refnancing programs customers who needed loss mitigation and to existing mortgage customers under a provision (known foreclosure avoidance assistance as HARP Phase II) introduced by the U.S. Federal Housing Finance Agency in November 2011.
MORTGAGE PRODUCTION
Value of total ÿrst $378 Total rst-mortgage customers mortgages extended Low- and moderate-income ÿrst-mortgage customers* to U.S. homeowners % Percent of total ÿrst-mortgage customers that are low- and moderate-income $298
1,704,804 1,336,164 693,125
$151 32.6% 33.5% 34.4%
Value of ÿrst $85.9 mortgages to $68.9 low- and moderate- income customers $35.2 555,951 448,274 238,388 2009 2010 2011 2009 2010 2011
In Billions Repurchased loans not included. * Inclusive of borrowers and census tracts, controlled for double counting.
Strong Economies 43 Home Retention In February 2011 we created Legacy Asset Servicing (LAS), MORTGAGE MODIFICATIONS which is directly accountable to the CEO and responsible for servicing all defaulted loans and discontinued residential Home loan modi cations through the second-lien modi cation program (2MP) mortgage products. With this, we’ve increased the number Proprietary second-lien home loan modi cations of staff helping mortgage customers who need assistance Loan modi cations through the U.S. Government’s from 5,000 in 2008 to more than 40,000. Home Affordable Modi cation Program (HAMP) Proprietary rst-lien modi cations This dedicated team has helped prevent 1.1 million foreclosures through loan modifcations, short sales and Total 284,537 deed-in-lieu of foreclosures. In addition, we’ve helped Total many more customers reduce their monthly payments 259,987 566 15,314 Total by refnancing their mortgages. Giving customers the 225,632 opportunity to stay in their homes, we’ve completed more 46,227 21,430 than one million loan modifcations since 2008. More than 1,016 108,931 210,000 of the permanent modifcations were completed 5,620 through Making Home Affordable; approximately 79 percent of all modifcations have been completed through our own 82,620 proprietary programs.
In cases where a borrower is unable to qualify for a loan 212,744 159,726 115,962 modifcation or is no longer interested in remaining in their home, we work to facilitate short sale and deed-in-lieu of foreclosure. In 2011, more than 115,000 short sale and deed- in-lieu transactions helped homeowners avoid foreclosure and 2009 2010 2011 make a less diffcult transition to alternative housing.
44 Strong Economies Customer Assistance and Outreach HELP FOR U.S. HOMEOWNERS To better understand customers’ unique situations and EMPLOYEE ASSISTANCE CUSTOMERS ASSISTED deliver solutions to meet their needs, we’ve established a Dedicated staff Customers reached single point of contact for customers and have expanded our helping distressed at bank-sponsored face-to-face outreach through Customer Assistance Centers borrowers homeowner events and homeowner events. U.S. Customer Bank-sponsored Assistance Centers homeowner events Through our case management service model, we provide many customers with a single point of contact who provides 323 updates, answers questions and ultimately communicates 65,617 decisions about loss mitigation and foreclosure solutions. 60,000 60,000 More than 518,000 customers have been assigned a Customer Relationship Manager through 2011, with thousands more customers being added in 2012. 50 296 Customer Assistance Centers: Our Customer Assistance 40,000 40,000 37,363 Centers (CACs) work closely with individuals, families and 6 community leaders in neighborhoods heavily impacted by the 30,000 198 housing crisis. In 2011, we expanded our CAC network in the 23,329 hardest-hit U.S. markets, bringing the total to 50 in 25 states 20,000 20,000 by the end of 2011. Since the frst CAC opened in 2009 through December 2011, we have assisted more than 63,000 1 customers, including more than 50,000 in 2011 alone. 5,000 0 0 Through bank-sponsored homeowner events we bring the 2009 2010 2011 2009 2010 2011 full loan modifcation process — including underwriting and fnancial counseling — under one roof, giving us the ability to meet with customers face-to-face and provide eligible customers with decisions onsite. These events help customers understand their mortgage options and allow them to make decisions with an experienced mortgage specialist. From January 2009 through December 2011, we participated in nearly 800 events, enabling us to reach more than 126,000 customers. nonproft Partnerships: We work closely with local nonprofts to promote the value of CACs and encourage other community members to participate in events. During 2011, we worked with nearly 600 nonproft organizations in 39 states and Washington D.C., expanding our relationships to more than 4,000 local leaders, thus improving the reach of our homebuyer education and counseling services.
Strong Economies 45 Home Loan Home Affordable Modiÿcation Program (HAMP): Modifications We’re an industry leader, and we’ve completed more than 190,000 HAMP modiÿcations — with approximately 37% of permanent modiÿcations completed through HAMP in 2011. Since 2008, to help homeowners retain their Proprietary First-Lien Modiÿcations: homes, we have completed Since January 2008, more than 680,000 borrowers have received proprietary more than one million modiÿcations to their ÿrst mortgage. modiÿcations of ÿrst- and second-lien mortgages Second-Lien Modiÿcations: Bank of America has completed nearly 22,000 second-lien modiÿcations through the government’s second-lien modiÿcation program (2MP), with 97% of this total completed in 2011. More than 100,000 customers have received proprietary second-lien modiÿcations.
Emergency Homeowners’ Loan Program and Hardest-Hit Fund: Bank of America leads the industry with $71.5 million in assistance provided through both programs.
Short Sales and Deeds-in-Lieu: Alternatives to In 2011, we completed more than 115,000 short sales and deeds-in-lieu of foreclosures, with nearly 107,000 short sales and more than 8,600 deeds-in-lieu. Foreclosure Since 2008, the bank has completed more than 264,000 short sales and When modiÿcations are not 16,000 deeds-in-lieu. an option, Bank of America dedicates signiÿcant resources Customer Transition Program: to help customers avoid To assist customers who will transition to new housing, the bank has worked with foreclosure. United Way and other community partners to develop the Home Transition Guide Since its inception, more than 200,000 customers have received the guide in the mail or at bank-sponsored homeowner events, or viewed it online.
Relocation Assistance: We have provided nearly $190 million to assist those who must transition from their home due to a short sale or foreclosure. Customers or tenants are offered assistance for rental deposits for new housing and moving expenses. In 2011, the bank provided almost $76 million in relocation assistance.
Property Donations: Specialty Property donations focus on ÿve areas in support of the company’s philanthropy goals: military, ÿrst responders/police ofÿcers, community development, environment Programs and disaster relief. We provided more than 200 property donations in 2011, and We’re committed to working with more than 235 since 2008. community groups, city leaders and nonproÿt organizations to Neighborhood Stabilization Program: assist in those communities We provided support for the Neighborhood Stabilization Program (NSP), where recipients and their designees, such as community or nonproÿt groups, are granted hardest hit by the economic access to the bank’s real-estate owned (REO) inventory and prelisted vacant downturn in order to address properties. In 2010, we provided more than 900 properties to NSP recipients, blight and stabilize the and in 2011, we delivered nearly 500 additional properties. housing market. Community Partnerships: We maintain partnerships with public agencies in Cleveland, Chicago and Detroit to donate up to a total of 350 low-value vacant properties and to help defray the cost of demolishing deteriorated structures. Global Philanthropy “Through our philanthropic investments, we support the health of communities and Through our philanthropy, we aim to provide a meaningful local economies, creating opportunities response to critical community challenges. As such, our philanthropic efforts have evolved over the past several for individuals to prosper and businesses years, during a time when many communities faced to thrive. As we continue to respond to economic hardship. During 2011, we provided more than community needs, we look for ways to $200 million to address some of the most pressing issues create innovative solutions by engaging our in our communities including affordable housing, fnancial education and other critical needs. We’ve developed customers and employees around pressing signifcant partnerships with nonproft organizations such issues such as hunger, housing and as Habitat for Humanity, United Way Worldwide and Feeding connecting individuals to 21st-century jobs. ” America, which are engaged on the front lines in many communities. These partnerships form the backbone of our philanthropic efforts and are often magnifed through our — Kerry Sullivan, President, Bank of America Charitable Foundation employee volunteer efforts.
GLOBAL PHILANTHROPY BREAKDOWN
BY REGION
$196,693,650 North America $6,909,845 Europe, $3,246,039 Middle East, Asia-Paciÿc Africa
$1,574,042 Total Latin America $208,423,576
BY GIVING AREA
$52,754,921 $50,769,403 $39,010,430 $33,750,430 $25,537,672 $6,600,720 Community Development Education Health & Human Services Matching Gifts Arts & Culture* Environment
*Excludes sponsorship funds.
Strong Economies 47 Evolution of Our Strategy financial Education In 2011 we evolved our safety net strategy — which Bank of America has a long-standing commitment to has supported critical needs like food and shelter — to supporting fnancial capability programs and resources. We increasingly support longer-term economic empowerment maximize our impact by directing loans and investments to in the areas of (1) workforce development, (2) transitional revitalize hard-hit LMI communities. Across our philanthropic employment, (3) youth employment, and (4) green jobs. investments, fnancial stability is integrated into many of One key demonstration from 2011 includes our 3-year, our nonproft partnerships (for example, providing fnancial $50 million workforce development pledge. In 2011, we education to food bank clients). made nearly $6 million in safety net grants that focused on providing education and job training programs to help In addition to our fnancial support of organizations such individuals regain economic stability. This funding provided as Junior Achievement, that provide fnancial education, 13,441 people with training and/or placement our employee volunteers are engaged in a wide range of into employment. activities from teaching middle-school children the basics of personal fnance to working at free income-tax assistance Workforce Development Pledge centers to providing senior citizens with plans for budgeting In 2011, we pledged to invest $50 million over the next and credit card management. We are also integrating three years in education initiatives that will help lead to our fnancial stability efforts through partnerships with economic self-suffciency through employment. These funds community colleges. For example, our work with Achieving will support programs that bridge the achievement gap and the Dream focuses on helping community college students lead to post-secondary education completion. The funding build their fnancial acumen and acquire the skills and will also connect the underserved and unemployed, as well resources to manage their fnances while in school, with the as returning veterans and individuals with disabilities to goal of degree completion and career success. workforce opportunities in high-growth sectors. For example:
Midlands Technical College — fInAnCIAL EDuCATIOn Quick Jobs Program (Columbia, South Carolina) Recognizing the increasingly important role that U.S. CONSUMERS REACHED WITH FINANCIAL EDUCATION AND LITERACY INITIATIVES community colleges play in helping individuals access workforce success, we provided $50,000 in funding to the Midlands Technical College Quick Jobs program, which provides an accelerated education preparing people for high-demand jobs in the regional workforce in as little as six weeks. Quick Jobs programs have been developed for felds where jobs are available and growth is expected, a distinguishing factor of our approach to workforce development. We seek to prepare individuals for employment across a range of sectors, based on local needs. Through this and other programs like it, we focus on helping individuals achieve long-term economic success. 12,413,100 10,838,200 2010 2011
48 Strong Economies CASE STuDY: UNITED WAY FINANCIAL STABILITY PARTNERSHIP
Featured: Sameer Munshi, NYC
In partnership with United Way, we helped lead the creation “Bank of America continues to be one of of the United Way Financial Stability Partnership, a fnancial United Way’s top U.S. corporate partners contribution and thought-leadership initiative that connects working individuals across the U.S. to income support, and is helping to lead innovative individual fnancial education and asset-building products. Through and family fnancial stability efforts our partnership with United Way, we are providing fnancial throughout the U.S. The bank and its and volunteer support to 56 United Way agencies and employees invest considerable time and community coalitions that offer tax assistance and Earned resources in communities to ensure that Income Tax Credit (EITC) awareness, coupled with other asset-building services. In 2011, Bank of America’s support more people are provided opportunities of United Way Volunteer Income Tax Assistance programs they need to lead successful lives.” resulted in measurable impact for individuals and families, including more than 530,000 completed tax returns and — Brian Gallagher, United Way Worldwide president and CEO $800 million in total tax refunds fled, including $279 million in EITC. neighborhood Preservation Recognizing the ongoing need to assist homeowners through Volunteerism our Neighborhood Preservation Initiative, we continue to support homebuyer education, counseling programs and Employee volunteerism and giving are playing a fnancial literacy in communities across the U.S. In 2011, signifcant role in our support of the communities in we delivered more than $41 million in grants and loans which we operate. We are particularly proud that our toward our three-year goal, beginning on January 1, 2010 and employees donated 1.5 million hours of service continuing through June 30, 2012, to provide $50 million in last year, exceeding the million hours of service grant and program-related investments in three key areas: given in 2010. A more comprehensive discussion of homeowner retention, transitional services and REO/ employee volunteerism can be found in preservation. Through this initiative, we provided 2,722,938 consumers with fnancial education and literacy materials in 2011, building off of our 2010 provisions to 3,187,707.
Disaster Relief neighborhood Housing Services of Phoenix (Phoenix, Arizona) In 2011, the bank and its employees provided critical We provided funding for operational support to deliver support and $2.94 million in funding to address major foreclosure prevention counseling, fnancial education disasters around the globe, focusing specifcally on those workshops, credit repair assistance and housing counseling that took the largest toll on communities we serve. to help fnancially distressed homeowners in Arizona. Bank of America committed 100 million yen ($1.22 million) Neighborhood Housing Services also received general to aid victims affected by the earthquake and tsunami in operating support and leadership training for its executives Japan. This included a 50 million yen grant to the American through our Neighborhood Builders program. Red Cross (ARC) to meet the immediate needs of survivors. We also engaged our customers by offering them an opportunity to donate through our banking centers, raising $600,000 in customer donations for the ARC Japan Earthquake Relief and Recovery. Bank of America employees contributed more than $574,000.
Within the U.S., one example of our disaster relief efforts in 2011 was a donation of $250,000 to support the American Red Cross Disaster Fund for the 2011 hurricane season, starting with their response to Hurricane Irene, which impacted states from North Carolina to Massachusetts. We are currently recognized as one of American Red Cross’s Annual Disaster Giving Partners, and we have developed a turnkey approach for activating donation collection in our banking centers to raise funds for the American Red Cross.
50 Strong Economies CASE STuDY: GIFT FOR OPPORTUNITY™ FUND
We are responding to community needs and illuminating important issues by engaging our customers and employees. As an example, we launched the Gift for Opportunity fund, which has tackled hunger $3.5 million in communities by extending the impact of customer donations in donations through a corporate match. In 2011, the program helped raise $3.5 million through individual and corporate donations, providing more than 26 million meals to the hungry. In addition, nearly 200 56,000 volunteer events were held in conjunction with the Gift for Opportunity fund in which employees invested more than 56,000 volunteer hours volunteer hours. Since 2009, we’ve provided more than $21 million in philanthropic support for hunger relief. THInkInG AHEAD
In 2012, we will continue to explore new opportunities to strengthen the communities we serve through strategic lending, investing and giving programs. We plan to:
•Continuetorespondtocriticalcommunityneedswiththe goal of advancing local economies •Offerouremployeesmeaningfulopportunitiestostrengthen the communities in which they live and work •ContinuetoleveragetheexpertiseofourNCACandother strategic community partners to strengthen our lending, investing and giving programs •Increasenewcredittosmallbusinesses,asweexpand our team of small business experts who are focused on assessing deposit, cash management and credit needs •Increaseourface-to-faceoutreachthroughmorethan 340 bank-sponsored homeowner events, including at least 40 bank-sponsored events, to provide counseling to more than 240,000 customers •StrengthenCustomerAssistanceCenters’impactonlocal community partners and improve on-site services, including increasing the number of decisions and resources related to alternatives to foreclosure •Advanceourcommunitystabilizationeffortsbydonating up to 2,000 properties, with a value of around $32 million, in 20 cities •ImplementtheU.S.FederalHousingFinanceAgency’s Housing Affordable Refnance Program (HARP) Phase II to better assist struggling homeowners with refnancing their home loans
In addition to the above, in February 2012, Bank of America agreed in principle to the terms of a global settlement with 49 U.S. state attorneys general, the United States Department of Justice and other U.S. federal agencies. This settlement is expected to allow additional relief to qualifed homeowners who are struggling to make mortgage payments, and it will make refnancing options available to more homeowners.
52 Strong Economies CHAPTER 6
Environmental Sustainability 5 | EnVIROnMEnTAL SuSTAInABILITY
We are working to fnance the transition to a lower-carbon future — managing our own efforts and helping customers and communities navigate the transition to a different type of economy built on more sustainable business practices.
We have long believed that business and environmental Transformational Finance objectives work hand in hand. In 2007, when we committed to a ten-year, $20 billion environmental business initiative We made substantial progress in 2011 on our $20 billion to address global climate change and demands on natural environmental initiative, as we committed more than resources, we put that belief into action. Our capital, $3.65 billion toward underwriting, advising on and fnancing capabilities and employees are being put to work to help a number of landmark transactions that are expected to fnance a new, lower-carbon economy, reduce our create thousands of jobs and help our clients move closer environmental footprint and promote environmentally to a lower-carbon economy. From providing clean-burning sustainable solutions around the world. Since 2007 we cookstoves to families in Mozambique, to fnancing two of have lent, invested, underwritten and advised on more than the largest distributed solar projects in U.S. history, we are $17 billion toward the initiative — putting us far ahead of demonstrating the many ways we are supporting a transition schedule. While we are very proud of this business success, to cleaner, sustainable energy sources. Learn more at our our activities are signifcantly broader — encompassing four website. core areas of focus: •TransformationalFinance Solar investments •Operations Through ProjectAmp, the largest distributed rooftop solar- •EmployeeProgramsandNonprofitPartnerships generation project in the world, and Project SolarStrong, •GovernanceandPolicies the largest residential solar-power project of its kind, we are making groundbreaking steps toward transforming the marketplace for solar energy systems.
Lines of Business Added to Our Initiative Additionally, we worked with our client, European-based Each line of business at Bank of America adheres to private equity frm Terra Firma Capital Partners Ltd., in disciplined reporting and analysis procedures in order to its acquisition of Rete Rinnovabile S.r.l. (RTR), a solar qualify a transaction under the stringent criteria for our photovoltaic generation business. This marked the $20 billion environmental business initiative. Through a largest solar-generation acquisition in Europe. combination of better communication, improved data collection and clarifed reporting standards, additional lines of business including Dealer Financial Services, Public Finance and Commercial and Corporate Banking identifed nearly $3 billion in new transactions that have contributed to our commitment since 2007.
54 Environmental Sustainability ENVIRONMENTAL BUSINESS INITIATIVE
SUCCESS TOWARD 10-YEAR, $20 BILLION ENVIRONMENTAL BUSINESS INITIATIVE TO ADDRESS GLOBAL CLIMATE CHANGE
2007–2011 10-Year Goal Total: $17.2 Billion $20 Billion
$2.6 $2.3 $3.6 $5.0 $3.7 2007 2008 2009 2010 2011
BY LINE OF BUSINESS (2007–2011)
COMMERCIAL REAL ESTATE BANKING (CREB) ÿnances projects with LEED and ENERGY STAR certiÿcation, brownÿeld redevelopment and use of renewable-energy tax credits
$5.6 GLOBAL INVESTMENT BANKING (GIB) Billion provides equity and debt capital and advisory services to lower-carbon companies and activities
LEASING provides equipment ÿnancing for energy-efÿciency projects and renewable-energy projects in solar, wind, biomass and biofuel technologies for both utilities and end users
PUBLIC FINANCE $4.3 delivers project ÿnance for municipal renewable-energy projects Billion
DEALER FINANCIAL SERVICES (DFS) provides loans for hybrid vehicle purchases $3.5 Billion GLOBAL COMMERCIAL/CORPORATE BANKING (GC/CB) extends lending and credit to lower-carbon companies
STRATEGIC ENVIRONMENTAL INVESTMENTS (SEI) places private equity in companies addressing climate change
CORPORATE WORKPLACE (CW) initiates workplace energy and resource efÿciency activities for Bank of America facilities and LEED® certiÿcation for all new construction of ofÿce facilities and banking centers $1.4 Billion COMMODITIES $861 invests in transactions that ÿnance emissions Million reductions through the global carbon markets $690 Million PHILANTHROPY* supports nonproÿts focused on climate $275 change and other environmental Million $245 opportunities Million $200 Million $37.1 Million
*Environmental philanthropic grants may also align with other issue categories. LOWER-CARBOn ECOnOMY BuSInESS ACTIVITY Carbon Markets Already a carbon market leader outside of the U.S., this year Sector Investment we entered the California market, which is poised to become the second-largest carbon market in the world. Through a Energy Effciency $8.3 Billion multi-million-dollar carbon offset agreement with TerraPass Renewable and Other Lower-Carbon Energy Inc., a company that brings verifed carbon offsets to market and manages national carbon reduction projects, we are able Wind $1.4 Billion to offer our clients integrated solutions to address their new Solar $1.2 Billion California emissions compliance obligations.
Hydro $911 Million Energy Effciency *Mixed Renewables $837 Million Providing capital that helps reduce energy consumption, and therefore carbon emissions, has been an ongoing BioMass/BioFuel/ $5.8 Billion $359 Million Methane Recovery effort at Bank of America. This year, we announced a $55 million Energy Effciency Finance Program to encourage Geothermal $45 Million improvements to older buildings in low-income communities. Fuel Cell $18 Million This program provides low-cost loans and grants to nine Community Development Financial Institutions that specialize Nuclear $1.1 Billion in fnancing much-needed energy-effciency upgrades that will Hybrid Cars $860 Million help save energy and money for homeowners and building owners in markets across the U.S. Brownfeld Redevelopment $729 Million Hybrid Vehicle finance Forestry $543 Million Our Dealer Financial Services group has lent customers **Other $488 Million more than $861 million to help them purchase carbon- and fuel-saving hybrid and electric vehicles. This commitment to * Mixed — Companies that fnance a mix consumer lending has helped fuel the industry and advance of renewable energy (solar, wind, hydro) vehicle sales. ** Other — Includes battery storage, water purifcation, etc.
Innovative Environmental Investing
In addition to transactions we have completed under our $20 billion environmental initiative, we are creating opportunities for individuals and institutions to invest in environmental sustainability through our new Socially Innovative Investing Strategy, which was launched in 2011 by our U.S. Trust Private Wealth Management group.
56 Environmental Sustainability CASE STuDY: A TRANSFORMATIVE USE OF CARBON FINANCE IN AFRICA
Nearly half the world continues to cook with solid fuels such sustainably sourced cooking fuel that will replace thousands as dung, wood, agricultural residues and coal. According to of hazardous and polluting charcoal-burning cookstoves. the World Health Organization, the use of these solid fuels We have an option to purchase and market millions of CERs for cooking and heating is one of the largest sources of (each representing one ton of CO2e reduced) that will be indoor air pollution on a global scale. In particular, the indoor generated in Mozambique and other countries in sub-Saharan smoke from charcoal cookstoves produces toxic pollutants Africa where clean cooking fuel will replace charcoal. The that are linked to a number of debilitating health problems, carbon fnance revenues received by Clean Star will be used including acute lower respiratory infections in young children, to subsidize the upfront cost and ongoing warranty for clean chronic obstructive pulmonary disease and lung cancer. cookstoves, technology that would otherwise be too expensive for low-income consumers in Africa. To help address this issue in Mozambique, Bank of America Merrill Lynch Commodities entered into a certifed emissions In addition to safeguarding lives from dangerous charcoal reduction (CER) fnancing agreement with Clean Star smoke, this joint venture aims to signifcantly increase Ventures and Novozymes, the global leader in bioinnovation, farmers’ incomes, save thousands of acres of forest every to establish a unique food-energy business to serve Maputo, year and dramatically reduce greenhouse gas emissions. the country’s capital. This venture will offer consumers affordable, clean cooking stoves together with a new, Operations
As a global company with operations in more than 40 In conjunction with our GHG and energy-reduction efforts, this countries, we believe it is our responsibility to drive energy year we also: effciency and resource conservation within our daily operations. Reducing our emissions and use of natural •ExpandedthetotalleadershipinLEED-certifiedspace resources lessens our environmental footprint, enhances to 16 percent of our total workspace. In 2011, the bank our effciency and delivers tremendous value for our expanded its Leadership in Energy and Environmental company and shareholders. Learn more at our website. Design (LEED)-certifed space occupied by more than 5.1 million square feet, including 49 new LEED-certifed Greenhouse gas reductions and energy effciency projects by Bank of America (and our frst LEED data As with most companies, the vast majority (90 percent) of center) and 13 initiated by our landlords at facilities in the our greenhouse gas (GHG) emissions comes from energy U.S., South Korea, Taiwan and Costa Rica. Created by the consumption, so efforts to reduce both are closely linked. U.S. Green Building Council, LEED is a globally recognized In 2011, we set an ambitious new goal to reduce our GHG standard for certifying the environmental performance of emissions by 15 percent from 2011 to 2015, based on a a building. Our goal is to have 20 percent of our corporate 2010 baseline. Having reduced our GHG emissions by 18 workspace portfolio LEED-certifed by 2015. percent between 2004 and 2009 under a prior goal, this industry-leading target puts our company on the path of Additionally, Bank of America earned precertifcation in the reducing overall GHG emissions by more than 30 percent LEED Volume Program for Operations and Maintenance. over 2004 levels — that means eliminating 700,000 Based on LEED 2009 for Existing Buildings: Operations
metric tons of CO2-equivalent. In 2011, we achieved a & Maintenance, our program creates a uniform set of seven-percent reduction in GHG emissions, compared to standards for verifying environmental performance at 2010. participating sites, while streamlining the certifcation process, which saves us both time and money. In 2011, we invested more than $3.5 million in energy- effciency projects, contributing to a cost savings of •Remainedcommittedtotransparencyinourcorporate $7.9 million in the same year. Effciency opportunities were carbon reporting. Bank of America has developed identifed through our engineering teams, on-site energy relationships with organizations such as Ceres, the audits and a proprietary, facility-level energy performance Center for Climate and Energy Solutions, and the Carbon scoring system. These effciency projects included low- and Disclosure Project (CDP) to support our progress in no-cost operational improvements such as turning off idle tracking, benchmarking and reporting efforts. equipment, improved maintenance and optimizing cold-air delivery to computer rooms. •Thisyear,ourCDPresponsescored97outofapossible 100 points for completeness of disclosure and achieved Since 2004, we have reduced electricity costs by more than the highest rank possible for emissions performance. As a 14 percent in banking facilities and 18 percent in offce result, Bank of America was the top-ranked global fnancial buildings, driving the signifcant reduction in our carbon services company and ranked fourth across all sectors in footprint and contributing to a cumulative cost savings of CDP’s Global 500 Report. CDP ranked Bank of America $195 million. frst among fnancial service companies and second among all of the largest U.S. companies in its S&P 500 Report.
•Additionalinformationabouttherecognitionandawards we received for our environmental efforts can be found in Chapter 10.
58 Environmental Sustainability URBAN CORPS Bank of America is proud to support San Diego’s Urban Corps as they work to provide young adults with a high school education and job training in conservation and recycling. With this support, these young adults gain the knowledge and life skills they need to succeed.
Waste Because we recognize the environmental impact associated more effciently disposing of it, which improves our overall with waste, we expanded recycling services at our buildings waste management capabilities. Waste and recycling and made improvements in tracking and reporting of program enhancements in the U.S. alone resulted in workspace waste and recycling. By the end of the year, annualized cost avoidance of nearly $329,000 in 2011. recycling of plastic, aluminum and cardboard was available in over 71 million square feet of workspace — that’s 60 We also recognize that e-waste is particularly important for any percent of the owned and leased space we occupy globally service-based company, and we are committed to the disposal — up from 43 million square feet the year before. of e-waste through e-Steward certifed recyclers where possible. In 2011, we recycled 1,556 metric tons of e-waste from our By implementing an innovative waste-audit process at operations in the U.S., EMEA, Latin America and Canada. We our U.S. facilities, we are establishing ourselves as a also remarketed or refurbished and redeployed an additional corporate leader in better understanding our waste and 120 metric tons of electronic equipment.
Environmental Sustainability 59 Water Water usage is not traditionally viewed as a signifcant Internally, we advanced our paper reduction efforts through environmental impact for fnancial services companies. the deployment of print-tracking software to employee But with growing concerns over water availability in many desktop computers. With this reporting and management of Bank of America’s markets, it is an area the bank takes system in place, leaders were able to readily identify the very seriously. Over the last several years, we have worked greatest areas of consumption in their organizations and to more accurately determine our water usage and reduce initiate programs to address them. As a result, we reduced consumption wherever possible. In 2011, we completed a 1,526 metric tons of printed pages for the year, saving more two-year comprehensive inventory of our water consumption than $15 million. (our frst ever). The review found that we consumed 3.9 billion gallons of water in 2011, down from 4.2 billion As the bank’s business has improved over the past year, gallons in 2010. Many of our facilities employ water recycling our need to communicate with clients has also increased and reuse technologies. At 1 Bank of America Center in — from updating them on the new regulations impacting Charlotte, an on-site groundwater treatment system reduced our industry to sharing information about new products and our demand on city water by approximately 600,000 gallons services. However, as a result of the programs outlined in 2011. above and many more like them, we still reduced our paper consumption by more than one percent from 2010 to 2011. Paper We will continue to expand our conservation efforts in With the size of our operations and the myriad of ways we the coming years and aim to achieve even more use printed materials today, reducing our paper consumption signifcant reductions. is a large priority for the bank — it helps to protect the environment and lower GHG emissions, but it also Bank of America is not just focused on paper consumption, represents signifcant cost saving. but also its content and source. We purchase paper with recycled content where practical and feasible, and We continued to move toward digital operations by providing diligently monitor the sources of the paper we use (for opportunities for both our employees and our customers more information, please see our Paper Procurement Policy to reduce paper consumption. Through our enterprise-wide discussed in this chapter’s Governance and Policies section). Electronifcation of Paper (EoP) initiative, programs like Overall, as a result of these efforts, 9.4 percent by weight mail suppression; print monitoring and control; electronic of our copy and printer paper was recycled content and 99.7 payments; and image ATMs have prevented the use of percent of it met Bank of America’s requirement to source 12,492 metric tons of paper and, thus, the emissions of paper from sustainably managed forests. 36,022 metric tons of GHG. Supply Chain To reduce customer paper use across our businesses, our The supply chain represents a signifcant portion of any strategy includes everything from statement suppression company’s environmental footprint. Last year, we continued and electronic payments to our envelope-free-deposit to turn the spotlight on our supply chain to identify impacts image ATMs. We delivered more than 368 million digital and engage our suppliers and landlords in conversation correspondences through Online Banking and other about sustainability. Efforts to reduce impacts all along channels, and our ATMs eliminated nearly 1,500 metric tons our supply chain have been successful, and many of of envelopes. We also initiated delivery of our annual and our suppliers have begun or continued on their paths to corporate social responsibility reports electronically to sustainability as a result. Recognizing the importance of many stakeholders. these activities, we are proud to be a founding Supply Chain member of the Carbon Disclosure Project (CDP). Details can be found in Chapter 11.
60 Environmental Sustainability CHARLOTTE COMMONS Charlotte Commons is a working example of our commitment to improve energy effciency based on data and proven cost-effectiveness. By collecting metering information from our banking centers and analyzing it over time, we can decrease energy use, driving cost savings and reducing our carbon footprint.
Banking on Energy Effciency
As continued evidence that our sustainability goals align This energy model was utilized to analyze the impact of closely with operational effciencies, we teamed up with high-performance interior and exterior LED lighting, HVAC the U.S. Department of Energy (DOE) Pacifc Northwest systems, building automation systems and building material National Laboratory to improve market adoption of current upgrades. Charlotte Commons is the frst facility in our energy-saving technologies and produce real-world portfolio (and is one of the frst buildings anywhere) to be building-design solutions. entirely lit by LED lighting. We estimate the improvements selected for Charlotte Commons will lead to cost and energy Through the DOE Commercial Building Partnerships program, savings of close to 50 percent compared to a conventional we identifed and analyzed energy-saving measures for our building, saving our company nearly $7,000 a year at newly constructed, state-of-the-art Charlotte Commons this location. banking center in Punta Gorda, Florida. By installing more comprehensive metering at a comparable existing banking center nearby, a detailed energy model of the new banking center was developed.
Environmental Sustainability 61 Employee Programs and Nonproft Partnerships
Mobilizing our employees is essential to the success of our Ocean Conservancy environmental efforts. With a workforce that is almost equal Since 2002, we have partnered with Ocean Conservancy, to the population of St. Petersburg, Florida, our employees aligning our philanthropic giving with employee volunteerism have the power to make a positive environmental impact in support of the organization’s annual International Coastal on a big scale. We encourage them to act as environmental Cleanup. Enthusiastic turnout for this event continues to stewards at work, at home and in their communities by build — helping to make 2011 their most successful event providing a variety of educational opportunities, resources to date. In addition to providing Ocean Conservancy with and tools. a $250,000 grant from the Bank of America Charitable Foundation, our employees volunteered 3,079 hours and Engaging Employees contributed to the removal of more than 9.1 million pounds Our My Environment Ambassador program grew to a total of trash from beaches, lakes and waterways in the U.S., of 1,256 employee participants. By leading educational India, Hong Kong, Spain, Brazil, Costa Rica and the UK. sessions on LEED certifcation, recycling, energy conservation and sustainable transportation, as well as Employee Hybrid Vehicle Reimbursement Program a series of webcasts with subject-matter experts, we are An additional 870 U.S.-based employees participated in helping our employees understand environmental issues this program, which reimburses employees $3,000 on the and drive positive change. purchase of a hybrid, electric or compressed natural gas vehicle — bringing the total to 4,655 participants since the Our Environmental Ambassadors also play an active role launch of the program in 2006. By replacing conventionally in coordinating environmental volunteer programs. From powered vehicles, this year’s participants saved or avoided Hong Kong to Miami, our global workforce dedicated an estimated 1,382 tons in carbon emissions. On average, more than 48,000 volunteer hours to environmental these new cars are 20 miles per gallon more fuel-effcient activities this year. than the trade-ins. With rising gas prices, these employees are lowering their expenses while benefting the environment.
“I care about the environment because I want to keep our planet beautiful for my children and future generations. We all have a responsibility to take care of it. I am proud that Bank of America Merrill Lynch understands this responsibility and creates opportunities for me to improve the environment in my community.”
— Hilmarie Palarca, Team Leader, Bank of America Home Loans, Philippines
62 Environmental Sustainability CALIFORNIA ACADEMY OF SCIENCES Our grant helped the California Academy of Sciences expand its educational outreach to attract a wider audience for its natural history museum.
Environmental Philanthropy We recognize that the health of our company is dependent increase access to safe drinking water, sanitation and on the health of the communities we serve. As a result, we hygiene services for the residents of Musiri Block, a region invest in programs and partnerships that provide sustainable of Tamil Nadu, India. Funding allows Water.org to continue solutions to environmental challenges facing communities its work with SCOPE, their on-the-ground nonproft partner, around the world. which has set up a revolving-loan fund providing microloans to local residents to install water connections and construct Water.org toilets within their homes, as well as to educate the local According to Water.org, there are currently more than community on sanitation and hygiene. The grant also 120 million people in India who lack access to safe supports overall sanitation-education programs, which water, and more than 800 million do not have adequate include the installation of toilets and support for local sanitation. We are helping to address this issue by farmers to diminish dangerous agricultural runoff. providing Water.org with $450,000 in grant funding to
Environmental Sustainability 63 DUMONT GREEN By investing in affordable housing development, Bank of America is helping to revitalize communities across the United States. Developments like Dumont Green, an eight-story, environmentally friendly apartment building that provides a home for 176 low-income families in Brooklyn.
u.S. Green Building Council This year completed the frst round of a two-year, $500,000 The success of the frst round of the Affordable Green grant, funding, in part, the USGBC’s Affordable Green Neighborhoods Program has surpassed expectations, and as Neighborhood program. With this funding from the a result, Bank of America provided an additional $500,000 Bank of America Charitable Foundation, the USGBC was grant to fund this program’s growth through 2013. able to provide assistance to 10 affordable-housing redevelopment projects nationwide. Using a process This new grant will also create the Center for Green School’s centered on strong community involvement, each of the Community Green Program that will expand the USGBC grant recipients’ projects features the redevelopment and Student Program to the community college system. The revitalization of a previously income- and transit-separated program engages with students and staff members at neighborhood having badly outdated building stock, using a community colleges to help prepare graduates for region- process centered on strong community involvement. specifc jobs in the clean economy and connect them to future employers. In total, the grant recipient projects represent the creation of 4,741 rental units and 1,681 for-sale units all built to We continue to work and deepen our relationship with other the highest standards of environmental sustainability and philanthropy partners including The Nature Conservancy, indoor air quality, with 84% and 48% reserved for low-income National Wildlife Federation and Jobs for the Future (through residents, respectively. the Greenforce Initiative).
64 Environmental Sustainability nonproft Partnerships Partnering with groups that have in-depth knowledge of specifc environmental issues, global resources and Our environmental activities are overseen by our established events helps us to increase the impact of our Environmental Council, which sets environmental strategy, environmental efforts. Through participation in networks priorities and goals and ensures rigorous risk management and membership organizations, we are able to maintain to guide our progress. an ongoing dialogue with partners who help us better understand our key environmental and social impacts. Bank of America has strong environmental policies and due diligence processes in place across a wide range Access to energy affects everything from education, food, of environmental issues, in addition to comprehensive healthcare and security to economic stability. According to evaluations conducted by consultants and other outside the United Nations, one in fve people around the world lack experts. By working with clients in adherence to these access to modern energy. Developed countries also face policies, we can bring about positive environmental outcomes. signifcant energy challenges both today and into the future. Recognizing the impact this has on everything from local In implementing our policies, we regularly engage with clients economies to global business, Bank of America’s Chairman, to address environmental impacts that may be attributed Chad Holliday, agreed to cochair the United Nations to a client business or activity. In some cases, the bank Sustainable Energy for All, a multidisciplinary group of global will request a customer to take actions to address issues leaders across government, the private sector, academia and and minimize certain risks. These actions may range from civil society. The group is charged with developing an action cleaning up contaminated real estate for transactions plan toward three very interrelated goals: to ensure universal secured by real estate, to implementing environmental access to modern energy for all people; to double the rate management criteria for transactions that are aligned with of improvement in energy effciency; and to double the share higher-impact commercial or industrial operations. of renewable energy in the global energy mix — all by 2030. More detail on this action plan was made available in the For example, in 2011, Bank of America explored underwriting months leading up to and during the UN Rio+20 Conference a bond offering for a forestry sector client in an emerging in Brazil in June 2012. market. As a condition of our involvement, Bank of America required the client to use a portion of the proceeds to help Other organizations and academic partners we work with achieve forestry certifcation in compliance with a well- include Ceres; Center for Climate and Energy Solutions; recognized international forestry certifcation standard. Nicholas Institute for Environmental Policy Solutions, Duke The client was also required to disclose the forestry University; The Initiative for Global Environmental Leadership, certifcation plans to their investors. While the transaction The Wharton School of the University of Pennsylvania; and ultimately failed to close for other reasons not related to Center for Law, Energy & the Environment, UC-Berkeley Law & the environment, this is a good example of how we engage Emmett Center on Climate Change and the Environment and clients from high-impact sectors toward a positive result. UCLA Law. In addition, Bank of America remains committed to maintaining the Equator Principles and the Carbon Principles, and to regularly report on transactions that are reviewed under these Principles. In 2011, Bank of America had one transaction that was subject to the Equator Principles. The Category B project was in the oil and gas sector with a total project cost of U.S. $8.6 billion. There were no transactions considered by Bank of America in 2011 that were applicable to the Carbon Principles.
Environmental Sustainability 65 All of our environmental policies are available to provide Environmental Management System (EMS) transparency and clarity about our position on important Bank of America employs an EMS that utilizes a environmental issues. To learn more about our environmental comprehensive compliance database that helps Global governance and policies, go to http://environment. Workplace Environmental Risk to identify, manage and bankofamerica.com/policies-and-practices/index.html. mitigate risk and improve performance across our corporate real estate portfolio. The foundation of the EMS is our utility Portfolio Emissions stringent environmental policy that ensures a commitment to: Bank of America tracks and reports on the greenhouse gas emissions of its U.S. power utility loan portfolio. In our 1. Stringent compliance with applicable environmental laws latest reporting, we maintained lower attributed emissions and regulations in our portfolio compared to historical levels through two 2. Pollution prevention and environmentally sustainable primary factors: practices •ashiftinlendingawayfromsomeofthehighest-emitting 3. Continuous improvement in all areas of environmental companies in the portfolio and the addition of lower- management emitting companies; and •areductionintheemissionrateoftheothercompanies Our EMS covers all key areas including roles and remaining in the portfolio. responsibilities, training, inspections, inventory procedures, formal targets, documentation, measurement, complaint response, and emergency procedures. A core component EMISSIONS UTILITY PORTFOLIO of the EMS is Integrated Data for Environmental Applications (ID|ea), an online tool for bank employees and partners Tons C02 per MWH that provides the unique ability to understand and manage environmental compliance across the bank’s signifcant global real estate footprint. 0.733
We are very proud of our strong record of compliance across our signifcant real estate portfolio, a result of our rigorous 7% Reduction Target EMS. Environmental fnes paid by the bank decreased from 0.658 $23,584 in 2010 to $16,240 in 2011 — considered to be 0.638 0.634 a minimal amount given the size of our footprint.
0.581 0.580
2004 2005 2006 2007 2008 2009* 2010
PORTFOLIO YEAR
*Bank of America was unable to compile data for 2009. This chart shows an interpolation between 2008 and 2010.
66 Environmental Sustainability CASE STuDY: THE POWER OF SOLAR ENERGY
Photo credit: Land Lease.
Bank of America has used our size and global reach to help Upon full deployment, this vast, eco-friendly project will clients grow while positively changing the clean renewable- create thousands of jobs (many flled by U.S. veterans energy sector in the process. Working with our client, and military family members) and will eliminate more than SolarCity, we have launched the largest residential solar- 250,000 metric tons of carbon dioxide emissions annually. power project to date. Project SolarStrong is an example of Bank of America’s commitment to fnancing environmentally sustainable If fully deployed, Project SolarStrong is expected to create energy solutions as well as our commitment to supporting more than $1 billion in solar projects and up to 300 our local communities. Not only were we able to create a megawatts of new solar generation capacity through the blueprint that has the potential to transform the distributed installation of rooftop photovoltaic (PV) systems on up to solar market, but this project offers the added beneft 120,000 U.S. military base residences. “As a leader in of creating training and employment opportunities for full-service solar power, we are proud to be a partner in this thousands of military families and veterans. initiative, which marks a giant leap forward — providing the solar industry with a debt model that can make distributed generation affordable on a massive scale,” says Lyndon Rive, CEO of SolarCity. THInkInG AHEAD
We have ambitious goals in place across our four priority Specifc areas of focus include: areas that support our overall environmental commitment. We seek to identify opportunities to show and maintain our Energy effciency — in residential, commercial and public leadership in this space, and continue to ask how we can properties, as well as supporting the full supply chain that do more. Our focus in the year ahead will include: drives energy effciency. Renewable energy and energy infrastructure — including •Continuingtoworkwithclientstofinancethetransition wind, solar, hydro, biomass and waste-to-energy solutions to a new, lower-carbon economy. We will accelerate and their upstream and downstream supply chains, as the business we are already doing, while continuing to well as smart grid, large-scale energy storage and other engage new lines of business. important infrastructures. •Announcinganew$50billionenvironmentalbusiness Transportation — including certain lower-carbon forms goal to address climate change and demands on natural of transport, such as electric and hybrid-electric vehicles, resources, while helping to advance lower-carbon batteries/fuel cells and sustainable biofuels, as well as economic solutions. In addition, we are announcing a developing local and regional charging infrastructure to comprehensive suite of operational goals around our use support the growth of new hybrid-vehicle technologies. of waste, water and paper. Water and waste — focusing on innovative new •Evaluatingourenvironmentalpoliciestobecurrent technologies and infrastructure development, including water with the latest risk issues and developments in various purifcation and waste disposal and recycling. business sectors. •Broadeningenvironmentalemployeeengagement We will also continue to provide grants and program- programs. related investments to support nonproft organizations and other institutions promoting lower-carbon and resource Setting new Goals conservation solutions. Building on the anticipated completion of our current $20 billion environmental business initiative by the In addition, we are initiating new global operational goals end of 2012, we are announcing a new 10-year, around waste, water, paper and energy consumption, with $50 billion environmental business goal to address global plans to achieve them by 2015. environmental issues, reduce the environmental impact of our own operations, save money, produce revenue and create long-term economic value for our shareholders.
Effective January 1, 2013, this new business initiative will consist primarily of lending, equipment fnance, capital markets and advisory activity, carbon fnance, and advice and investment solutions for our clients.
68 Environmental Sustainability What you need to know about our data
At Bank of America, we continually strive to expand and strengthen our reporting on key sustainability indicators. If we fnd inconcistencies or errors during the process of auditing or reviewing our data, we will report that, too. We believe this is a key part of the bank’s commitment to transparency and accountability. With all of this in mind, here are some important things to know about our 2011 data:
In 2010, we established new baselines for our global As mentioned earlier in this chapter, throughout the year, operations that included the acquisitions of Countrywide and we implemented enhanced waste-diversion programs and Merrill Lynch. In many respects, 2011 represents our frst improved overall waste-data reporting. This comprehensive year of benchmarking against those new baselines. refnement of our reporting process allows us to more accurately report our 2011 total waste and diversion data. This year’s data table refects the addition of several Due to these adjustments and the limitations of our 2010 metrics reported for the frst time, such as global water waste-data set, 2010 data are no longer comparable to consumption; global energy consumption by fuel source; 2011 waste fgures, and will therefore not be included in NOx, SOx and other signifcant air emissions from our data table. direct combustion; and expanded information about our Electronifcation of Paper efforts. In addition, in response to Additionally, our 2010 GHG emissions and energy requests by various stakeholders, we have now broken out consumption fgures have been modestly adjusted to refect our Scope 1 and 2 GHG emissions for 17 countries around the sale of First Republic and the inclusion of additional the globe that make up 99.6% of our emissions. facilities for which we did not previously have data. It also refects improved property data quality and updated We also have made adjustments to some data points for information about the amount of greenhouse gas emissions 2010, due in large part to our deeper evaluation for our contained in all of our fuel sources. As a result of these combined organizations required to create new baselines. adjustments, our GHG emissions for 2010 were actually less than originally reported: 1,831,852 metric tons of
CO2 versus the 1,872,212 metric tons reported in last year’s report. Greenhouse Gas Emissions units Region 2010 2011
US 105,267 100,627
Scope 1 Direct Emissions Metric tons CO2e Non-US 15,076 9,378
Total 120,343 110,005
US 1,505,844 1,400,838
Scope 2 Indirect Emissions Metric tons CO2e Non-US 205,664 199,047
Total 1,711,509 1,599,885
US 1,611,111 1,501,465
Total Scope 1 and 2 Emissions Metric tons CO2e Non-US 220,740 208,425
Total 1,831,852 1,709,890
Reductions from Renewable Metric tons CO e Global 24,552 10,310 Energy Credits 2
Net Emissions Metric tons CO2e Global 1,807,300 1,699,581
Reduction in Scope 1 and 2 Percent reduction — Global N/A 7% Emissions year over year
Scope 3 Indirect Emissions
Employee Commuting Metric tons CO2e Global 719,532 538,578
Business Travel Metric tons CO2e Global 214,190 217,228
Check Couriers and Armored Cars Metric tons CO2e Global 49,809 50,576
Other Contracted Transportation Metric tons CO2e Global 6,615 5,256
Lifecycle Emissions from Waste Disposal*
Traditional Disposal Metric tons CO2e Global N/A 61,937
Recycling and Composting Metric tons CO2e Global N/A (285,346)
* Emissions from waste are calculated using the U.S. EPA’s Waste Reduction Model (WARM), version 11, August 2010. This model calculates emissions based on a life-cycle analysis, such as emissions from the long-term decomposition of waste in a landfll. As such, these emissions should not be added to or subtracted from any annual emissions source.
70 Environmental Sustainability GREENHOUSE GAS EMISSIONS BY COUNTRY IN 2011
Total Scope 1 and 2 Emissions
In Metric Tons CO2e
1. United States 18. Rest of World 1,501,465 7,269 10. Canada 12. Russia 1,832 2. United Kingdom 793 86,717
13. Germany 399 4. China 12,824
5. Japan 7,884
8. Ireland 3,585
6. Southeast Asia 7,851
14. Italy 396 11. Mexico 1,663
3. India 70,099
16. France 17. Saudi Arabia 7. Australia 93 50 4,100 15. Brazil 232 9. South Africa 2,638
Country Scope 1 Direct Scope 2 Indirect Country Scope 1 Direct Scope 2 Indirect
(Metric tons CO2e) (Metric tons CO2e) (Metric tons CO2e) (Metric tons CO2e)
1. United States 100,627 1,400,838 10. Canada 142 1,690 2. United Kingdom 5,853 80,864 11. Mexico 17 1,646 3. India 1,552 68,547 12. Russia 204 589 4. China 159 12,665 13. Germany 10 388 5. Japan 120 7,765 14. Italy 7 389 6. Southeast Asia 122 7,728 15. Brazil 20 213 Thailand, Singapore, Indonesia, Malaysia and Philippines 16. France 5 88 7. Australia 22 4,078 17. Saudi Arabia 1 49 8. Ireland 578 3,006 18. Rest of World 543 6,726 9. South Africa 23 2,616
Environmental Sustainability 71 nOx, SOx and Other Signifcant Air Emissions units Region 2010 2011 from Direct Combustion US 17 17
SOx Metric tons Non-US 1.3 2.5
Total 18 20
US 41 39
NOx Metric tons Non-US 7.1 3.8
Total 48 43
US 51 49
CO Metric tons Non-US 6.8 4.6
Total 58 54
US 6.7 6.4
PM Metric tons Non-US 1.1 0.6
Total 7.8 7.0
US 3.5 3.4
VOCs Metric tons Non-US 0.5 0.3
Total 4.0 3.7
Direct and Indirect units Region 2010 2011 Energy Consumption
US 10,772,586 10,020,883
Electricity Gigajoules Non-US 1,358,042 1,284,430
Total 12,130,629 11,305,313
US 262,156 265,972 Other Indirect Gigajoules Non-US 22,135 22,135 (Purchased Steam and Cooling) Total 284,291 288,108
US 1,336,230 1,286,856
Natural Gas Gigajoules Non-US 164,009 121,024
Total 1,500,238 1,407,879
US 303,202 284,036 Other Direct (Fuel Oil, Jet Fuel, Gigajoules Non-US 83,453 33,531 Gasoline, Diesel Fuel, Propane) Total 386,655 317,567
72 Environmental Sustainability INDIRECT ENERGY % CONSUMPTION INDIRECT ENERGY CONSUMPTION BY FUEL MIX (2011) — GLOBAL BY PRIMARY FUEL SOURCE (2011) — GLOBAL
Coal Petroleum Natural Gas Nuclear Renewable Coal Petroleum Natural Gas
(in gigajoules) 8% 12,348,814
35% 757,756 24% 8,071,500
3% These data represent total source energy consumed 30% to produce the intermediate energy (electricity, steam, chilled water) used.
facilities units 2010 2011
Net SF 13,200,000 18,300,000 LEED Certifcations % of Total Workplace 10% 16%
Metric tons purchased 530 2,136 Carpet % recycled input materials 39% 48%
Million SF of Space Cleaned Environmentally Sustainable Cleaning 77 78 using Qualifying Products
Compliance Region units 2010 2011
Fines and non-monetary sanctions Global Value of Monetary Fines $23,854 $16,240 for non-compliance with environmental Non-Monetary Notice Global 9 19 regulations of Violations
Global Number 2 2 Number and volume of reportable spills Global Total Volume — Gallons 3 1,340
Transportation units 2010 2011
Employee Commuting Annual Miles Traveled 1,962,652,062 1,516,150,982
New Participants 669 842 Hybrid Vehicle Reimbursement Metric tons of CO e avoided by Program 2 771 1,254 new participants
Environmental Sustainability 73 Paper — Global units 2010 2011
Total usage (Metric tons) 64,765 64,072
Global Paper % Recycled Input Materials by Weight 8% 10%
% FSC- or SF-Certifed Input Materials by Weight N/A 97%
Electronifcation of Paper units 2010 2011
Metric tons of Paper Avoided 5,280 8,430 Suppression
Metric tons of CO2e Avoided 14,296 24,312 Metric tons of Paper Avoided 1,032 1,052 Electronic Payment
Metric tons of CO2e Avoided 2,794 3,032
Metric tons of Paper Avoided 0† 1,526 Print Monitoring and Control
Metric tons of CO2e Avoided 0† 4,398
Metric tons of Paper Avoided 1,361 1,485 Image ATM Envelope Elimination
Metric tons of CO2e Avoided 3,922 4,280
†Print Monitoring and Controls initiative was implemented in stages, beginning in the second half of 2010, with 2011 being the frst entire year that could be measured and reported.
Water Consumption — Global units 2010 2011
Water Consumption Billion Gallons 4.17 3.88
Water Consumption Million cubic meters 15.8 14.7
Waste — Global units Disposal Method 2011
Nonhazardous Waste Metric tons Landfll & Incineration 59,083
Nonhazardous Waste Metric tons Recycling & Compost 87,788
Nonhazardous Waste % Diverted 60%
Hazardous, Universal, Used Oil Metric tons Landfll & Incineration 443 and Asbestos Waste
Hazardous, Universal, Used Oil Recycling, Reuse & Metric tons 233 and Asbestos Waste Salvage
Hazardous, Universal, Used Oil % Diverted 34% and Asbestos Waste
Total Waste Metric tons Landfll & Incineration 59,526
Total Waste Metric tons Recycling & Compost 88,021
Total Waste % Diverted 60%
74 Environmental Sustainability CHAPTER 7 Leadership & Service 7 | LEADERSHIP & SERVICE
We have a long-standing commitment to global leadership development of individuals and organizations that advance economies and society. Our employees worldwide play a critical role in contributing to communities through volunteer service.
Fostering leadership development and service across our offces around the world helps to empower community leaders and partners to more effectively address the community challenges. Our efforts may be viewed through our support to our nonproft partners and our employee volunteerism and giving programs.
76 Leadership & Service Investing in Leadership and Service
Since 2004, Bank of America has invested more than development has helped nonprofts deliver better results $150 million to provide local nonproft organizations and in their community. community leaders with the tools and resources critical to advancing their communities. We understand the importance of empowering future leaders. In 2011, we recognized 230 community-minded high school Through our signature philanthropic program, students as Student Leaders®, providing them with a paid neighborhood Builders®, we are enabling nonprofts to nonproft summer internship at a local nonproft and reach more individuals and families in need through a participation in a leadership summit in Washington, D.C., unique combination of funding and leadership development. offering young people the opportunity to gain valuable More than 90 nonprofts were recognized as Neighborhood workforce experience supports our broader efforts to build a Builders in 2011, and since 2004 the program has reached knowledgeable and skilled future workforce. We’ve recognized more than 1,200 executive directors and emerging leaders more than 1,600 students as Student Leaders since 2004. from nearly 600 nonprofts. In 2011, the program was recognized by nonproft advisory organization the Bridgespan In 2011, we also strengthened the Asia 21 Young Leaders Group as the largest U.S. investment in nonproft leadership Initiative and brought together more than 150 Young Leaders development. More importantly, Bridgespan found that the fellows and delegates from Asia and the U.S. for the Asia combination of fexible funding paired with leadership 21 Young Leaders Summit.
CASE STuDY: JUMA VENTURES
In 2007, we recognized Juma Ventures, a San Francisco- Most importantly, the funds enabled Juma to expand its based nonproft organization that empowers reach and replicate successful programs by moving into impoverished youth to successfully transition to higher two new cities and partnering with seven other youth- education and independence in adulthood, with a supporting agencies. The results speak to the success Neighborhood Builder award. The award has extended of more robust programs: 100% of the youth in the the reach of Juma Ventures, enabling it to increase its workforce development program were placed in jobs, organizational capacity. This included the addition of new and 90% of those in the college readiness program leadership team members, who have strengthened entered college. critical aspects of the organization’s operations such as human resource management, technology infrastructure and fundraising initiatives.
Leadership & Service 77 Creating Impact through nonproft Partnerships One of the ways we support local leadership and service is $24 million pledged during last fall’s United Way Campaign through philanthropic investments in a range of local, national — more than exceeding our $20 million campaign goal. and regional partnerships that work together to achieve Overall, through employee generosity and company greater impact. For example, we have committed more than investments, we have raised more than $474 million through $10 million annually to United Way Worldwide, our largest the United Way Campaign since 1999 and supported more philanthropic partner. In addition to corporate giving, our than 700 local United Ways. employees generously support critical needs, with more than
In 2011, some examples of grants include:
Organization Investment focus COMMunITY DEVELOPMEnT
To help develop, fnance and operate an additional 60,000 Mercy Housing $375,000 affordable multifamily homes between 2010 and 2014.
Broad support for the continued creation and preservation of affordable housing opportunities, as well as investment in Neighborhood Reinvestment Corp. $1 million capacity-building and leadership development of affordable- housing nonproft organizations.
WORkfORCE DEVELOPMEnT/EDuCATIOn
To connect veterans to workforce development training and Wounded Warrior Project $250,000 fnancial readiness through awareness programs, coaching and workshops.
To help train other nonprofts to develop sustainable social REDF (Roberts Enterprise enterprises that will place hard-to-employ individuals, who have $500,000 Development Fund) been homeless, incarcerated, addicted, or have a mental illness, into the workforce.
To provide learning programs to connect high-need middle-school Citizens Schools $1 million over two years students with future college and career opportunities through volunteer-driven apprenticeships.
CRITICAL nEEDS
To support the Houston Food Bank’s operations by providing Houston Food Bank $100,000 grant funding and leadership development training for its staff.
To support outreach to individuals who may be eligible for Feeding America $2.5 million SNAP (formerly the food stamp program) outreach and help give meals to those in need.
78 Leadership & Service Our philanthropic efforts are part of our broader CSR commitments. For example, we provide environmental philanthropic grants that support our $20 billion Impact of our 2011 Global environmental business initiative. We support the U.S. Giving and Volunteerism: Green Building Council, and by funding of its Affordable Green Neighborhood program, we have helped provide •Costa Rica, Hong kong, India, Spain, the u.S. assistance to 10 affordable-housing redevelopment projects and the uk — Employees volunteered 3,079 nationwide, representing the creation of 4,741 rental units hours with the Ocean Conservancy to clear 9.1 million pounds of trash from beaches and and 1,681 for-sale units all built to the highest standards of waterways during September’s Coastal Clean Up. environmental sustainability and indoor air quality, with 84% and 48% reserved for low-income residents respectively. · Chile, Costa Rica, India, Thailand and the u.S. Based on this program’s success, we are funding its growth — Employees volunteered more than 20,000 through 2013, including the creation of the Center for Green hours with Habitat for Humanity, helping to School’s Community Green Program, which engages students build housing for 44 working families in 2011. and staff at community colleges to help prepare for jobs in the clean economy.
CASE STuDY: TOWER HAMLETS EDUCATION BUSINESS PARTNERSHIP
In 2005, Tower Hamlets Education Business Partnership The success of the program is clear — we have had over and Bank of America Merrill Lynch launched the Financial 4,500 students and 2,000 employees participate since Education and Employability Programme in three Tower 2005. We have seen test scores increase — GCSE Hamlets secondary schools: Bow, Mulberry and Swanlea. grades, including English and Math, have increased by The frst and largest of its kind in the UK, the program 78% (Swanlea School), 15% (Mulberry School) and 52% comprises a range of activities designed to improve (Bow School) against a national average of 18% since students’ knowledge, skills and attitudes to help them 2005. Both Swanlea and Mulberry Schools have achieved prepare for the modern workplace. And, it is an opportunity “Outstanding” Ofsted reports. Perhaps most exciting is for our employees to volunteer their time and talent. that the program has now been extended to include a module for primary schools.
Leadership & Service 79 Volunteerism EMPLOYEE ENGAGEMENT Our employees champion our commitment to strengthening TOTAL EMPLOYEE VOLUNTEER HOURS communities. Their efforts align with the bank’s philanthropic priorities, including in the U.S., housing, hunger and job-training programs. Employee volunteer 800,000 1.3 Million 1.5 Million hours rose by 15% from 1.3 million in 2010 to 1.5 million Hours Hours Hours in 2011. This record achievement was driven by our 2009 2010 2011 leadership’s commitment to the program, line of business engagement, call to action to volunteer and strategic partnerships that provided local opportunities. VOLUNTEER HOURS BY GIVING AREA
General Community Support Employee Donations/Matching Gifts To further the impact of our employees, the Bank of America 534,144 Charitable Foundation has continued to award volunteer Education/Youth Development grants and offer its matching gift program. In 2011, our 455,647 employees contributed more than $25 million in donations Health & Human Services to support nonproft organizations, which in conjunction with 247,666 donations through the company’s matching gift program, resulted in more than $50 million of impact. Arts & Culture 108,282 Community Development/Neighborhood Preservation 80,965
Environment 48,352
Financial Education 24,944
“What an absolute joy it was for me to don my red volunteer shirt and go back to volunteer at the very shelter that I once occupied! It is an amazing feeling to have the frsthand knowledge of the impact that our local shelters have on our communities and the impact that we have on them.”
— Allen Pickett, Consumer and Small Business Banking, U.S.
80 Leadership & Service Leadership & Service 81 “By partnering with global initiatives such as Asia 21, Bank of America can leverage its resources to encourage and support young leaders from across sectors, including social enterprise, nonproft, media, economics and arts, to enable a better and brighter future for business, politics and civil society in Asia.”
— Kaku Nakhate, Bank of America Merrill Lynch’s President and Country Head for India
THInkInG AHEAD
In 2012, we will continue to explore new opportunities to strengthen the communities we serve through strategic leadership development and service programs. We plan to: •Lookforinnovativewaystopromoteleadershipdevelopment in response to challenges in our communities •Illuminatepressingissuesinourcommunitiesandoffer local leaders and organizations meaningful opportunities to be part of the solution •Continuetostrengthenemployeevolunteeropportunities •Engageemployeesthroughskills-basedvolunteeractivities, including support of board service and fnancial education
82 Leadership & Service CHAPTER 8 Arts & Culture 8 | ARTS & CuLTuRE
We are committed to a diverse program of cultural support — enriching society, helping arts organizations thrive, and promoting cultural understanding through the arts.
Our commitment to the arts is based on the belief that Enable a thriving arts and culture sector benefts societies and economies. Beyond intrinsic beauty, arts and culture can Enabling great arts organizations to serve spur urban renewal, attract new businesses, draw tourism their communities and spark innovation. It is a powerful industry that educates, promotes creativity, elevates our cultural understanding and We provide fnancial support to a wide range of organizations generates economic growth around the world. around the world, from local, community-based arts outreach and education programs to leading, world-class arts institutions. Bank of America is one of the leading corporate supporters of the arts, helping to strengthen thousands of art and Museums on us® cultural organizations around the world. Our diverse program Last year marked the 14th season of our signature of cultural support is designed to engage individuals, Museums on Us program, offering Bank of America and organizations, communities and cultures in creative ways to Merrill Lynch debit and/or credit cardholders the opportunity build mutual respect and understanding; to strengthen to visit great U.S. national and regional art museums, science institutions that contribute to local economies; to engage and history museums, zoos, aquariums and gardens during and provide benefts to our employees, and to fulfll our the frst weekend of each month. In 2011 we expanded the responsibilities as a major corporation with global reach and program to include 150 of the greatest American cultural and making an impact on economies and societies throughout educational institutions. Additions in 2011 included the Indian the world. Learn more at our website. Pueblo Cultural Center in Albuquerque, NM and the Great Lakes Science Center in Cleveland, OH. Our program is built around three main pillars: Enable, Share and Preserve. Sydney Theatre Company Sydney Theatre Company (STC) is one of the many arts organizations to which Bank of America provides ongoing support. Established in 1978, STC is a pillar of the Sydney community and presents an annual 12-play program of Australian plays, lively interpretations of the classic repertoire and the best of new international writing. Current Artistic Directors Cate Blanchett and Andrew Upton joined the Company at the beginning of 2008.
84 Arts & Culture ART INSTITUTE OF CHICAGO Through our Museums on Us program, the Art Institute of Chicago helps inspire and educate art lovers through its world- class collection for free.
Arts & Culture 85 CASE STuDY: CHICAGO SYMPHONY ORCHESTRA
Bank of America is building on its record as one of the Bank of America’s sponsorship began at a very special largest corporate supporters of the arts by expanding its time–whenrenownedconductorRiccardoMutibegan programming to new markets around the world. In 2009, his tenure as the CSO’s music director, and cellist Yo-Yo Bank of America became the frst-ever global sponsor of Ma took on a new role as CSO’s Judson and Joyce Green the Chicago Symphony Orchestra (CSO). This orchestra, Creative Consultant. The bank’s support has encouraged long renowned as the one of the world’s fnest, performs Maestro Muti and Yo-Yo Ma to act as inspirational not only in Chicago, but also tours throughout the world. catalysts for the Chicago community, advocating for the Our support enables the orchestra to deliver tremendous transformative power that music can have on individuals, benefts to the Chicago community, while also traveling regardless of age or socioeconomic background. to different cities around the world, acting as a cultural diplomat for the United States through the universal language of music. Share Sharing great works for art from our collection
Through our Arts in Our Communities® program, we have converted our own art collection into a unique resource from which museums and nonproft galleries may borrow complete or customized exhibitions at no cost, helping them generate vital revenue for institutions. Since the program’s launch in 2008, we have loaned complete exhibitions to more than 50 museums around the world, allowing them to deliver new experiences while creating traffc and excitement for their institution.
The Art Books of Henri Matisse (Chester Beatty Library, Dublin, Ireland) One of the exhibitions of Arts in Our Communities in 2011 was The Art Books of Henri Matisse, displayed in the Chester Beatty Library in Dublin, Ireland from May through September. Starting in the 1930s, Matisse, one of the preeminent artists of the twentieth century, began devoting much of his time to book illustration. Over two decades, Matisse illustrated 12 books. RobertSpencer(American,1879–1931) This exhibition displayed works from four of them: Poésies de Afternoon Bathers, ca. 1920 Oil on linen Stéphane Mallarmé, Pasiphaé—Chant de Minos, Jazz, and 29 1/2” x 35 1/2” Poèmes de Charles d’Orléans. During this exhibition, the museum experienced twice its normal attendance.
Conversations: Photography from the Bank of America Collection (Museum of Fine Arts, Boston) One of the landmark exhibitions of Arts in Our Communities in 2011 was Conversations: Photography from the Bank of America Collection, displayed in the Museum of Fine Arts in Boston, MA from February through June. The exhibition featured nearly 100 photographs from our collection grouped by broad themes — portraits, still lifes, landscapes, documentary images, street photography and experimental abstractions — to create visual conversations between photographs exhibited side by side. This show was so successful that additional museums asked to WilliamEggleston(American,1939–) borrow it. The exhibition has been on display at the Museo del Untitled (Memphis) 1970 Dye-transfer print Novecento in Milan and the Irish Museum of Modern Art in Dublin. 16” x 20”
Arts & Culture 87 WINSPEAR OPERA HOUSE Our investment in two new performing arts spaces—the Wyly Theatre and the Winspear Opera House—is helping to support the vibrant Dallas Arts District.
88 Arts & Culture Preserve Preserving works of art for future generations
We support the restoration of paintings, sculptures, “By providing support for the archaeological or architectural pieces that are signifcant to the cultural heritage of a country or region or important preservation of cultural treasures to the history of art. of many nations, our company is expressing our respect for cultures Bank of America Art Conservation Project and traditions around the world.” Works of art can provide a lasting refection of peoples and cultures, but, over time, they are subject to deterioration and even loss. The Bank of America Art Conservation — Rena De Sisto, Global Arts and Culture Executive Project provides grants to nonproft museums throughout the world to conserve historically or culturally signifcant works of art that are in danger of degeneration. The program, introduced in 2010 in Europe, the Middle East and Africa, has contributed to the conservation of works ranging from Winged Victory of Samothrace at the Louvre to Ndebele beaded aprons at the Wits Art Museum in Johannesburg. In 2011 we expanded the program, seeking applications from nonproft arts organizations in the United States, Europe, the Middle East, Africa and Asia Pacifc.
Arts & Culture 89 THInkInG AHEAD
We will continue and expand our support of arts and culture in 2012 through our Enable, Share and Preserve approach.
Enable: In addition to continuing our support for our arts and culture partners around the world, we will offer our 15th season of Museums on Us, adding more than 20 new organizations to the museum roster, giving Bank of America customers more educational and cultural opportunities.
Share: Through Arts in Our Communities, we will share great works from the Bank of America collection with museums from Madrid and London to Jacksonville, FL and Kansas City, MO.
Preserve: We received many outstanding applications from nonproft arts organizations around the world in 2011 to participate in the Bank of America Art Conservation Project. From these, we will select new partners in 2012 to work with to preserve a second set of treasured artifacts and works of art.
90 Arts & Culture CHAPTER 9 Diversity & Inclusion 9 | DIVERSITY & InCLuSIOn
We value our differences — in thought, style, culture, ethnicity and experience — understanding that diversity and inclusion are good for business and allow our company to better serve our employees, customers, clients and shareholders.
Fostering a diverse, inclusive workplace gives us the Diversity and Inclusion Councils business advantage of understanding, meeting and creating Bank of America continues to be widely recognized for our the best solutions for the needs of our diverse customers, diversity and inclusion policies and initiatives as well as the clients and communities we serve. Our efforts to promote internal structure and oversight that guide our practices, diversity and inclusion fall into four focus areas: which include:
•Recruitingandretainingdiversetalent Global Diversity & Inclusion Council: Chaired by CEO Brian •Maintainingrelationshipswithdiversesuppliers Moynihan, the Global Diversity & Inclusion Council includes •Offeringproductsandservicestomeetthediverse senior executives from across the bank who set the strategic needs of our customers, and agenda for diversity and inclusion. •Philanthropysupportingunderservedcommunities. Global Diversity & Inclusion Organization: Led by chief Diversity & Inclusion executive Geri Thomas, the Global Diversity & Inclusion Organization partners with businesses across regions to develop strategy, recruit diverse talent and manage our diversity sponsorships and strategic alliances. Diversity & Inclusion Business & Regional Councils: Each business and region has its own Diversity & Inclusion Council that defnes and executes the business and regional diversity and inclusion priorities. Employee networks: With over 200 chapters worldwide, employee networks work to enhance opportunities for employee development through networking, mentoring and information forums.
92 Diversity & Inclusion “A diverse and inclusive workplace is good for business and the right thing to do for our employees. There is diversity in the customers we serve and in the communities where we live and work. By refecting that, our team can create the best solutions for all those we serve.”
— Brian Moynihan, CEO
Employee networks Maintaining Supplier Diversity To determine how we could enhance the support provided to At Bank of America we encourage through Supplier Employee Networks, in 2011 we surveyed Employee Network Diversity, the use of diverse and small businesses, leaders, executive sponsors, council members and various based on the categories of goods and services we partners. The results identifed the need for enhanced tools purchase in the communities we serve. The Supplier and processes for these leaders as well as the desire for Diversity and Development program managers collaborate increased collaboration and best-practice sharing across internally to ensure that we include diverse businesses affnity groups. across the Bank. Some examples of diverse suppliers include minorities and individuals with disabilities, or Part of this work included a name change for the Employee businesses owned by veterans, women, individuals who Networks. Formerly known as Affnity Groups, the change to are lesbian, gay, bi-sexual or transgender. Employee Networks was made to more accurately refect the role and value these groups provide to the bank. The shift to In 2011 Bank of America spent $2.36 billion with diverse Employee Networks also resonates across our global footprint. businesses, an increase from $2.33 billion in 2010 and Learn more about our global workforce in Chapter 3. $1.87 in 2009.
Diversity & Inclusion 93 SUPPORT SERVICES Our Support Services organization continues to provide employment opportunities to employees with disabilities. In 2011 the team included 300 employees who provided services across our lines of business that included packaging and fulfllment; digital, wide-format, and screen printing; and warehouse and distribution services.
Recruiting and Retaining Diverse Talent The bank is committed to attracting, recruiting and retaining to increase the number of people with disabilities hired top diverse talent from across the globe. In 2009, we into the company through advocacy, internal education and created the Diversity Executive Recruiting team, which external partnerships. identifes prospective executives and connects talent to leaders within our organization. In 2011 we expanded our Retaining top talent is equally important. Our approach is efforts by engaging our Global Staffng team to help our top to foster an environment where all employees have the candidates fnd the right roles within the bank. opportunity to learn and grow in their career, providing the support employees need — both personally and We also partner with our lines of business leaders and professionally — through every stage of their lives. We employee networks to engage with a variety of organizations also offer a variety of fexible work arrangements so to fnd the best talent for our company. For example, since employees can maintain a healthy balance between work our efforts to recruit military service members and veterans and personal commitments. Additional information on began, we’ve seen a signifcant increase in our hiring and employee programs can be found in Chapter 3. currently employ approximately 5,000 service members and veterans. In 2012, we committed to double our military hiring efforts through additional recruiting staff and partnerships with external organizations. We recently formed a task force
94 Diversity & Inclusion Focusing on Diverse Client Needs
We value the diversity of our client base and understand the Special needs range of their fnancial needs, wants and goals. Our In 2011, 722 employees became designated Certifed Consumer Banking business provides a variety of products Special Needs Advisors (CSNAs), bringing the year-end total and services to meet the diverse needs of customers. to 2,580 CSNAs serving Merrill Lynch special-needs clients. We also launched an online Special-Needs Calculator to •Thebankhasdevelopedinnovativeservicesforvisually help parents navigate complex fnancial matters involved and hearing impaired customers, including over 18,000 with lifelong care of a family member or individual with talking ATMs that provide audible instructions in English special needs. and Spanish. Customers can receive Braille and large-print banking statements. LGBT U.S. Trust added to the division’s existing efforts to serve •BankingcustomerscanconductATMtransactionsinseven the LGBT community by piloting a local market initiative languages, including Spanish, Chinese, French, Korean, in Dallas. Working closely with on-the-ground partners, Portuguese and Russian. U.S. Trust cultivated relationships with LGBT organizations, allies and prospects to offer wealth services locally that •Thebankoffersavarietyofproductsandserviceswiththe address the unique fnancial needs facing this community. option of Spanish translation. This includes Spanish fulfllment, statements, account information and customer Elder-care service for credit card products such as BankAmericard The number of Americans age 65 and up is expected to and Cash Rewards, MLB and Royal Caribbean. In addition, double during the next 40 years, which means there will be home loan statements are offered in Spanish, and several an even greater need for solutions that address health, online services such as Online Banking and Text Banking mobility and overall fnancial well-being for an aging are offered in Spanish. population. In late 2011, U.S. Trust launched ElderCare Planning, a customized program that covers fduciary, •Thebankpartnersoncreditcardsanddemanddeposit fnancial and health-related solutions for elderly clients. account products with many diverse organizations, such as The program also offers health care management and the Human Rights Campaign (HRC). coordination services through strategic partnerships, as well as assistance with planning for future care and retirement. Bank of America’s Global Wealth & Investment Management division has focused on providing specifc advice and guidance, solutions and services so that we can continue to help our clients realize their personal fnance goals. Supporting underserved Communities THInkInG AHEAD Bank of America remains committed to underserved Fostering a diverse, inclusive workplace will continue to give communities by looking for opportunities to make every good us the business advantage of understanding and meeting the loan and investment we can. Strengthening underserved needs of our diverse customers, clients and communities. communities through direct capital investment and employee In 2012, we plan to: service is critical to our nation’s economic recovery, and •Continuetoexecuteonthebank’sglobalDiversity& is good business for the bank. More on our support for Inclusion strategy and priorities underserved communities can be found in the Stronger •Supportingourcultureofinclusionandengagementby Economies and Leadership & Service chapters. leveraging Employee Networks, business and regional councils, as well as the leadership team •Increaserepresentation,developmentandretentionof women globally and people of diverse races and ethnic backgrounds in the U.S. •Expandoursupportofthemilitarycommunitythroughthe ongoing work of the Military Affairs Advisory Group, recently created to coordinate programs across the company to provide greater assistance to military service members and their families through philanthropy, hiring, customer service and employee engagement. •Continuetodriveleadershipengagementandaccountability to build a diverse talent pipeline and foster a diverse and inclusive environment.
96 Diversity & Inclusion CHAPTER 10
Awards, Recognitions and Rankings 10 | AWARDS, RECOGnITIOnS AnD RAnkInGS
In 2011 we were honored to be recognized for our employment and business practices. In addition to the rankings and awards listed throughout this report, a representative sample of awards from key areas and markets is listed below:
2011 Awards, Recognitions and Rankings
100% score on the Human rights Campaign Corporate equality index, for the sixth Human rights Campaign consecutive year
Top 10 — 2012 Working Mother 100 best Companies list: our 23rd year on the list. Working Mother Top 10 companies for women’s advancement and best companies for kids
No. 11 on Diversity Inc. magazine’s “Top 50 Companies for Diversity” annual list — for the 11th year Diversity Inc.
Top 10 for Recruitment & Retention, Supplier Diversity, Executive Women and LGBT Employees
Black Enterprise “40 Best Companies for Diversity” by Black Enterprise magazine for the seventh year in a row
Hispanic Business Hispanic Business magazine’s “Top 60 Diversity Elite” for the sixth year in a row
Bank of America Merrill Lynch recognized by the Workplace Wellness Council in Mexico Workplace Wellness Council for quality and excellence in workplace health promotion
Department of Defense recognized Bank of America with the following awards for our support of employees who serve in the National Guard and Reserve:
–TheSevenSealsAwardfromtheMaineChapteroftheEmployerSupport Department of Defense of the Guard and Reserve –TheAboveandBeyondAwardinTexasandNorthCarolina –ThePatriotAwardinGeorgia –Nominatedasasemi-finalistinMaineandfinalistinDelawarefortheFreedomAward
G.I. Jobs Top 100 Military Friendly Employers by G.I. Jobs magazine for the sixth year in a row
Military Times EDGE Among Military Times EDGE magazine’s “Best for Vets 2011: Employers”
Merrill Lynch Wealth Management led all fnancial services frms on Barron’s “top 100 Women Financial advisors” list again this year, with 33 in the rankings; leading the list every Barron’s year since 2006. Also #1 on “Top 1,000 Financial Advisors” overall and #1 in number of Advisors ranked frst in their state.
Best Adoption-Friendly Workplace by the Dave thomas Foundation for adoption for the fourth Dave thomas Foundation year in a row
98 Awards, Recognitions and Rankings Dalbar Recognition for our participant statements arts business to arts business to arts: Judge’s Special Recognition Award environment
Bank of America #1 in fnancial services, #4 overall in Global 500, #1 in fnancial sector and Carbon Disclosure project #2 overall in S&p 500
Newsweek Ranked #2 among big U.S. banks in the Newsweek 2011 Green rankings
The Banker — Bank of American Merrill Lynch Most Innovative Investment Bank in Climate The Banker Change and Sustainability
Financial Times — Sustainable Finance Award, Honorable Mention, Base of the Financial Times Pyramid category
FtSe4Good Bank of America was listed on FtSe4Good, a leading SRI Index
bloomberg Markets ranked Bank of America second “greenest bank” globally; frst among bloomberg Markets U.S. banks
regional institutional investor institutional investor — #1 2011 All-Japan Research Team
Euromoney Magazine “2011 Awards for Excellence”
–BestequityhouseinLatinAmerica –BestdebthouseinArgentina Euromoney Magazine –BestdebthouseinColombia –BestdebthouseinPeru –BestdebthouseinJapan –BestdebthouseinSouthKorea
Innovator in providing accessibility to European online banking customers with auditory or sight disabilities, the Computerworld Honors program’s Digital access laureate
Thomson Reuters Extel and UK SIF Socially Responsible Investing and Sustainability Survey rated Bank of America Merrill Lynch Global Research: thomson reuters extel and UK SiF a. #2 Leading Brokerage Firm for SRI and Sustainability b. #1 Leading Brokerage Firm for SRI Research lord Mayor Lord Mayor’s Dragon Award for Financial Education and Employability Programme
Awards, Recognitions and Rankings 99 Business in the Community Awards for Excellence: Education Award for Bank of America business in the Community Merrill Lynch’s London Schools Programme
aliarSe and the Mexican Center Socially Responsible Company Distinction, by aliarSe and the Mexican Center for philanthropy for philanthropy
Mundo ejecutiv Top 50 companies with highest Social Responsibility in Mexico by Mundo ejecutiv
innovative technology and operations
Keynote Systems Number one online bank for the second year, according to Keynote Systems banker Scorecard
Best in Class in banking identity safety for the 7th year, according to Javelin Strategy Javelin Strategy & research & research
Top-ranked in delivering outstanding client experience for a second year in a row and J.D. power and associates Bank of America Merrill Lynch Retirement Contact Centers recognized for providing outstanding customer service experience for a seventh consecutive year
100 Awards, Recognitions and Rankings CHAPTER 11
Global Reporting Initiative Disclosures 11 | GRI Disclosures
StanDarD DiSCloSUreS part i: profle Disclosures
1. Strategy and analysis
Profle Disclosure Description Reported Cross-reference/Direct answer
1.10 Statement from the most senior decision-maker of the organization. Fully Chapter 1, Pages 3-4
1.20 Description of key impacts, risks, and opportunities. Fully Chapters 1, 4, 6 and 12
2. organizational profle
Profle Disclosure Description Reported Cross-reference/Direct answer
2.10 Name of the organization. Fully Direct Answer: Bank of America Corporation
2.20 Primary brands, products, and/or services. Fully Chapter 2, Pages 10-11 Operational structure of the organization, including main divisions, 2.30 Fully 2011 Annual Report Pages 33-49 operating companies, subsidiaries, and joint ventures. Direct answer: Charlotte, 2.40 Location of organization’s headquarters. Fully North Carolina, U.S.A. Number of countries where the organization operates, and names of Chapter 2, Page 10; 2.50 countries with either major operations or that are specifcally relevant to the Fully 2011 Annual Report Pages 98-102 sustainability issues covered in the report. Certifcate of Incorporation available at 2.60 Nature of ownership and legal form. Fully www.bankofamerica.com/investor Markets served (including geographic breakdown, sectors served, and types Chapter 2, Pages 10-11; 2.70 Fully of customers/benefciaries). 2011 Annual Report Page 20 Chapter 2, Pages 10-11; 2.80 Scale of the reporting organization. Fully 2011 Annual Report Page 20, 31 Signifcant changes during the reporting period regarding size, structure, or Chapter 2, Pages 10-11; 2.90 Fully ownership. Chapter 4, Pages 26-29 2.10 Awards received in the reporting period. Fully Chapter 10, Pages 97-100
3. report parameters
Profle Disclosure Description Reported Cross-reference/Direct answer
3.10 Reporting period (e.g., fscal/calendar year) for information provided. Fully Chapter 12, Page 116
3.20 Date of most recent previous report (if any). Fully Chapter 12, Page 116
3.30 Reporting cycle (annual, biennial, etc.) Fully Chapter 12, Page 116
3.40 Contact point for questions regarding the report or its contents. Fully Chapter 13, Page 122
3.50 Process for defning report content. Fully Chapter 1, Page 8; Chapter 12, Pages 116-119 Boundary of the report (e.g., countries, divisions, subsidiaries, leased Direct answer: The scope of this report covers 3.60 facilities, joint ventures, suppliers). See GRI Boundary Protocol for further Fully the organization as defned on Pages 10, 11 guidance. and 116. Direct answer: The boundary of the report is State any specifc limitations on the scope or boundary of the report (see 3.70 Fully described in Chapter 12. No notable limitations completeness principle for explanation of scope). in the scope.
Basis for reporting on joint ventures, subsidiaries, leased facilities, Chapter 12, Page 116; Direct answer: This 3.80 outsourced operations, and other entities that can signifcantly affect Fully report refects the performance of wholly-owned comparability from period to period and/or between organizations. Bank of America entities and facilities.
Data measurement techniques and the bases of calculations, including assumptions and techniques underlying estimations applied to the Chapter 6, Page 69; Chapter 12, Page 118: 3.90 compilation of the Indicators and other information in the report. Explain Fully Data Measurement and Assurance Statement any decisions not to apply, or to substantially diverge from, the GRI Indicator Protocols. Explanation of the effect of any re-statements of information provided in earlier reports, and the reasons for such re-statement (e.g., mergers/ 3.10 Fully Direct answer: No restatements acquisitions, change of base years/periods, nature of business, measurement methods). Signifcant changes from previous reporting periods in the scope, boundary, 3.11 Fully Chapter 1, Page 8; Chapter 12, Pages 116-118 or measurement methods applied in the report. 3.12 Table identifying the location of the Standard Disclosures in the report. Fully Chapter 11, Pages 101-110 Policy and current practice with regard to seeking external assurance for 3.13 Fully Chapter 12, Pages 116-119 the report.
102 Global Reporting Initiative Disclosures 4. Governance, Commitments and engagement
Profle Disclosure Description Reported Cross-reference/Direct answer
Governance structure of the organization, including committees under the 2012 Proxy Statement (available here: 4.10 highest governance body responsible for specifc tasks, such as setting Fully http://media.corporate-ir.net/Media_Files/ strategy or organizational oversight. IROL/71/71595/Proxy2012.pdf) Pages 7-14 Indicate whether the Chair of the highest governance body is also an 4.20 Fully 2012 Proxy Statement, Pages 8-9 executive offcer. For organizations that have a unitary board structure, state the number 4.30 of members of the highest governance body that are independent and/or Fully 2012 Proxy Statement, Pages 7-9 non-executive members. Mechanisms for shareholders and employees to provide recommendations 4.40 Fully 2012 Proxy Statement, Page 13 or direction to the highest governance body. Linkage between compensation for members of the highest governance body, senior managers, and executives (including departure arrangements), 4.50 Fully 2012 Proxy Statement, Pages 14, 18-46 and the organization’s performance (including social and environmental performance). View Bank of America Code of Ethics which guides all staff and management on Processes in place for the highest governance body to ensure conficts of 4.60 Fully Conficts of Interest. Available here: http:// interest are avoided. investor.bankofamerica.com/phoenix. zhtml?c=71595&p=irol-govconduct
Direct answer: We assess board members’ Process for determining the qualifcations and expertise of the members capacity to guide overall company strategy, 4.70 of the highest governance body for guiding the organization’s strategy on Fully including their ability to understand environmental economic, environmental, and social topics. and social impacts. Additional information is available in our 2012 Proxy Statement.
Internally developed statements of mission or values, codes of 4.80 conduct, and principles relevant to economic, environmental, and social Fully Chapter 1, Pages 3-7 performance and the status of their implementation. Procedures of the highest governance body for overseeing the organization’s identifcation and management of economic, environmental, Chapter 1, Pages 3-8; Chapter 4, Pages 22-32; 4.90 and social performance, including relevant risks and opportunities, and Fully Annual Report Pages 62-65 adherence or compliance with internationally agreed standards, codes of conduct, and principles. Processes for evaluating the highest governance body’s own performance, Chapter 4, Pages 22-32; 2012 Proxy Statement, 4.10 particularly with respect to economic, environmental, and social Fully Page 13 performance. Chapter 4, Pages 30-31; Chapter 6, Pages 65- Explanation of whether and how the precautionary approach or principle is 4.11 Fully 66; Chapter 12, Page 116 (e.g., Equator, Carbon addressed by the organization. Principles) Externally developed economic, environmental, and social charters, Chapter 4, Pages 30-31; Chapter 6, Pages 65- 4.12 principles, or other initiatives to which the organization subscribes or Fully 66; Chapter 12, Page 116 (e.g., Equator, Carbon endorses. Principles) Memberships in associations (such as industry associations) and/or national/international advocacy organizations in which the organization: 4.13 * Has positions in governance bodies; * Participates in projects or Fully Chapter 4, Page 32 committees; * Provides substantive funding beyond routine membership dues; or * Views membership as strategic. Chapter 4, Page 30, Page 32; Chapters 5, 7, and 4.14 List of stakeholder groups engaged by the organization. Fully 8; Chapter 6, Page 65 (nonproft partnerships); Chapter 12, Pages 116-119 Chapter 4, Pages 30-32; 4.15 Basis for identifcation and selection of stakeholders with whom to engage. Fully Chapter 12, Pages 116-119 Approaches to stakeholder engagement, including frequency of Chapter 4, Pages 30-32; Chapter 5, Pages 34, 4.16 Fully engagement by type and by stakeholder group. 36, 38; Chapter 6; Chapter 12, Pages 116-119 Key topics and concerns that have been raised through stakeholder 4.17 engagement, and how the organization has responded to those key topics Fully Chapter 1, Page 8; Chapter 12, Pages 116-119 and concerns, including through its reporting.
StanDarD DiSCloSUreS part ii: Disclosures on Management approach (DMas) fSSS DMAs Description Reported Cross-reference/Direct answer
DMA PS Disclosure on Management Approach PS
Aspects Product Portfolio Fully Chapter 2, Pages 10-11; Chapter 4, Pages 30-31 Policies with specifc environmental and social components applied to Chapter 6, Pages 65-66 (Governance and Policies FS1 Fully business lines. section)
Global Reporting Initiative Disclosures 103 fSSS DMAs Description Reported Cross-reference/Direct answer
Chapter 4, Page 31; Chapter 6, Pages 65-66 Procedures for assessing and screening environmental and social risks in FS2 Fully (Governance and Policies section, example of business lines. forestry sector client) Processes for monitoring clients’ implementation of and compliance FS3 with environmental and social requirements included in agreements or Partially Chapter 6, Pages 65-66 transactions. Training is provided to employees on all policies, Process(es) for improving staff competency to implement the including social and environmental policies. FS4 environmental and social policies and procedures as applied to business Fully Additionally, a certain percent of employee lines. compensation is linked to achieving social and environmental goals. Chapter 6, Pages 65-66 (Governance and Interactions with clients/investees/business partners regarding FS5 Partially Policies description of implementing policies/ environmental and social risks and opportunities. example of forestry sector client) Audits Fully Chapter 4, Pages 27, 31
Active Ownership Fully Chapter 4, Pages 27, 31
DMA EC Disclosure on Management Approach EC
Aspects Economic performance Fully Chapter 2, Chapter 4, Chapter 5
Market presence Fully Chapter 2, Chapter 3, Chapter 4, Chapter 5
Indirect economic impacts Fully Chapter 4, Chapter 5
DMA EN Disclosure on Management Approach EN
Aspects Materials Fully Chapter 6
Energy Fully Chapter 6
Water Fully Chapter 6, Page 60
Biodiversity Not Not material
Emissions, effuents and waste Fully Chapter 6
Products and services Not Not applicable
Compliance Fully Pages 6-7, 22, 27, 28, 30, 31, 56, 65, 66, 73
Transport Fully Chapter 6, Pages 62, 68, 70, 73
Overall Fully Chapter 6
DMA LA Disclosure on Management Approach LA
Aspects Employment Fully Chapter 3
Labor/management relations Fully Chapter 3, Page 16; Code of Ethics, Page 30
Occupational health and safety Fully Chapter 3, Page 18
Training and education Fully Chapter 3, Page 18; Chapter 4, Page 30 Chapter 1, Pages 5 and 7; Chapter 3, Pages 14 Diversity and equal opportunity Fully and 16; Chapter 9; Code of Ethics Page 30 DMA HR Disclosure on Management Approach HR
Aspects Investment and procurement practices Fully Chapter 4, Pages 30-31
Non-discrimination Fully Code of Ethics; Chapter 4, Page 30
Freedom of association and collective bargaining Not Not applicable
Child labor Not Not applicable
Forced and compulsory labor Not Not applicable
Security practices Fully Chapter 4, Page 30
Indigenous rights Not Not applicable
DMA SO Disclosure on Management Approach SO
Aspects Community Fully Chapter 5; Code of Ethics, Pages 30-31
Corruption Fully Chapter 4, Pages 28-31
Public policy Fully Chapter 4; Also Code of Ethics Page 30
Anti-competitive behavior Not Not available for disclosure
104 Global Reporting Initiative Disclosures fSSS DMAs Description Reported Cross-reference/Direct answer
Compliance Fully Chapter 4, Pages 28, 31; 10-K
DMA PR Disclosure on Management Approach PR
Aspects Customer health and safety Not Not applicable
Product and service labeling Fully Chapter 4
FS15 Policies for the fair design and sale of fnancial products and services Fully Chapter 4
Marketing communications Fully Chapter 4
Customer privacy Fully Chapter 4, Pages 29-30
Compliance Fully Chapter 4, Pages 29-31
StanDarD DiSCloSUreS part iii: performance indicators
product and Service impact: product portfolio
Profle Disclosure Description Reported Cross-reference/Direct answer
Percentage of the portfolio for business lines by specifc region, size Chapter 2, Page 10; Chapter 4, Page 27; FS6 Fully (e.g., micro/SME/large) and by sector. Chapter 5, Pages 34-46 Monetary value of products and services designed to deliver a specifc FS7 Fully Chapter 2, Pags 10-12; Chapter 5, Pages 34-46 social beneft for each business line broken down by purpose. Monetary value of products and services designed to deliver a specifc FS8 Fully Chapter 6, Pages 54-55 environmental beneft for each business line broken down by purpose.
product and Service impact: audit
Profle Disclosure Description Reported Cross-reference/Direct answer
Coverage and frequency of audits to assess implementation of FS9 Partially Pages 30-32; Chapter 12, Pages 116-119 environmental and social policies and risk assessment procedures.
product and Service impact: active ownership
Profle Disclosure Description Reported Cross-reference/Direct answer
Percentage and number of companies held in the institution’s portfolio with FS10 which the reporting organization has interacted on environmental or social Not Not available for disclosure issues. Percentage of assets subject to positive and negative environmental or FS11 Not Not available for disclosure social screening. Voting policy(ies) applied to environmental or social issues for shares over FS12 which the reporting organization holds the right to vote shares or advises Not Not available for disclosure on voting.
economic: economic performance
Profle Disclosure Description Reported Cross-reference/Direct answer
Direct economic value generated and distributed, including revenues, Chapter 2, Pages 10-12; Chapter 3, Page 19; operating costs, employee compensation, donations and other community Chapter 4, Pages 26, 30, 31; Chapter 5, Pages EC1 Fully investments, retained earnings, and payments to capital providers and 47, 54, 55, 56; Chapter 7, Pages 78, 80; governments. Annual Report - Pages 243-245 Chapter 6, Pages 65-66. Direct answer: Our support for the Carbon Principles and the Financial implications and other risks and opportunities for the EC2 Partially company’s Utility Portfolio Emissions efforts are organization’s activities due to climate change. two examples of how risk management can be compatible with environmental goals. Chapter 3, Page 17; 2011 Annual Report - EC3 Coverage of the organization’s defned beneft plan obligations. Fully Page 235-244 Direct answer: No signifcant fnancial EC4 Signifcant fnancial assistance received from government. Fully assistance received from governments in 2011
economic: Market presence
Profle Disclosure Description Reported Cross-reference/Direct answer
Range of ratios of standard entry level wage compared to local minimum EC5 Not Not available for disclosure wage at signifcant locations of operation.
Global Reporting Initiative Disclosures 105 Profle Disclosure Description Reported Cross-reference/Direct answer
Policy, practices, and proportion of spending on locally-based suppliers at EC6 Partially Chapter 4, Pages 30-31 signifcant locations of operation. Procedures for local hiring and proportion of senior management hired EC7 Not Not available from the local community at signifcant locations of operation.
economic: indirect economic impacts
Profle Disclosure Description Reported Cross-reference/Direct answer
Development and impact of infrastructure investments and services EC8 provided primarily for public beneft through commercial, in-kind, or pro Partially Chapter 5, Pages 34-40; Chapter7; Chapter 8 bono engagement. Understanding and describing signifcant indirect economic impacts, Chapter 1, Pages 3-4; Chapter 4, Pages 22-29; EC9 Fully including the extent of impacts. Chapter 5, Pages 34-40
environmental: Materials
Profle Disclosure Description Reported Cross-reference/Direct answer
EN1 Materials used by weight or volume. Fully Chapter 6, Pages 70, 72
EN2 Percentage of materials used that are recycled input materials. Fully Chapter 6, Pages 58-60, 70-74
environmental: energy
Profle Disclosure Description Reported Cross-reference/Direct answer
EN3 Direct energy consumption by primary energy source. Fully Chapter 6, Page 72
EN4 Indirect energy consumption by primary source. Fully Chapter 6, Page 72
EN5 Energy saved due to conservation and effciency improvements. Fully Chapter 5, Page 38; Chapter 6, Page 72
Chapter 6, Page 54, 55, 61, 73 ($55M energy Initiatives to provide energy-effcient or renewable energy-based products effciency fnance program; Hybrid vehicle fnancing; Hybrid vehicle reimbursement program for employees; EN6 and services, and reductions in energy requirements as a result of these Fully efforts to eliminate paper for consumers, including initiatives. ATMs services; email statements, telephone banking, and email communication) Chapter 6, Pages 54-59, 72, 73 (e.g., LEED; EN7 Initiatives to reduce indirect energy consumption and reductions achieved. Fully Paper elimination/tracking; Water reduction; Waste/recycling)
environmental: Water
Profle Disclosure Description Reported Cross-reference/Direct answer
EN8 Total water withdrawal by source. Partially Chapter 6, Page 74
EN9 Water sources signifcantly affected by withdrawal of water. Partially Chapter 6, Page 60
EN10 Percentage and total volume of water recycled and reused. Partially Chapter 6, Page 60
environmental: biodiversity
Profle Disclosure Description Reported Cross-reference/Direct answer
Location and size of land owned, leased, managed in, or adjacent to, EN11 protected areas and areas of high biodiversity value outside protected Not Not applicable. Minimal impacts. areas. Description of signifcant impacts of activities, products, and services on EN12 biodiversity in protected areas and areas of high biodiversity value outside Not Not applicable. Minimal impacts. protected areas. EN13 Habitats protected or restored. Not Not applicable. Minimal impacts. Strategies, current actions and future plans for managing impacts on EN14 Not Not applicable. Minimal impacts. biodiversity. Number of IUCN Red List species and national conservation list species EN15 Not Not applicable. Minimal impacts. with habitats in areas affected by operations, by level of extinction risk.
106 Global Reporting Initiative Disclosures environmental: emissions, effuents and Waste
Profle Disclosure Description Reported Cross-reference/Direct answer
EN16 Total direct and indirect greenhouse gas emissions by weight. Fully Chapter 6, Pages 70-71
EN17 Other relevant indirect greenhouse gas emissions by weight. Fully Chapter 6, Pages 70-71
EN18 Initiatives to reduce greenhouse gas emissions and reductions achieved. Fully Chapter 6, Page 58
EN19 Emissions of ozone-depleting substances by weight. Not Not applicable. Minimal impacts.
EN20 NOx, SOx, and other signifcant air emissions by type and weight. Fully Chapter 6, Pages 72
EN21 Total water discharge by quality and destination. Not Not applicable. Minimal impacts.
EN22 Total weight of waste by type and disposal method. Fully Chapter 5, Pages 59,70,74
EN23 Total number and volume of signifcant spills. Fully Chapter 6, Page 73 Weight of transported, imported, exported, or treated waste deemed EN24 hazardous under the terms of the Basel Convention Annex I, II, III, and VIII, Not Not applicable. Minimal impacts. and percentage of transported waste shipped internationally. Identity, size, protected status, and biodiversity value of water bodies EN25 and related habitats signifcantly affected by the reporting organization’s Not Not applicable. Minimal impacts. discharges of water and runoff.
environmental: products and Services
Profle Disclosure Description Reported Cross-reference/Direct answer Initiatives to mitigate environmental impacts of products and services, and EN26 Fully Chapter 6 extent of impact mitigation. Percentage of products sold and their packaging materials that are EN27 Not Not available for disclosure. reclaimed by category.
environmental: Compliance
Profle Disclosure Description Reported Cross-reference/Direct answer
Monetary value of signifcant fnes and total number of non-monetary EN28 Fully Chapter 6, Pages 66, 73 sanctions for non-compliance with environmental laws and regulations.
environmental: transport
Profle Disclosure Description Reported Cross-reference/Direct answer
Signifcant environmental impacts of transporting products and other EN29 goods and materials used for the organization’s operations, and Fully Chapter 6, Pages 70, 73 transporting members of the workforce.
environmental: overall
Profle Disclosure Description Reported Cross-reference/Direct answer
EN30 Total environmental protection expenditures and investments by type. Not Not available for disclosure.
Social: labor practices and Decent Work — employment
Profle Disclosure Description Reported Cross-reference/Direct answer
LA1 Total workforce by employment type, employment contract, and region. Partially Chapter 2, Page 11; Chapter 3 Total number and rate of employee turnover by age group, gender, and LA2 Not Proprietary region. Benefts provided to full-time employees that are not provided to temporary LA3 Not Not available for disclosure. or part-time employees, by major operations.
Social: labor practices and Decent Work — labor/Management relations
Profle Disclosure Description Reported Cross-reference/Direct answer
LA4 Percentage of employees covered by collective bargaining agreements. Not Not applicable Minimum notice period(s) regarding signifcant operational changes, LA5 Not Not applicable including whether it is specifed in collective agreements.
Global Reporting Initiative Disclosures 107 Social: labor practices and Decent Work — occupational Health and Safety
Profle Disclosure Description Reported Cross-reference/Direct answer
Percentage of total workforce represented in formal joint management- LA6 worker health and safety committees that help monitor and advise on Not Not available for disclosure occupational health and safety programs. Rates of injury, occupational diseases, lost days, and absenteeism, and LA7 Not Not available for disclosure number of work-related fatalities by region. Education, training, counseling, prevention, and risk-control programs in LA8 place to assist workforce members, their families, or community members Not Not available for disclosure regarding serious diseases. LA9 Health and safety topics covered in formal agreements with trade unions. Not Not available for disclosure
Social: labor practices and Decent Work — training and education
Profle Disclosure Description Reported Cross-reference/Direct answer
LA10 Average hours of training per year per employee by employee category. Partially Chapter 3, Page 14 Programs for skills management and lifelong learning that support the LA11 continued employability of employees and assist them in managing career Partially Chapter 3, Page 18 endings. Percentage of employees receiving regular performance and career LA12 Fully Chapter 3, Page 14 development reviews.
Social: labor practices and Decent Work — Diversity and equal opportunity
Profle Disclosure Description Reported Cross-reference/Direct answer
Composition of governance bodies and breakdown of employees per LA13 category according to gender, age group, minority group membership, and Partially Chapter 3, Page 14; Chapter 4, Page 28 other indicators of diversity. LA14 Ratio of basic salary of men to women by employee category. Not Not available for disclosure
Social: Human rights — Diversity and equal opportunity
Profle Disclosure Description Reported Cross-reference/Direct answer
Percentage and total number of signifcant investment agreements that HR1 include human rights clauses or that have undergone human rights Not Not available for disclosure screening. Percentage of signifcant suppliers and contractors that have undergone HR2 Not Not available for disclosure screening on human rights and actions taken. Total hours of employee training on policies and procedures concerning HR3 aspects of human rights that are relevant to operations, including the Partially Chapter 3, Page 14; Chapter 4, Page 30 percentage of employees trained.
Social: Human rights — non-discrimination
Profle Disclosure Description Reported Cross-reference/Direct answer
HR4 Total number of incidents of discrimination and actions taken. Not Not available for disclosure
Social: Human rights — Freedom of association and Collective bargaining
Profle Disclosure Description Reported Cross-reference/Direct answer
Operations identifed in which the right to exercise freedom of association HR5 and collective bargaining may be at signifcant risk, and actions taken to Not Not available for disclosure support these rights.
Social: Human rights — Child labor
Profle Disclosure Description Reported Cross-reference/Direct answer
Operations identifed as having signifcant risk for incidents of child labor, HR6 Not Not applicable and measures taken to contribute to the elimination of child labor.
Social: Human rights — Forced and Compulsory labor
Profle Disclosure Description Reported Cross-reference/Direct answer
Operations identifed as having signifcant risk for incidents of forced or HR7 compulsory labor, and measures to contribute to the elimination of forced Not Not applicable or compulsory labor.
108 Global Reporting Initiative Disclosures Social: Human rights — Security practices
Profle Disclosure Description Reported Cross-reference/Direct answer
Percentage of security personnel trained in the organization's policies HR8 or procedures concerning aspects of human rights that are relevant to Fully Chapter 4, Page 30 operations.
Social: Human rights — indigenous rights
Profle Disclosure Description Reported Cross-reference/Direct answer
Total number of incidents of violations involving rights of indigenous people HR9 Not Not applicable. and actions taken.
Social: Society — Community
Profle Disclosure Description Reported Cross-reference/Direct answer
Nature, scope, and effectiveness of any programs and practices that SO1 assess and manage the impacts of operations on communities, including Fully Chapter 5 entering, operating, and exiting. Access points in low-populated or economically disadvantaged areas by FS13 Fully Chapter 5, Page 38 type.
Direct Answer: Bank of America provides various services to improve access to fnancial services for Initiatives to improve access to fnancial services for disadvantaged FS14 Fully disadvantaged people including braille statements people. and talking ATMs. More information at http://www. bankofamerica.com/accessiblebanking
Social: Society — Corruption
Profle Disclosure Description Reported Cross-reference/Direct answer
Percentage and total number of business units analyzed for risks related Direct answer: 100 percent of business units are SO2 Fully to corruption. analyzed for risks related to corruption Direct answer: 100 percent of Bank of America Percentage of employees trained in organization’s anti-corruption policies employees are trained in anti-corruption policies and SO3 Fully and procedures. procedures as part of Bank of America’s Code of Ethics training SO4 Actions taken in response to incidents of corruption. Not Not available for disclosure
Social: Society — public policy
Profle Disclosure Description Reported Cross-reference/Direct answer
Public policy positions and participation in public policy development and SO5 Fully Chapter 4, pages 30-32 lobbying. Total value of fnancial and in-kind contributions to political parties, SO6 Not Not available for disclosure politicians, and related institutions by country.
Social: Society — anti-Competitive behavior
Profle Disclosure Description Reported Cross-reference/Direct answer
Total number of legal actions for anti-competitive behavior, anti-trust, and SO7 Fully 2011 Annual Report, Pages 216-228 monopoly practices and their outcomes.
Social: Society — Compliance
Profle Disclosure Description Reported Cross-reference/Direct answer
Monetary value of signifcant fnes and total number of non-monetary SO8 Not Not available for disclosure sanctions for non-compliance with laws and regulations.
Social: product responsibility — Customer Health and Safety
Profle Disclosure Description Reported Cross-reference/Direct answer
Life cycle stages in which health and safety impacts of products and PR1 services are assessed for improvement, and percentage of signifcant Not Not applicable products and services categories subject to such procedures. Total number of incidents of non-compliance with regulations and voluntary PR2 codes concerning health and safety impacts of products and services Not Not applicable during their life cycle, by type of outcomes.
Global Reporting Initiative Disclosures 109 Social: product responsibility — product and Service labeling
Profle Disclosure Description Reported Cross-reference/Direct answer
Type of product and service information required by procedures, PR3 and percentage of signifcant products and services subject to such Not Not applicable information requirements. Total number of incidents of non-compliance with regulations and voluntary PR4 codes concerning product and service information and labeling, by type of Not Not applicable outcomes. Practices related to customer satisfaction, including results of surveys PR5 Partially Chapter 4, Page 24 measuring customer satisfaction. FS16 Initiatives to enhance fnancial literacy by type of benefciary. Fully Chapter 5, Page 48
Social: product responsibility — Marketing Communications
Profle Disclosure Description Reported Cross-reference/Direct answer
Chapter 4, Pages 28, 30; Programs for adherence to laws, standards, and voluntary codes related Direct answer: Bank of America has a robust PR6 to marketing communications, including advertising, promotion, and Partially internal process that reviews marketing sponsorship. communications and aims to ensure compliance with laws and voluntary codes. Total number of incidents of non-compliance with regulations and voluntary PR7 codes concerning marketing communications, including advertising, Not Not available for disclosure promotion, and sponsorship by type of outcomes.
Social: product responsibility — Customer privacy
Profle Disclosure Description Reported Cross-reference/Direct answer
Total number of substantiated complaints regarding breaches of customer PR8 Not Not available for disclosure privacy and losses of customer data.
Social: product responsibility — Compliance
Profle Disclosure Description Reported Cross-reference/Direct answer
Monetary value of signifcant fnes for non-compliance with laws and PR9 Fully 2011 Annual Report - Pages 200-208 regulations concerning the provision and use of products and services.
110 Global Reporting Initiative Disclosures Global Reporting Initiative Disclosures 111
BUREAU VERITAS’ INDEPENDENT ASSURANCE STATEMENT
Introduction and objectives of work Bureau Veritas North America, Inc (Bureau Veritas) was engaged by Bank of America Merrill Lynch to conduct an independent assurance of the environmental data reported in its 2011 Corporate Social Responsibility Report (the Report). This Assurance Statement applies to the related information included within the scope of work described below. The intended users of the assurance statement are the stakeholders of Bank of America Merrill Lynch. The overall aim of this process is to provide assurance to Bank of America Merrill Lynch’s stakeholders on the accuracy, reliability and objectivity of the information included in the Report. This information and its presentation in the Report are the sole responsibility of the management of Bank of America Merrill Lynch. Bureau Veritas was not involved in the collection of the information or of the drafting of the Report.
Scope of work Bank of America Merrill Lynch requested Bureau Veritas to include in its independent review the following: . Assurance of the environmental data and information included in the Report for the calendar year 2011 reporting period, specifically: o Materials (Total, and percentage of recycled input materials) o Energy (Direct and Indirect Consumption; Energy saved due to conservation; Initiatives to provide energy-efficient or renewable energy-based products; and Initiatives to reduce indirect energy consumption) o Water (Total withdrawal and volume recycled) o Biodiversity (Significant impacts of products, and habitats protected or restored) o Emissions (Greenhouse gas emissions: Direct Scope 1, Indirect Scope 2, and Optional Scope 3 emissions by weight; Initiatives to reduce greenhouse gas emissions and reductions achieved; NOx, SOx and other significant air emissions) o Waste Quantities and Disposition o Total number and volume of significant spills o Products and Services (Initiatives to mitigate environmental impacts of products and services) o Compliance (Monetary value of significant fines for non-compliance with environmental laws and regulations) o Transport (Significant environmental impact of transporting products and other goods and materials used for the organization’s operations, and transporting members of the workforce) o Appropriateness and robustness of underlying reporting systems and processes, used to collect, analyze, and review the environmental information reported; . Review of the data on the following other GRI indicators for consistency with a number of other public reports and internal policies and general plausibility:
112 Global Reporting Initiative Disclosures
o Economic (Performance, Market Presence, Indirect Economic Impacts); o Social: Labor Practices and Decent Work (Employment; Labor/Management Relations; Occupational Health & Safety; Training & Education; Diversity & Equal Opportunity) o Social: Human Rights (Diversity & Equal Opportunity; Security Practices) o Social: Society (Community; Corruption; Public Policy; Anti-Competitive Behaviour) o Social: Product Responsibility (Product & Service Labelling; Marketing Communications; Compliance) . Evaluation of the reported data against the principles of the Global Reporting Initiative (GRI) Reporting Framework as defined in the GRI G3 Sustainability Reporting Guidelines. Excluded from the scope of our work is any assurance of information relating to: . Text or other written statements associated with Bank of America Merrill Lynch’s 2011 CSR Report . Activities outside the defined assurance period
Methodology Bureau Veritas undertook the following activities: 1. Interviews with relevant personnel of Bank of America Merrill Lynch (14 individuals including employees and external contractors at the corporate level); 2. Review of internal and external documentary evidence produced by Bank of America Merrill Lynch; 3. Audit of environmental performance data presented in the Report including a detailed review of a sample of data; 4. Review of Bank of America Merrill Lynch environmental data and information systems for collection, aggregation, analysis and internal verification and review. The work was planned and carried out to provide a limited level of assurance and we believe it provides a sound basis for our conclusions.
Our findings On the basis of our methodology and the activities described:
. Nothing has come to our attention to indicate that the reviewed information within the scope of our verification is not materially correct. . Nothing has come to our attention to indicate that the reviewed information is not a fair representation of the actual environmental data for calendar year 2011. . The performance indicators included within the scope of work conform to the GRI G3 Guidelines. . Bank of America Merrill Lynch has established appropriate systems for the collection, aggregation and analysis of relevant environmental information, and has implemented underlying internal assurance practices that provide a reasonable degree of confidence that such information is complete and accurate.
Global Reporting Initiative Disclosures 113
Statement of independence, impartiality and competence Bureau Veritas is an independent professional services company that specializes in Quality, Health, Safety, Social and Environmental management with over 180 years history in providing independent assurance services, and turnover in 2010 in excess of $4.4 billion (US). No member of the assurance team has a business relationship with Bank of America Merrill Lynch, its Directors or Managers beyond that of verification and assurance of sustainability data and reporting. We have conducted this verification independently and we believe there to have been no conflict of interest.
Bureau Veritas has implemented a Code of Ethics across the business to maintain high ethical standards among staff in their day-to-day business activities. The assurance team has extensive experience in conducting assurance over environmental, social, ethical and health and safety information, systems and processes, has over 20 years combined experience in this field and an excellent understanding of Bureau Veritas standard methodology for the Assurance of Sustainability Reports.
Bureau Veritas North America, Inc. San Ramon, California May 2012
114 Global Reporting Initiative Disclosures CHAPTER 12
About This Report 12 | ABOuT THIS REPORT
In compiling this report, which covers Materiality Process and Bank of America’s non-fnancial performance Stakeholder Engagement and impact in 2011, we have been guided by the Global Reporting Initiative (GRI) G3 As noted earlier in this report, given feedback we received from external and internal stakeholders on our 2010 CSR Sustainability Reporting Guidelines as well report, members of Bank of America senior leadership as its Financial Services Sector Supplement. agreed that the materiality assessment process should be both more formal and inclusive this year. Our process to identify and prioritize issues to be included in this report We provide additional GRI-related information through included the following steps: our annual submissions to the Carbon Disclosure Project, our 2011 Annual Report, and Quarterly Impact Reports 1. We develop a common standard of materiality for available at www.bankofamerica.com/reports. Also, as Bank of America with respect to CSR activities an Equator Principles Financial Institution, we consider 2. We analyze external coverage of the bank’s operations the social and environmental impacts of the development and management projects we fnance, and we report annually on our work. 3. We conduct interviews with internal subject-matter experts, A team from across Bank of America’s business lines communication team members and other senior executives and corporate functions was responsible for drafting this 4. We gain external feedback from report, published in August 2012. It provides an account of •OurExternalReviewCommitteeasorganizedbyCERES Bank of America’s CSR work and business impact between •StaffmembersofBusinessforSocialResponsibility January 1 and December 31, 2011. Our last CSR Report •MembersofBankofAmerica’sNationalCommunity covered 2010 and was published in June 2011. Advisory Council, which is an external group of nationally recognized leaders in community development This report aims to present pertinent information about the global business of Bank of America (particularly Materiality Bank of America and major subsidiaries in more than For the purposes of CSR activities, Bank of America’s 40 countries and across our six business divisions, as standard of materiality is as follows: Issues that can have described in Chapter 3 of this report and our 2011 10-K a fundamental impact on the reputation or viability of the fling), as well as important social, environmental, and enterprise and/or impact on stakeholders’ decisions as to economic impacts. Our CSR report should be reviewed whether to do business with us. alongside the 2011 Bank of America annual fnancial report, where we provide additional facts, fgures and analysis.
Bank of America is committed to continued year-on-year improvement in the way we measure and report our performance. We will collect and assess feedback on this report from stakeholders, which will help determine the content, timing and format of our next report.
116 About This Report Media Coverage External Review Committee Summary We conducted a media scan of Bank of America coverage Third-party feedback on our report is critically important, in top-tier publications from January 2011 through so we again engaged Ceres, a nonproft organization December 15. While there were over 60,000 media based in Boston, to bring together a group of external mentions of “Bank of America,” our key fndings are stakeholders to provide input at two stages of the report representative of the issue areas that received the most development process: (i) identifying material issues; and coverage this year. Prominent topics included: (ii) reviewing an early draft of the full report. The Committee included representatives from: the Florida State Board •Litigation Issues: Coverage addresses legal issues, of Administration, PAx World Investments, Domini Social including lawsuits related to Countrywide Financial and Investments, Jantzi-Sustainalytics, the Nonproft Finance Fannie Mae and Freddie Mac mortgage-backed securities Fund, the Environmental Defense Fund, NRDC and Ceres. •Transparency: Coverage focuses on the extent to which the bank is transparent about its day-to-day operations The table on the next page features highlights of the and corporate business practices feedback provided by stakeholders as a part of this process and our response. • Customer fees and Satisfaction: Coverage reports on changes to consumer offerings, such as card usage fees, national Community Advisory Council and customer reactions to these changes and Business for Social Responsibility • Regulatory Reform: Coverage addresses changes in The Bank also received comments from representatives regulation and how these changes impact the bank of the Bank’s National Community Advisory Council (NCAC) • Data Security: Coverage reports on the security and and Business for Social Responsibility (BSR). While there accessibility of the bank’s customer information was a great deal of overlap in their suggestions and recommendations with those from the Ceres lead team, •Executive Compensation: Coverage reports on shifts in a few additional topics were discussed: the bank’s management and compensation for past and current executives •Context: The Bank should provide greater context to the •Business Outlook: Coverage refects stock price data reported on throughout the report. movements, quarterly earnings, analyst perspectives, •Globality: Some of the sections are too US-centric. The management changes and new business ventures Bank should expand global coverage in the report. •Management and Governance: The Bank should provide Internal feedback more discussion on how it manages ethics, compliance Through a series of interviews with our own subject- and CSR. matter experts and communication and CSR leadership •Policies: The Bank should provide greater detail on its team members, the following issues were identifed: environmental policies including any advocacy efforts on climate policy. •Consumerissues,includingdebitusagefee,creditcard •Beyond Consumers: The Bank should include more business, customer satisfaction discussion on how CSR is considered beyond consumer •Mortgagesandhousingissues,includingforeclosure, business. modifcation performance, repurchase settlement and • Emerging Issues: The Bank should provide greater detail commitment to the mortgage business on how the Bank is addressing emerging CSR issues for •Small-businesslending the fnancial sector, such as supply chain. •Bankoperations,includingbranchclosuresandposition reductions •Litigation,includingthosesettledandstillpending •Regulatoryreformissues(bothnationalandinternational) •Environmentalimpactthroughthebank’soperationsand business activities •Commitmenttomilitary •Campaignfinance •PoliticalturmoilintheMiddleEast
About This Report 117 In general, we agree with the recommendations made and Data Measurement and Assurance expect our reporting to continue to evolve to ensure we are WSP Environment & Energy USA was responsible for providing our stakeholders with the information they need the collection of environmental performance indicators and want. A key strategy in developing the 2011 report was including greenhouse gas emissions, energy consumption, to provide our readers with greater accessibility to more waste generation and water usage. Wherever possible, information and detail on issues being addressed. To that data was collected in conformance with GRI principles. end, throughout the report we have provided readers with Non-environmental data was collected by teams embedded access/links to our federal flings, Quarterly and Annual across our business lines and functions, including Reports and Proxy Statements. All of these documents Human Resources, The Bank of America Foundation, and provide greater context on issues covered as well as our Procurement. The completeness and accuracy of this data policies and practices. was checked in accordance with Bank of America’s internal legal and compliance review process. We also set out to deliver a report that provided a more global view of the bank and its operations. The reader Bureau Veritas North America (BVNA) conducted an will fnd the 2011 report includes more global information, independent review to confrm the accuracy and reliability data and case studies. We have also developed regional of this environmental data. Additionally, Bureau Veritas reports, and for our larger markets, country-specifc evaluated other reported data (e.g., economic, social, reports. These reports were not ready for our reviewers, human rights, society, product responsibility) against the but will be available by the time this report is released. principles of the GRI Reporting Framework as defned in We will continue to explore ways to expand the global the GRI G3 Sustainability Reporting Guidelines (see Bureau narrative even further in our 2012 report. Veritas North America’s statement on page 111).
We appreciate the time and thoughtful consideration our reviewers have given this report. Their comments and recommendations will be used to help develop and deliver a strong 2012 CSR report.
Finally, senior leaders of the bank have started a strategic review of our CSR policies, practices and programs with an objective to strengthen and expand current efforts, and further integrate CSR into the business.
118 About This Report External Review Committee feedback Bank of America Response In developing the 2011 Report, the bank undertook a rigorous materiality analysis to identify and validate the most pressing challenges and issues we faced in 2011; seeking both bank-wide internal and external stakeholder input and feedback. A Challenges. Stakeholders recommended that comprehensive overview of the materiality process can be found in Chapter 12. Bank of America identify and speak candidly The report was built upon this candid feedback, and key challenges are addressed about the challenges it is currently facing. in chapters focusing on strength and stability of the corporation, fairness and transparency in dealing with customers, clients and employees, our support of communities we serve, and our environmental sustainability initiatives.
As above, the materiality analysis was conducted with a wide array of internal Bank of America stakeholders, across lines of business and global geographies, Materiality. Stakeholders stressed the as well as external input from several stakeholder organizations. Our process is importance of comprehensively highlighting highlighted in Chapter 1, with a more comprehensive review in Chapter 12 of the the materiality analysis process. report. From the analysis process, the four key issues identifed above (and the basis for the focused CSR report narrative) were clearly identifed. integration. Bank of America should seek to tie its sustainability efforts including community In both philanthropic/community support and our environmental initiatives, the Bank initiatives, environmental business and has demonstrated strong investment programs with specifc goaled commitments as philanthropy to its core business operations cited in the 2011 report. We are exploring a more holistic sustainability strategy as — specifcally products and investments — part of our broader and evolving corporate social responsibility strategy. ensuring a holistic sustainability strategy.
The Bank has a rigorous risk management system, covered in high-level detail in risk Management. The CSR report should Chapter 4, and further in our 2011 10-K fling. Risk is managed in all areas and at provide details about Bank of America’s risk all levels of the bank. Our evolved risk framework was launched in early 2010, and management systems; clarifying how they continues to be foundational given the critical nature of managing and mitigating have evolved since the fnancial crisis and risk by every employee at Bank of America. Clearer integration of ESG risk and how ESG fts into the company’s assessment assessment practices into this general risk framework is a suggestion worthy of processes. further discussion inside the bank.
Context. When presenting data in the report, Based on this feedback, we have refned the report to include (as feasible) many stakeholders offered that it would be helpful year-over-year data points to show trends in key lending, investing and giving areas. for the company to provide added context While the bank has very strong investment initiatives in both environmental and (e.g. year-over-year trends, environmental philanthropic areas, we do not currently measure investments in specifc areas as a investments as percent of overall portfolio) percent of our overall portfolio. We will consider this feedback and suggestion as part to better understand the information. of our overall evolving corporate social responsibility strategy.
In 2011, we continued to seek counsel and candid feedback from both internal and external stakeholders for the report and our ongoing business and CSR efforts. We are committed to an ongoing dialogue with stakeholders as an embedded policy of Stakeholder engagement. Stakeholders strategy and program development, and will look for ways to continue demonstrating encouraged Bank of America to demonstrate this commitment in ongoing reports and communications. how it is incorporating feedback from stakeholders, both in its CSR report and A brief summary of the Bank’s political engagement is included in Chapter 4, with overall sustainability strategy and goals. additional information available online. We appreciate the suggestion, which we think is worthy of further discussion inside the Bank.
About This Report 119 120 About This Report CHAPTER 13
Contacts and General Information 13 | COnTACTS & GEnERAL InfORMATIOn
Bank of America Merrill Lynch Plan Participant Statement Information, Feedback earned the DALBAR Communications Seal in 2010. DALBAR, and Concerns Inc., a leading fnancial services research frm, reviewed defned contribution statements from 25 fnancial service providers and For more information on Bank of America’s programs and scored them based on four factors, including calculated to be performance described in this report, visit understood, primary content, secondary content and design www.bankofamerica.com/about. features. Bank of America Merrill Lynch’s Plan Participant Website was rated DALBAR’s highest designation “Excellent” by DALBAR’s We would greatly appreciate your feedback on this — what you WebMonitor Program for 2011. DALBAR, Inc. examined 45 websites liked and what you didn’t, topics you wanted more information tailored to Defned Contribution plan participants. Scores were on and those where you wanted less. Please contact the based on the quality and range of capabilities and content Bank of America CSR team by sending an email message to provided, ease of navigation and ability to locate information. Ernesto Anguilla, CSR Communications Executive, at DALBAR, Inc. is not affliated with Bank of America Corporation. [email protected]. Bank of America Merrill Lynch received 27 Best in Class Honors in 19 categories for both plan sponsor and participant services in To report concerns about Bank of America’s reporting, internal 2010. Ratings were based on results from 5,929 plan sponsors controls and procedures, auditing matters, or other corporate that replied to the 2010 PLANSPONSOR DC Survey questionnaire. matters, contact the Bank of America Board of Directors: 45 plan providers obtained the minimum required 35 survey Corporate Secretary at Bank of America Corporation responses to be considered for awards. “Best in Class” awards 214 N. Tryon St. are given to providers with top quartile scores in each survey NC1-027-20-05 category, across both participant and sponsor services, within Charlotte, NC 28255. eachplanassetsize:Micro(under$5million);Small($5–50 million);Mid($50–200million);Large($200million–$1billion); and Mega (over $1 billion). For additional details, please refer to the November 2010 issue of PLANSPONSOR Magazine or go to Disclaimers www.plansponsor.com. PLANSPONSOR is not affliated with Bank of America Corporation. Copyright © 2012 Bank of America Corporation. All rights Rated #1 in 2010 in Group 5’s annual study. Bank of America reserved. Merrill Edge is the marketing name for two businesses: Merrill Lynch’s satisfaction ratings are based on 2010 responses Merrill Edge Advisory Center, which offers team-based advice from 106 plan sponsors representing 257 equity compensation and guidance brokerage services; and a self-directed online plans in Group 5’s annual study of stock plan sponsors’ investing platform. Both are made available through Merrill Lynch, satisfaction with their plan administration service, conducted from Pierce, Fenner & Smith Incorporated (MLPF&S). May to July 2010. Group 5 is a leading consulting and market Banking products are provided by Bank of America, N.A. and research frm in the fnancial services industry. Group 5, Inc. is affliated banks, Members FDIC and wholly owned subsidiaries not affliated with Bank of America Corporation. of Bank of America Corporation. Investment products: MLPF&S is a registered broker-dealer, Member SIPC and a “Bank of America Merrill Lynch” is the marketing name for the wholly owned subsidiary of Bank of America Corporation. global banking and global markets businesses of Bank of America Bank of America Merrill Lynch’s Retirement & Benefts Contact Corporation. Lending, derivatives, and other commercial banking Center has been recognized by J.D. Power and Associates for activities are performed globally by banking affliates of providing “An Outstanding Customer Service Experience” for Bank of America Corporation, including Bank of America, N.A., sevenyearsinarow(2005–2011).Forcertificationstatus,a member FDIC. Securities, strategic advisory, and other investment call center operation must pass a detailed audit and perform banking activities are performed globally by investment banking with the top 20 percent of customer service, based on J.D. Power affliates of Bank of America Corporation (“Investment Banking and Associates’ cross-industry customer satisfaction research. Affliates”), including, in the United States, Merrill Lynch, Pierce, Certifcation is valid for one year. For additional information, visit Fenner & Smith Incorporated and Merrill Lynch Professional www.jdpower.com. J.D. Power and Associates is not affliated Clearing Corp., all of which are registered broker dealers and with Bank of America Corporation. members of FINRA and SIPC, and, in other jurisdictions, by locally registered entities.
122 Contacts & General Information
10% post-consumer content.