Bank of America Corp

Highlights of progress since our last report [...] Created the Sustainability Transaction Forum to review and discuss sustainability transactions in Global Banking with potential reputational risks to determine and recommend further action. [...] Appointed a Corporate Sustainability Controller to oversee the controls and governance around our climate reporting. [...] Board of Directors oversight [...] The Company's Board of Directors (Board) oversees the business and affairs of the Company, providing active and independent oversight of management, including its development and execution of our climate-related activities. [...] The Board and the committees that report to it regularly discuss climate-related topics through various channels. For example: - The Board receives periodic presentations from management on the Company's climate-related activities and climate-related risk management practices and opportunities. - The Board's CGESC, which has specific responsibility for overseeing the Company's environmental and social sustainability-related activities and practices, regularly reviews the Company's climate-related work and policies. - The Board, in coordination with its Enterprise Risk Committee (ERC), oversees climate risk—a risk that spans across all key risk types—as set forth in the Company's Board- and ERC-approved Risk Framework and Risk Appetite Statement (RAS). To this end, the Board and the ERC receive quarterly risk reporting and periodic deep dives that address and provide updates on key and emerging risks, including climate risk. - The Board, through its Audit Committee, periodically reviews the Company's enterprise climate disclosures in its financial reports filed with the U.S. Securities and Exchange Commission (SEC). The Audit Committee also receives regular updates on global developments in climate-related reporting. Key topics covered with the Board and/or its committees include our sustainable finance activities, updates on the execution of our Net Zero goal, our 2030 emissions reduction targets related to our financing activities, climate-related oversight requirements, regulatory landscape and the continued enhancement and evolution of the climate risk management efforts. [...] Supporting the Board in its oversight of climate-related activities are management-level committees comprised of senior leaders across every major LOB and control function. Among these, the Management Risk Committee (MRC), co-chaired by our chief executive officer (CEO) and chief risk officer, oversees risks facing the Company, taking into consideration climate risk, which spans across all key risk types. The MRC reports to the Board's ERC and is supported by subcommittees organized by risk type (e.g., credit, market, operational) and LOB, which also review the implications of climate-related risks. [...] The Responsible Growth Committee (RGC) is responsible for overseeing the Company's mandate to grow in a sustainable manner and works to accelerate our progress on environmental and social initiatives, including climate. The RGC is co-chaired by our chief administrative officer and our vice chair, who was formerly our chief financial officer, and currently oversees the Company's sustainability activities and stewards our work and progress to achieve our Net Zero goal. Its members are comprised of senior leaders representing each LOB and control function. The RGC is accountable to the CEO and is supported by the ESG Disclosure Committee, which is responsible for reviewing and providing oversight of our climate and other sustainability-related public disclosures. [...] The RGC engages in dialogue and debate on sustainability issues that are significant to our business. It escalates relevant sustainability matters and related risks to the CGESC and to the MRC, respectively. It is charged with providing overall leadership for the Company in environmental and social areas, and it monitors our focus on climate transition and sustainable finance across our LOBs as we work to meet our Net Zero goal. The details on our approach to Net Zero and the 2030 Financing Activity Targets outlined herein were approved by the RGC and reviewed by senior management and the Board. [...] We have established a climate program, which includes various workstreams to help achieve our climate objectives (Climate Program). The Climate Program Executive Steering Council (Climate SteerCo) coordinates and integrates the capabilities required to drive the execution of our work in these areas. Additionally, the Climate Risk Council, which consists of leaders across risk, LOBs and control functions, meets routinely to discuss our approach to managing climate-related risks in line with our Risk Framework. This council is overseen by the climate and environmental risk executive, who reports to the corporate social responsibility (CSR) and environmental risk executive, a member of the chief risk officer's leadership team. [...] In addition, since our last report, we have established the role of corporate sustainability controller to oversee the controls and governance around our climate reporting. [...] Our governance framework establishes oversight of our climate strategy by the Board and management-level committees. Additionally, across the first and second lines of defense, we have routines in place to help deliver decisions in a timely manner, escalate risks and issues for solutions, and achieve milestones. [...] Global coverage Sustainability-related strategic, risk and regulatory governance routines are conducted in each region (Europe, Middle East and Africa (EMEA), Latin America (LATAM) and Asia Pacific (APAC)) and for certain legal entities, as needed. These councils and steering groups provide management oversight of activities related to the financial risks and opportunities from climate change and of sustainability-related regulatory requirements. [...] The Global Environmental Group (GEG) within the Global Public Policy group is an enterprise advisory function that oversees our environmental policies, including our work to drive progress toward our Net Zero goal and other environmental commitments. The group also catalyzes and supports the development of low-carbon business activity, the achievement of greenhouse gas (GHG) emissions reductions and carbon neutrality across our operations, the development of environmental positions and practices (e.g., Environmental and Social Risk Policy Framework (ESRPF)) and the monitoring and reporting of environmental activities. This team works across the enterprise to help embed our environmental work into our business in support of Responsible Growth and a just transition, across the globe and in the communities we serve. [...] As part of the Climate Program and to streamline decision-making related to our approach to reaching our Net Zero goal, in 2022, GEG formed the FAMS workstream, directed by senior leaders within the Global Environmental Group and LOBs including Global Corporate & Investment Banking, Global Commercial Banking and Business Banking. The FAMS workstream leads the development of the strategy associated with the Company's Net Zero goal, all methodological decisions related to financing activity emissions (including calculations and targets), and management of many of the alliances and organizations with which the Company is involved. Within the workstream we have established a cross-functional group to help develop recommendations that go through various levels of review and approval by the workstream leaders before being implemented. In addition to senior leaders, the workstream includes industry experts within the LOBs and teammates from Climate and Environmental Risk, Credit Risk, Global Risk Analytics, International Risk, Enterprise Credit, Chief Financial Officer Group, Legal, Compliance and Corporate Audit. Key decisions and recommendations resulting from this workstream are approved by the RGC. [...] The Corporate Social Responsibility (CSR) Group includes both the International CSR Group and the CSR Data and Reporting Team, both of which contribute to reaching our Net Zero goal. These teams work in close coordination with GEG and report to the chief administrative officer. - The International CSR Group works across regions outside of the U.S. to integrate our environmental and social strategies into all aspects of our business and in support of the communities we serve. This team includes an enterprise advisory function that works across different LOBs to support sustainable business activity including to drive progress toward our $1.5 trillion sustainable finance commitment and our Net Zero goal. The group also contributes to the development of our policies and practices as well as brings expertise to support a balanced and just transition globally. Additionally, the group catalyzes and supports the monitoring and reporting of a number of our environment- and climate-related activities. - The CSR Data and Reporting Team leads data management and external disclosures of the Company's activities related to Stakeholder Capitalism (people, planet, prosperity, principles of governance). This includes collaboration with the Chief Financial Officer (CFO) Group with regard to disclosure controls; and oversight and governance through the ESG Disclosure Committee. [...] The Corporate Sustainability Controller is part of the CFO Group and also supports the work to reach our Net Zero goal and contributes to our overall climate strategy. This team works in close cooperation with the CSR Data and Reporting Team and GEG, focusing on strengthening our control environment and governance processes for climate reporting. [...] The Global Sustainable Finance Group (GSFG) is an enterprise-wide front-line unit (FLU) within Global Markets that works with our Management Team and partners across our LOBs to establish Bank of America's firm-wide sustainable finance objectives, set Bank of America's capital mobilization and deployment goals (e.g., Bank of America's $1.5 trillion by 2030 sustainable finance commitment), drive thought leadership across international alliances and task forces, expand existing sustainable finance activities across LOBs and innovate across emerging areas of environmental (including climate) and social finance. The Global Head of Sustainable Finance chairs the Global Sustainable Finance Cross-LOB Council (the SF Council) which is accountable to and serves as a sub-council of the RGC. The SF Council meets routinely and is responsible for implementing initiatives and accelerating the Company's sustainable finance progress across all eight LOBs and all four core roles the Company plays in sustainable finance, including: (i) balance sheet deployment—financing and investment, (ii) underwriting/distribution, (iii) advisory/ Governance Council provides governance of our sustainable finance reporting and oversees the Sustainable Finance Taxonomy and key data decisions. [...] Within our Global Corporate & Investment Banking (GCIB) business, our Sustainable Banking Solutions Group (SBSG) delivers expertise on how addressing sustainability considerations impacts clients' cost of capital and ability to execute on their strategic priorities. SBSG provides market insights and investor perspectives, in coordination with investment banking, corporate banking and capital markets partners, to help structure and execute transactions where sustainability factors are a component of the value proposition for investors. This includes Green, Social and Sustainability Bonds and other financings for projects and investments with environmental and social benefits and sustainability-linked transactions focused on issuers' performance on sustainability. The team also partners across the Company to allow for all groups within GCIB to progress on sustainability-related commitments made by the Company. Notably, SBSG is driving the work to keep the business on track toward meeting our 2030 Financing Activity Targets. This includes instituting a framework to drive client engagement, data collection and assessment and monitoring progress.

To strengthen our oversight of environmental and social concerns and focus on sustainable finance solutions, we established our Responsible Growth Committee, a management-level committee comprised of senior leaders across every major line of business and support function. The Responsible Growth Committee reports to the Corporate Governance, ESG and Sustainability Committee of the Board of Directors on environmental and social activities and practices. The Corporate Governance, ESG and Sustainability Committee has overall responsibility for reviewing the company's activities and practices relating to environmental and social sustainability matters, other than human capital matters. [...] The Responsible Growth Committee also engages other management committees as necessary. On matters of environmental and social risk, the Responsible Growth Committee reports to the Management Risk Committee, which in turn reports to the Enterprise Risk Committee of the Board of Directors. Bank of America's Global Climate and Environmental Risk Executive updates the Management Risk Committee on matters related to climate risk. [...] We review the ESRP Framework at least every two years. If at that time, or any other time in the interim, significant changes need to be made to the ESRP Framework, they will be reviewed and approved by the Responsible Growth and Management Risk Committees and will be reflected, as appropriate, in internal policies and procedures.

Achieving Net Zero will require collective action by governments at all levels, corporations, individuals, nonprofits and other actors. Our public policy team is engaged with policy makers across the globe to help ensure we understand and, where appropriate, work to influence potential policy changes that could impact the Company or our clients. We are supportive of policies that will help accelerate the transition to a low-carbon economy and have continuously stated our support for a price on carbon. [...] To encourage policy action, we are collaborating with trade associations, through cross-sectoral and financial sector alliances, and with non-profit partners. Examples of trade associations with which we are engaged include: Institute of International Finance, Global Financial Markets Association, Business Roundtable, the U.S. Chamber of Commerce and Bank Policy Institute. Of importance, along with several other members of the U.S. Chamber of Commerce, we formed an independent Climate Solutions Working Group, which has provided a collective voice for Chamber members that have prioritized climate action to engage with the Chamber on climate policies. In 2020, the Chamber issued a new policy position on climate change, which supports: a market-based approach to accelerate GHG emissions reductions; continued investment in research and development that advances technologies and innovation offering the best solution for managing climate risks; and the promotion of climate resilient infrastructure.

Proper management of climate-related risks and opportunities through oversight starting with the Company's Board of Directors (Board) and management committees through to business councils, forums and steering groups. Our governance framework establishes oversight of our climate strategy by the Board and management-level committees and forums. Additionally, across our lines of business, risk and control functions, we have routines in place to help deliver decisions in a timely manner, escalate risks and issues and achieve milestones. These councils and steering groups provide management oversight of activities related to the financial risks and opportunities from climate change and of sustainability-related regulatory requirements. From an international perspective, sustainability-related strategic, risk and regulatory governance routines are conducted in each region (Europe, Middle East and Africa (EMEA), Latin America (LATAM) and Asia Pacific (APAC) and for certain legal entities. [...] Oversees all environmental and social sustainability-related matters, including climate risks and opportunities, and engages with management on strategic climate topics, including the Company's Net Zero goal BOARD-LEVEL DIRECTORS AND Audit Committee Compensation and Human Corporate Governance, ESG and Enterprise Risk Committee Capital Committee Sustainability Committee (CGESC) COMMITTEES Oversees the integrity of our financial reporting including sustainability-related disclosures Oversees risks, including reputational and climate risks Oversees human capital management practices, including compensation programs Oversees social and environmental sustainability matters generally, other than human capital matters Accountable for execution of the climate strategy, including climate risk management Responsible Growth Council Management Risk Committee Oversees our mandate to grow in a sustainable manner and works to accelerate our progress on social and environmental initiatives MANAGEMENT-LEVEL COMMITTEES & COUNCILS Regional and LOB Reputational Regional and LOB Risk Legal Entity Risk Committees Risk Committees Risk Committees ESG Disclosure Council Oversee and review business Embed climate risk into Review and oversee risks at Oversees accuracy, completeness and activities that present elevated key risk considerations the legal entity-level, including timeliness of ESG-related disclosures levels of reputational risk across LOBs climate-related risks Enterprise Functional Groups Client-Facing Groups ENTERPRISE FUNCTIONAL AND CLIENT-FACING GROUPS WITH SUSTAINABILITY EXPERTISE Global Global Corporate Business Banking and Climate and Environmental Social Corporate Global Sustainable Sustainable Banking Global Commercial Environmental Group within the Responsibility Sustainability Finance Group Solutions Group Banking Sustainability Controller Risk Group Global Public Policy Group Team Group *Note: The Board's CGESC regularly receives updates from the Responsible Growth Council (RGC) on sustainability matters. [...] Supporting the Board in its oversight of climate-related and transition planning activities are management-level committees and councils comprised of senior leaders across every major line of business and control function. Our Transition Plan is aligned with and integrated into key processes across the Company including strategic and financial planning, and assessment and management of climate-related risks. By integrating climate risk and transition planning into our core enterprise routines, the opportunities and risks stemming from climate change are embedded in our core evaluation and decision-making tools and processes to support our and our clients' transition commitments. The Management Risk Committee (MRC), co-chaired by our chief executive officer (CEO) and chief risk officer (CRO), oversees risks facing the Company, taking into consideration climate risk, which spans across all key risk types. The MRC reports to the Board's ERC and is supported by subcommittees organized by risk type (e.g., credit, market, operational) and line of business, which also review the implications of climate-related risks. The Responsible Growth Council (RGC) is responsible for overseeing the Company's mandate to grow in a sustainable manner and our progress on environmental and social initiatives, including climate and our Net Zero goal. The RGC is co-chaired by our chief administrative officer and our vice chair, who was formerly our chief financial officer. Its members are comprised of senior leaders representing each line of business (LOB) and control function. The RGC is accountable to the CEO and is supported by its sub-council, the ESG Disclosure Council, which is responsible for reviewing and providing oversight of our climate and other sustainability-related public disclosures. The Responsible Growth Council, in accordance with its statement of governance principles, escalates sustainability matters and related risks to the CGESC and to the MRC, respectively. It monitors our focus on climate transition and sustainable finance across our LOBs as we work to meet our Net Zero goal. The details on our approach to Net Zero and the 2030 Financing Activity Targets outlined herein were approved by the RGC and reviewed by senior management and the Board. The Target Management Forum is directly responsible for reviewing the transition plans of top clients in the sectors where we have set 2030 Financing Activity Targets. The Target Management Forum consists of senior leaders from Global Banking, Enterprise Credit and the Global Environmental Group and is described in more detail in the Understanding Client Transitions section of this document. We enlist many independent third parties, including our National Community Advisory Council, for advice, counsel, perspective, ideas and assistance. These third parties and other stakeholders (including employees, clients, investors/shareholders, communities, regulators and policymakers) represent a range of diverse perspectives and provide continuous feedback on our actions and progress, holding us accountable. We are transparent and report on our activities, seeking input from our shareholders about the type of information that would be useful to them in assessing our activities, as we have done with this document.

Item 6: Report on lobbying Sada Geuss, c/o • We believe that our public policy engagement and participation in trade associations is appropriate and in the best interests of our alignment with Bank of Trillium Asset company and shareholders and supports many objectives, including our commitment to achieving Net Zero emissions from our America's climate goals Management operations, supply chain, and financing activities before 2050 Seeks report on how company • Our political activities and public policy engagement are subject to comprehensive governance, including oversight from our is aligning lobbying activities Board's Corporate Governance, ESG, and Sustainability Committee with public commitment to • We already provide extensive disclosure about our federal lobbying activities, political activities and contributions, and trade achieve net zero emissions by association memberships 2050