Our approach to materiality

Our approach to materiality is guided by our commitment to Responsible Growth and doing so in a sustainable manner, which helps us deliver returns to our clients and shareholders and help address society’s biggest challenges. We use these principles to evaluate the environmental, social and governance (ESG) issues that are most material to our company.

At all times, we listen to and engage with a diverse set of stakeholders who are interested in or directly affected by our company’s business. As part of this stakeholder engagement process, we listen to the feedback of our constituents, including shareholders, to help inform our decisions and our approach to disclosure. We do this through a variety of ongoing engagement and activity, including our National Community Advisory Council (NCAC), a forum made up of senior leaders from civil rights, consumer advocacy, community development, environmental, research, and other organizations who provide external perspectives, guidance and feedback on our business policies and products.

We also utilize ESG frameworks and ratings to guide our disclosures. ESG frameworks include: Global Reporting Initiative (GRI), Sustainability Accounting Standards Board (SASB), the Task Force on Climate-Related Financial Disclosures (TCFD), CDP, and the World Economic Forum's International Business Council stakeholder capitalism metrics (WEF IBC). ESG ratings include Morgan Stanley Capital International (MSCI), Sustainalytics and S&P. As regulators are increasingly focused on ESG, we are incorporating those recommendations into our materiality approach.

We then apply an internal lens through our risk management principles, an ESG Committee, and a particular focus on climate change and racial equality. The result is a dynamic, ongoing process to weigh this information and produce a view on how various priorities are ranked in terms of importance to core business success and importance to external stakeholders.

To initially establish our baseline, we worked with a third party, Business for Social Responsibility (BSR), which used our Operating Principles and focus on Responsible Growth as a framework to conduct interviews and analysis. Issues were weighted, prioritized and plotted on the following ESG Materiality Assessment Map according to their relative degree of importance. The Materiality Map was then reviewed and approved by the company’s ESG Group and Global ESG Committee. It is important to note that all issues on the Map — regardless of where they fall — were, and still are relevant to the company. These issues were drawn from a broader set of potential areas, many of which were deemed not to be pertinent to the bank. For clarity, we grouped issues as Governance, Environment, Society, or People (i.e., dividing Social issues into external and internal categories).

We used the results of our ESG Materiality Assessment as well as our ongoing approach to materiality to guide our ESG reporting and disclosures and to ensure transparency into ESG issues of greatest importance.

materiality chart


Chart shows topics on a quadrant chart with an x axis representing the increasing importance to business success and a y axis representing the increasing importance to stakeholders.

The top right quadrant shows a smaller quadrant chart illustrating Material ESG Issues for Bank of America. The x axis of this smaller chart represents the importance to business success and the y axis represents the importance to stakeholders.

In the smaller chart The bottom left, with a relatively lower priority to both business success and stakeholders, is "Monitor, comply, manage"
The bottom right, important to business success is "Continue internal efforts"
The top left, important to stakeholders is "Sustain and communicate"
The top right, with significance to both business and stakeholders if "Prioritize"

The remaining area of the larger chart represents other ESG areas and topics that may be relevant to other industries that were not identified as material ESG issues for Bank of America.

Materiality matrix

Initial map completed in 2016

ESG MATERIALITY MAP - Top Right Quadrant Detail

Chart shows the top right quadrant of the ESG Materiality Map - Overview, which is also a quadrant chart with an x axis representing the increasing importance to business success and a y axis representing the increasing importance to stakeholders.

There are four categories of topics - Governance, Social, Environment, and People.

The bottom left, with a relatively lower priority to both business success and stakeholders, contains two Governance items, "Lobbying and public policy engagement" and "Board diversity and independence"

Three Social items "Human rights practices", "Investor activism and proxy voting" and "Responsible sourcing"

Two Environment item "Natural resource management in operations and supply change", and "GHG/Non GHG emissions in internal operations and supply chain""

Five People items "Workforce reductions", "Employee knowledge of ESG issues", "Equal pay and wage gap", "Employee practices and benefits" and "Employee volunteerism"

The bottom right, important to business success contains one Governance item "Operating within the legal and regulatory environment"

One Social item "Retail branch strategy/presence"

One People item "Talent attraction and retention"

The top left, important to stakeholders contains two Governance items "Transparency, accountability, and reporting" and "Zero-tolerance conduct/grievance mechanisms"

One Social item "Access to finance"

The top right, with significance to both business and stakeholders contains Five Governance items "Data privacy and security", "Employee incentives and risk culture", "Systemic risk management", "ESG integration in financial analysis" and "Ethical behavior"

Four Social items "Consumer financial health", "Community investment", "Wealth inequality" and "Consumer financial protection"

One Environment item, "Financing transition to low-carbon economy"

One People item, "Employee diversity"

Definition of Issues


  • Board diversity and independence: This includes efforts to improve the diversity of Bank of America's board structure, as well as its independent oversight of the company, governance of sustainability, and role of CEO/chairman.
  • Business conduct and culture/grievance mechanisms: This includes having a culture in which bad conduct is not tolerated internally or with clients and employees speak up and are comfortable enough to raise risks or conduct issues that can negatively impact the company, without fear of retribution. Additionally, this includes providing formal grievance mechanisms' for employees to utilize to communicate and report on issues.
  • Employee incentives and risk culture: This includes the ways in which Bank of America promotes an effective risk culture throughout the organization, including appropriate incentives, risk management training, and leadership enforcement.
  • Equal pay and wage gap: This includes the social and market justification for high executive compensation relative to average worker salaries, equitable pay between women and men, and ensuring fair wages for lower level employees.
  • ESG integration in financial analysis: The explicit inclusion of ESG analysis into traditional financial analysis and investment decisions based on a systematic process and in all asset classes, including ESG investment and lending products, policies, and services.
  • Ethical behavior: This includes the promotion of high standards of ethics in business behavior and with business partners and working against corruption, extortion, and bribery in all markets in which the Bank operates or does business.
  • Lobbying and public policy engagement: This includes the lobbying efforts and political contributions made by Bank of America to governments and institutions of political influence (e.g., Super PACs), its relationships with public authorities, and its public policy and market influence.
  • Operating within the legal and regulatory environment: This includes the Bank's approach to managing legal and regulatory issues, including those related to non-compliance with relevant financial sector regulations, such as fines and settlements associated with mortgage industry regulations.
  • Systemic risk management: This includes Bank of America's overall approach to assessing and managing risk across the business and within individual business units, product and services, and transactions, across all geographic locations.
  • Transparency, accountability, and reporting: This includes efforts to provide clear and comparable business and sustainability information in an accessible manner.


  • Access to finance: This includes the development of and increased access to financial products and services, including through technology solutions, for unbanked and underbanked segments and different customer demographics, such as the aging population.
  • Community investment: This includes strategic lending, investing and philanthropy to support community economic development.
  • Consumer financial health: This includes efforts to address and improve consumer financial security, including through financial literacy programs, lending, and products and services designed to improve financial security.
  • Customer financial protection: This includes ensuring the marketing and communications of products and services is honest, transparent and fair and managing customer risks, including management of lending to at-risk borrowers, credit requirements in low- and moderate-income demographics, loan modifications, overdraft protections, low balance alert systems, and other approaches to ensuring the safety of financial products offered by the Bank. This also includes efforts to engage with consumers to understand their perception of and level of satisfaction with Bank of America products and services, and efforts to ensure that products meet or exceed customer expectations.
  • Data privacy and security: This includes Bank of America's approach to identifying and addressing vulnerabilities and threats to customer and employee data security, safeguards for preventing fraudulent transactions and breach of privacy or data security, and responsible use of big data.
  • Retail branch strategy/presence: This includes the activity surrounding local, regional, or national bank branches, including branch closures and expansions, the ways in which branches enable access to finance, help to meet individualized needs of customers, and the location of branches in underbanked communities.
  • Human rights practices: This includes Bank of America's exposure to human rights issues and its policies and procedures related to risk and impact assessments in investments (e.g. UN Declaration on Human Rights).
  • Investor activism and proxy voting: This includes active voting of proxies on behalf of investors that involve specific ESG issues (e.g. board diversity, lobbying disclosure, etc.)
  • Responsible sourcing: This includes supplier diversity and efforts to meet or exceed internationally agreed labor standards in working hours and conditions, wages and benefits, wage changes, labor shortages, health and safety, and humane treatment of workers employed in the supply chain.
  • Wealth inequality: This includes the ways in which the Bank uses its position and business strategy to respond to and address rising income and wealth inequality.


  • Natural resource management in operations and supply chain: This includes the responsible management of energy, water, and waste in Bank of America's operations and supply chain. This includes efforts to improve energy efficiency, use renewable energy sources. reduce waste, conserve water use, and implement water-saving measures.
  • Financing transition to low-carbon economy: This includes establishing investment policies and offering products and services that enable clients, and other industries to mitigate their environmental impacts and build adaptive capacity in the context of a changing climate (e.g. providing financing solutions for clean energy) and also the bank's efforts in reducing investment in products and services with financial exposure to high GHG emitting sectors (e.g. coal).
  • GHG/Non GHG emissions in internal operations and supply chain: This includes efforts to reduce GHG and Non-GHG emissions, such as VOCs, ODCs, NOx, SOx, particulate matter, etc. This includes efforts to reduce GHG emissions from employee business travel.


  • Employee diversity: This includes efforts to ensure the company workforce reflects its global business and clients and efforts to ensure workplace practices reflect a commitment to equity.
  • Employee knowledge of ESG issues: Communication and training for key employee groups to develop knowledge and experience in understanding and evaluating ESG issues and risks.
  • Employee volunteerism: This includes Bank of America-supported efforts by employees to volunteer in their local communities or provide monetary contributions to qualified organizations.
  • Employment practices and benefits: This includes efforts to provide a decent wage, health and safe work environment, and work life balance, such as providing vacation time, paid medical and parental leave, flexible work arrangements, wellness programs, and wellness incentives.
  • Talent attraction and retention: This includes company's ability to attract and retain top talent and its efforts to promote professional growth and measure and improve employee satisfaction.
  • Workforce reductions: This includes efforts to manage the negative impacts of workforce reductions.