Environmental Policies, Organization and Management

ank of America associates receive information about environmental programs, criteria and guidelines through their managers, departmental procedure updates and internal communications. Associates can also access information and programs on the corporate Intranet Web site.

BANK OF AMERICA ENVIRONMENTAL COMMITMENT

The Bank of America Environmental Commitment is a corporate wide commitment. Quarterly management reports and the bank's annual report will highlight the bank's progress in support of this commitment.

ORGANIZATION AND MANAGEMENT RESPONSIBILITY

The Bank of America Technology and Operations executive, reporting to the Chairman and CEO, serves as the executive environmental officer and has overall accountability for the bank's Environmental Commitment.

The organizational structure:

• Environmental Advisory Group: This group is responsible for leadership, oversight and review of the Environmental Commitment. Members include the executive environmental officer, four executive managers from the bank's Management Operating Committee, and the following three associate positions:
  • Senior Vice President of Environmental Initiatives. Responsibilities of this position include reporting on the bank's Environmental Commitment, implementing programs, ensuring environmental advocacy, networking and partnering with internal and external stakeholders and generating new ideas for enhancing the overall Environmental Commitment.
  • Senior Vice President of Environmental Services. This associate leads the team responsible for due diligence on transactions that require environmental oversight and provides environmental risk management expertise and information to lending officers franchise wide.
  • Senior Vice President of Supply Chain Management. This associate leads a team whose task is meeting the bank's goal of reducing the impact of internal operations. The team is made up of associates from the bank's Procurement & Corporate Services, Corporate Real Estate, Technology & Operations and Personnel.
• The executive environmental officer shares quarterly Environmental Initiatives reports with senior management. An Environmental Progress Report is sent annually to all senior management and the board of directors.

ENVIRONMENTAL GUIDELINES

Global Corporate & Investment Banking Credit Policy Guide

Environmental Matters:
These guidelines instruct banking officers to use environmental sensitivity when making decisions on providing core business products and services such as credit, investment, underwriting and payments. These guidelines support the practice of making special efforts to identifying ways to finance projects and companies that benefit the environment and staying away from financing projects and companies whose environmental practices fall short of acceptable standards. The bank considers environmental practices acceptable if they meet industry standards, conform to World Bank guidelines and comply with applicable law.

Developing Countries Lending Criteria:
When extending new loans and other credit commitments to developing countries, Bank of America will consider not only the borrower's capacity and willingness to repay, but will also consider social policy, the purpose of the transaction and the impact on the local populace. These guidelines cover such areas as impact on the environment, cultural and social structures and human rights.

CERES Principles:
By adopting the CERES (Coalition for Environmentally Responsible Economies) Principles, Bank of America publicly affirms its belief that corporations have a responsibility for the environment and must act as responsible stewards of the environment by conducting all aspects of business in a manner that protects the earth. Bank of America believes corporations must not compromise the ability of future generations to sustain themselves. Bank of America updates its practices in light of advances in technology and new understandings in health and environmental science. In collaboration with CERES, Bank of America also promotes a dynamic process to ensure the principles are interpreted in a way that accommodates changing technologies and environmental realities. Bank of America will continue to make consistent, measurable progress in implementing these principles and will apply them to all aspects of its operations throughout the world.

Climate Change Position:
In 2002, the bank's Environmental Advisory Group reviewed the climate change issue. The group recognized, if not checked, climate change and atmospheric pollution could alter the natural, social, and economic systems that support a growing global economy.
Based on the advisory group's recommendation, Bank of America approved a climate change position summarized as follows:

Recognizing that climate change and atmospheric pollution do indeed represent a risk to the ultimate stability and sustainability of our way of life and our business, Bank of America will take action including:

• Assessing our direct effect on green house gases
• Reducing our energy consumption
• Working with others to find solutions
• Assessing the risk to our business
• Informing our associates
• Reporting on goals, actions and progress

The bank's enterprise risk management executive is the executive champion for this effort and Environmental Initiatives will act as project manager. Bank of America will continue to monitor the issue and, as needed make adjustments to its position and actions.

SUSTAINABILITY

The Bank of America Enviro-Team partnered with The Natural Step, an international advisory and research non-profit organization, to hold a sustainability workshop. The objectives were to educate the participants in sustainability and provide them with a broader context and a framework for the environmental work they are currently engaged in. Enviro-Team members, made up of associates from Supply Chain Management, Corporate Real Estate and Technology & Operations, are aligned to each of our major cross-functional commodity councils to help drive out the environmental strategy and to educate the commodity council members on environmental sustainability. The team developed an Environmental Training Toolkit for training commodity councils.

The end result included Supply Chain Management's adoption of an Environmental Sustainability Mission and Guiding Principles/Strategies. (See Section 6 for more details.)

See The Natural Step case studies at: http://www.naturalstep.org/learn/case_summaries.php

Although Bank of America has not adopted a sustainability policy, we are committed through our endorsement of the CERES Principles to achieve progress in meeting those principles (see Appendix One). The Principles are built on pursuing a sustainable economy and environment. The bank's community development lending, diversity and multi-cultural programs, foundation grants and long-time involvement in the communities we serve also illustrate our support of equitable opportunities for all our communities.

BANK OF AMERICA ASSOCIATE RESPONSIBILITY

Another Bank of America goal is to integrate environmental sensitivity and consideration into our business decisions, practices and processes. Success will be the result of a change in the way we do business, rather than a special program. While Environmental Initiatives is an internal advocate and a change agent within our corporate culture, it is the tens of thousands of associates throughout the company whose enthusiastic support and hard work actually make the commitment a reality. The progress documented in this report was accomplished by the many associates who are responsible for the implementation of the Bank of America Environmental Commitment through their job responsibilities and as champions for the environment.

Associate Engagement
Associates regularly participate in the bank's Environmental Commitment through the Team Bank of America Environmental Networks. The Environmental Networks engage associates in activities that promote our Environmental Commitment and help establish Bank of America as a leader in working to achieve a society that seeks a sustainable economy.

GOALS OF THE ENVIRONMENTAL NETWORKS

• Help associates understand why an active environmental program and ethic should be part of our corporate culture
• Help associates engage in environmental best practices and activities at work, at home and in their communities
• Provide measurable results of Environmental Network activities to demonstrate the positive effects of corporate environmental responsibility
• Encourage professional development and networking opportunities

In 2002, Team Bank of America Environmental Network had 38 networks nationally. Examples of projects include:

• A car pooling database
• Associate education about commuter choices and supported local transit programs
• A greeting card recycling program
• The International Coastal Clean up and ongoing adopt-a-beach volunteer projects
• The donation of old cell phones to an organization that assists victims of domestic violence
• Donating unused binders to local schools
• A battery collection program
• The recycling of 2.3 tons of old phone books
• Cleanup projects in community parks, rivers, and highways
• A computer and equipment clean up day
• Volunteering at local Earth Day events and lunchtime associate environmental fairs
• A community garden and an annual associate children's poster contest

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