BCE Inc

BCE's Chief Legal and Regulatory Officer has overall responsibility for (among other things): [...] oversight of BCE's ethics program, including the Code of Business Conduct and ethics training; our anonymous and confidential 24/7 Business Conduct Help Line that assists employees with any ethical issues and provides a means by which to report breaches of the Code of Business Conduct or any Bell policy and to report issues relating to questionable accounting, internal controls, auditing matters, corporate fraud or corruption; and oversight of BCE's corporate policy management framework, designed to improve employee awareness of, and access to, core corporate policies and business unit-specific practices, processes and procedures. [...] The most significant corporate-wide policies with respect to business ethics are the Code of Business Conduct, the Complaint Procedures for Accounting and Auditing Matters, the Disclosure Policy and the Auditor Independence Policy. These policies are available in the governance section of our website at BCE.ca.

In order to achieve our targets and address climate change risks and opportunities, we need collaboration from our employees, suppliers and other supply chain partners. This is why we are focussed on implementing a strong governance structure starting from the top. The BCE Board of Directors (the Board) has established clear lines of authority and oversight regarding the assessment and management of climate-related risks and opportunities, with primary accountability at the Board committee level. The management and oversight of climate-related matters have been integrated into the roles and responsibilities of executives, management and other team members. Remuneration is linked to the successful delivery of our corporate-wide climate change strategy through the evaluation of progress against climate-related objectives and targets. The chart on the next page provides an overview of our governance structure related to climate change (CC). [...] The Energy Board collects energy-related information from teams responsible for value creation, communications, fleet, network and building management, and analyzes such information to seek to ensure alignment with our climate-related strategy and operational objectives. In addition, the Climate Resiliency Taskforce has started analyzing the vulnerability of our critical buildings and developing mitigation plans to help make them more resilient to the impacts of climate change. Pertinent trend analysis and recommendations are subsequently reported to the HSSEC Committee, the final arbiter of climate-related strategy at the operational level. The HSSEC also oversees the implementation of recommendations across all of Bell and reports progress to the RPFC.

Regular reports are provided to the Audit Committee and the Governance Committee with respect to our ethics program and oversight of corporate policies across BCE. BCE's Chief Legal and Regulatory Officer has overall responsibility for (among other things): [...] • [oversight of BCE's ethics program, including the Code of Business Conduct and ethics training;] [...] • [oversight of BCE's corporate policy management framework, designed to improve employee awareness of, and access to, core corporate policies ] and business unit-specific practices, processes and procedures.

The Board of Directors has established clear lines of authority over, and oversight of, our corporate responsibility programs and our approach to ESG practices, with primary accountability at the committee level. The Corporate Governance Committee (CGC) is responsible for oversight of our corporate purpose and our ESG strategy and disclosure, which includes oversight and related disclosure of climate-related risks. It is also responsible for our governance practices and policies, including those concerning business conduct and ethics. [...] Moreover, the Risk and Pension Fund Committee (RPFC) oversees environmental and security risks, including data governance and cybersecurity, while the Management Resources and Compensation Committee (MRCC) has oversight of human resource issues, including respectful workplace practices, health and safety, and tracks corporate performance against our ESG targets. In 2020, the MRCC formally added ESG targets to corporate performance metrics, establishing a link to compensation. Furthermore, as of 2022, additional ESG related metrics were added and are embedded into each of the strategic imperatives, which is reflective of how ESG is embedded into the overall strategy of the business. ESG is targeted to represent, in aggregate, at least 30% of the total strategic imperatives score in 2022. The MRCC reviews the detailed metrics and targets and approves them early in the year, tracking as well as key performance metrics such as community investment, greenhouse gas emissions reduction, ISO recertification, team member engagement, the time lost accident frequency rate and waste management. These metrics can be found under the key metrics section of this report. In addition, EVPs have 30% of their annual bonuses tied to personal objectives that include a variety of corporate responsibility topics. [...] At the management level, the Health, Safety, Security, Environment and Compliance (HSSEC) oversight committee is mandated to make every effort to ensure that our corporate responsibility strategy is integrated throughout the business in order to minimize risk and optimize business opportunities. This committee is co-chaired by the Chief Human Resources Officer (CHRO) & Executive Vice-President (EVP), Corporate Services and the Chief Legal & Regulatory Officer who report to the RPFC, CGC and the MRCC.

The results of the scenario analysis were provided to BCE's Health, Safety, Security, Environment and Compliance (HSSEC) Oversight Committee, Corporate Governance Committee (CGC) and Risk and Pension Fund Committee (RPFC). This enables these committees to review the potential financial impacts from climate change and equips them with the information needed to incorporate climate-related risks and opportunities into future decision-making and strategic planning. [...] The Energy Board collects energy-related information from teams responsible for value creation, communications, fleet, network and building management, and analyzes such information to seek to ensure alignment with our climate-related strategy and operational objectives. Pertinent trend analysis and recommendations are subsequently reported to the HSSEC Committee, the final arbiter of climate-related strategy at the operational level. The HSSEC also oversees the implementation of those recommendations across all Bell business units and reports decisions and progress to the Board's RPFC.

The Board is actively engaged in the strategic management of corporate responsibility issues, and receives regular reports on performance. The Board of Directors has established clear oversight of our corporate responsibility programs and our approach to ESG practices, with primary accountability at the committee level. The Corporate Governance Committee (CGC) is responsible for the oversight of our corporate purpose and our ESG strategy and disclosure, which includes oversight and related disclosure of climate-related risks. It is also responsible for our governance practices and policies, including those concerning business conduct and ethics. [...] The Health, Safety, Security, Environment and Compliance (HSSEC) oversight committee is mandated to make every effort to ensure that our corporate responsibility strategy is integrated throughout the business in order to minimize risk and optimize business opportunities. Accordingly, Bell is focused on implementing adaptation governance structures and measures to maintain the resiliency of our operations and the security of our team members. We also monitor the potential for current and future climate-related legislation, policy and regulations that may affect our business, and report on these findings to our internal HSSEC Oversight Committee. The HSSEC Oversight Committee periodically oversees health and safety, security, environmental and compliance risks, and ensures that they are addressed through efficient programs implemented within the various business units. This committee is co-chaired by the Chief Human Resources Officer (CHRO) & Executive Vice-President (EVP), Corporate Services and the Chief Legal & Regulatory Officer who report to the Risk and Pension Fund Committee (RPFC), the Corporate Governance Committee (CGC) and the Management Resource and Compensation Committee (MRCC) of the Board of Directors, in accordance with their respective Committee Charters. [...] In order to support the evolution of our corporate responsibility strategy, in 2021 we created an internal Corporate Responsibility (CR) Board composed of 50 Bell leaders (directors, Vice Presidents and senior Vice Presidents). The CR Board meets quarterly and its responsibilities include the following: - Embed corporate responsibility considerations into corporate and business strategies, - Help identify corporate responsibility areas of further improvement, - Establish relevant KPIs, - Support our corporate responsibility disclosure, - Respond to stakeholders' concerns, and - Support various corporate responsibility initiatives. Reports on progress are provided to the HSSEC Oversight Committee, which reports to the RPFC of the BCE Board.

The Board has overall responsibility for supervising the management of BCE's business and affairs, which includes taking into account the effects of climate change. The Board has established clear lines of authority and oversight over our climate-related risks and opportunities, with primary accountability at the Board committee level. [...] The CGC is responsible for the oversight of our corporate purpose and our ESG strategy (including our climate change strategy) and disclosure, including integration of ESG within the company strategy and monitoring the implementation of ESG programs, goals and key initiatives. It is also responsible for our governance practices and policies, including those concerning business conduct and ethics, and approves the Strategic Overview section of the Integrated annual report. The committee receives quarterly ESG updates. Specifically for climate change, the CGC approves our climate change strategy and monitors our performance against our climate change targets (carbon savings enabled by the use of Bell's technology and GHG reduction targets). The CGC monitors climate change risks and opportunities, reviews and monitors the disclosure of our climate change risks and assumptions. [...] The RPFC oversees the enterprise risk governance framework and the company's exposure to key ESG risks that may result in significant operational, financial, legal or reputational impacts. Business continuity and environmental risks, including those related to climate change, are among the RPFC's responsibilities. The committee receives quarterly reports from management and conducts at least one annual detailed review of Bell's environmental programs. These reports allow the RPFC to review and monitor Bell's performance against climate change targets, its climate change risks and opportunities and the disclosures on these risks and their underlying assumptions. [...] The MRCC has oversight of human resources issues, including respectful workplace practices, diversity, equity, inclusion and belonging, team survey results, human rights and health and safety. The committee tracks corporate performance against our ESG targets. Our climate change targets are part of the ESG targets linked to compensation. [...] The Audit Committee is responsible for overseeing financial reporting and disclosure, and the organization's internal control systems and compliance with legal requirements. The Audit Committee monitors the climate change risks and approves climate change risks and assumptions disclosures. [...] While the Board is responsible for BCE's risk oversight program, management has established a governance framework through the Health, Safety, Security, Environment and Compliance (HSSEC) Oversight Committee. The HSSEC Committee oversees health and safety, security, environmental and compliance risks, and seeks to ensure they are addressed through efficient programs implemented within the various business units. In addition, two management committees, the Energy Board and the Corporate Responsibility Board, report to the HSSEC Committee. [...] The HSSEC Committee is mandated to ensure that our corporate responsibility strategy is integrated throughout the business in order to minimize risk and maximize business opportunities. This committee is co-chaired by the Chief Human Resources Officer (CHRO) & Executive Vice-President (EVP), Corporate Services, and the Chief Legal & Regulatory Officer who report to the RPFC, CGC and the MRCC. Its members include a significant number of Bell's most senior leaders including the Chief Financial Officer (CFO), Chief Technology and Information Officer (CTIO), and Group President, Customer Experience. [...] The cross-functional composition of the HSSEC seeks to ensure that relevant risks are adequately recognized, that mitigation activities are well integrated and aligned across the organization, and that sufficient resources are in place. The HSSEC Committee also looks to maximize business opportunities and to ensure that these opportunities are integrated and aligned across all parts of our business. More specifically, the HSSEC Committee is required to: - review our corporate responsibly (CR) vision and guiding principles – including our climate change strategy – based on recommendations from the Corporate Responsibility & Environment (CR&E) team and recommend it for approval by the CGC of the Board, - assess emerging CR issues and trends, such as climate change, and provide recommendations on appropriate positioning for Bell, - review and approve Bell's Environmental Policy and CR objectives and monitor their progress and achievement on an annual basis, - approve operational strategies and objectives to address specific environmental issues including climate change. Review the results from our most recent Climate scenario analysis exercise and monitor the progress of implementation of climate change mitigation measures, and - report to the RPFC any incidents or material issues in complying with Bell's Environmental Policy. [...] We created the Energy Board in 2008 and tasked it with the responsibility of continually improving our energy performance. The Energy Board is a senior management-level committee reporting to the HSSEC Committee. It is composed of vice-presidents, directors, managers and specialists from across the company. The Energy Board's specific mandate is to ensure the ongoing effectiveness of our energy management system. It identifies and supports the implementation of energy-saving initiatives in our facilities (buildings, communications network and IT infrastructure), in our vehicle fleet and in our efforts to substitute travel with technology. The Energy Board also oversees progress toward meeting our targets for reducing GHG emissions. [...] The CR Board is a senior management-level committee. It is mandated by the HSSEC Committee to support the evolution of our corporate responsibility strategy, and to proactively manage ESG topics in an integrated fashion. The CR Board establishes processes for preparing, verifying and approving ESG information to be contained in public disclosure documents, which include our climate change disclosure. Climate change targets and related disclosure are reviewed by the CR Board. [...] Carbon Reduction Task Force: We created BCE's Carbon Reduction Task Force in 2023 to develop and closely follow the implementation of our strategy to meet our GHG emissions reduction targets. The task force is composed of internal stakeholders involved in the governance of corporate climate change mitigation. It reports its progress to the Energy Board. Acting on its governance role, the task force has developed VP-level targets and is exploring internal carbon pricing. The task force also developed a carbon emissions dashboard to report progress to the RPFC. [...] Carbon Innovation Working Group: The Carbon Innovation Working Group (IWG) is a cross-functional team reporting to the Carbon Reduction Task Force. The IWG uses its expertise and access to new technologies to implement certain GHG-saving initiatives. Other initiatives are evaluated, prioritized and recommended for funding through the Green Budget, a dedicated annual fund to decarbonize our operations. The IWG also establishes a process to consider energy and GHG emissions impacts from the onset of any new business project at both the design and procurement stages. [...] Climate Resiliency Task Force: The Climate Resiliency Task Force brings together key internal stakeholders who assist in building a strong climate resiliency governance to address the potential impacts of climate change in the short and medium terms. This includes physical climate-related risks such as natural disasters and increases in mean temperatures.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]Bell's Corporate Responsibility and Environment (CR&E) team, which drives our internal mandate as it relates to our climate change strategy, makes every effort to seek to ensure our CR strategy is well integrated throughout the business in order to minimize risk (such as financial and reputational) and optimize business opportunities. The CR&E team's managers also have part of the variable portion of their compensation tied to social and environmental goals, which include our GHG emissions reduction targets.

Moreover, we rigorously apply a global strategic approach to managing corporate responsibility and have an effective, practical environmental management system (EMS). Our EMS has been certified ISO 14001 since 2009, making us the first North American communications company to be so designated. Our environmental programs (including that on climate change), which form the foundation of our company-wide EMS, are integrated throughout Bell's business units and subsidiaries and are governed by local environmental coordinators. Each environmental coordinator reports to the CR&E governance team on action plans and results throughout the year. Thanks to our continued diligence in constantly improving our environmental management system and processes, we have been certified ISO 14001 for 13 consecutive years.

In addition, Bell Canada's energy management system was certified ISO 50001 in 2020, making us the first North American communications company to be so designated. The international ISO 50001 standard requires companies to adopt a strict set of energy management objectives, guidelines and practices that enable energy efficiency and associated reductions in GHG emissions.

The CR&E team works closely with all business units within Bell, including the Legal and Government Affairs (GA) teams to seek to ensure that our engagement activities are consistent with our overall climate change strategy. Bell's Chief Human Resources Officer & Executive Vice President, Corporate Services (CHRO) and the Chief Legal & Regulatory Officer (CLRO) are the co-chairs of our Health, Safety, Security, Environment and Compliance Oversight Committee (HSSEC Committee), which oversees our climate change strategy. The HSSEC Committee seeks to ensure business units are informed of strategy and compliance measures.

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]No, and we do not plan to have one in the next two years

Describe the process(es) your organization has in place to ensure that your external engagement activities are consistent with your climate commitments and/or climate transition plan?[…]Bell's Corporate Responsibility and Environment (CR&E) team, which drives our internal mandate as it relates to our climate change strategy, makes every effort to seek to ensure our CR strategy is well integrated throughout the business in order to minimize risk (such as financial and reputational) and optimize business opportunities. The CR&E team's managers also have part of the variable portion of their compensation tied to social and environmental goals, which include our GHG emissions reduction targets.