Bank of America

In terms of senior leadership accountability, the responsibility for sustainability issues lies with Bank of America’s board of directors. On gender equality and diversity, the financial institution publicly commits to gender equality and women’s empowerment and has gender-balanced representation among its senior leaders; 42% of positions are held are women. The financial institution describes its approach to engagement on sustainability themes and impact topics and publishes case studies describing where it has engaged successfully with clients and investees on sustainability themes and impact topics. Regarding trade associations, Bank of America, discloses a list of associations of which it is a member including sustainability- and non-sustainability-related organisations.

As a member of the Glasgow Financial Alliance for Net Zero (GFANZ), Bank of America has set a target of net-zero financed emissions by 2050. Additionally, the financial institution discloses the aggregate amount and share of financing it devotes to climate solutions, while specifying what these solutions are.

Bank of America has a publicly available policy statement committing it to respect human rights. It also has a grievance mechanism accessible to all workers and external stakeholder to raise human rights, as well as bribery and corruption, concerns and complaints. In regard to financing for usually excluded groups, the financial institution discloses the amount of finance it directs towards small- and medium-sized enterprises. Finally, in terms of workforce diversity, Bank of America discloses a breakdown of its total direct operations workforce for each employee category by gender, race and ethnicity.

In terms of its approach to senior leadership accountability, Bank of America could clarify whether it links the remuneration of the group’s executive and management teams to sustainability performance criteria. Regarding female representation in leadership positions, women are underrepresented on the board of directors where only 5 out of 14 board members are women. Furthermore, the financial institution could disclose the ratio of basic salary and remuneration of women to men in its total direct operations workforce for each employee category. Finally, Bank of America has an opportunity to disclose the actions it takes to address any pay gaps.

While Bank of America has intensity-based interim targets for its auto manufacturing, energy and power generation sectors, it has an opportunity to disclose an interim absolute financed emissions reduction target which covers all its financing activities. Moreover, while the financial institution discloses the key sectors it has identified as priorities to engage with on the topic of climate change, it has an opportunity to disclose the rationale for choosing these priorities. The financial institution aims to mobilise USD 1.5 trillion in sustainable finance by 2030, however the financial institution could disclose time-bound targets explicitly for its climate solutions. Regarding nature and biodiversity, no evidence was found that Bank of America is committed to minimising its negative impacts or financing regenerative solutions.

Bank of America has an opportunity to describe the process for identifying its human rights risks and impacts through its relevant financing activities. In regard to workforce diversity, while the financial institution discloses the ages of its board of directors, it has an opportunity to disclose this information for each employee category. Furthermore, while the financial institution has a health and safety policy, it does not use strong enough language to constitute a true commitment to health and safety. Finally, Bank of America has an opportunity to disclose the amount of finance directed towards usually excluded groups or low-income developing countries.