Stakeholders, Governance & Risk

Stakeholder Engagement & Materiality

Stakeholder Engagement:

We define our stakeholders as employees, customers, communities, shareholders, government/regulators, suppliers and our non-profit partners. We engage each stakeholder clearly, honestly and respectfully to understand current and emerging trends that may affect our business. We work together to identify social, environmental and governance topics that demand our attention. We are proactive and responsive to the unique needs of each stakeholder, evaluating each of their priorities based on its influence, legitimacy and urgency. We understand that meaningful engagement with our stakeholders is critical to improving our business and communities.

How we engage:

Employees	Performance reviews, training and development, surveys, emails, intranet, employee assistance program
Customers	Meetings, phone calls, emails, online and in-branch surveys, social media, community rooms
Communities	Meetings, conferences, forums, social media, email, Foundation grant making, XTEAM™ volunteering, stakeholder listening sessions, industry/chamber memberships, community rooms
Shareholders	Phone calls, emails, annual shareholder meeting, quarterly earnings calls, shareholder outreach, conferences
Government & Regulators	Meetings, webinars, CRA and compliance reviews, emails, phone calls
Suppliers	Meetings, phone calls, emails
Nonprofit Organizations	Meetings, email, social media, conferences, stakeholder listening sessions, Foundation grant making, XTEAM™ volunteering

Materiality

The Be FIRST Commitment, our Corporate Responsibility program and report all center on the material topics identified in our 2018 materiality assessment. The company completes a formal materiality assessment every three years unless there are significant changes in the scope, size and complexity of its operations. We found that topics remain consistent over this period, allowing us to track trends and our impact. We define material topics as those that affect our economic, environmental and social performance or influence the decisions of our stakeholders today and into the future.
 
To identify our material topics we conducted in-depth research, including media audits, surveys and interviews with all our stakeholder groups. Once we identified the priority topics, we validated the results with executive management to ensure appropriate alignment with the company’s strategic objectives. The goal of our materiality process is to help inform our overall Corporate Responsibility program, set priorities which are brought to life through our Be FIRST Commitment, effectively use resources and ensure we are managing those material topics in an appropriate matter. The priority topics outlined below illustrate where our long-term business success aligns with marketplace and stakeholder priorities. These topics are grouped into three aspirational themes which guide our Be FIRST Commitment:

Build a Responsible Workforce

• Data Privacy, Security & Fraud
• Ethics
• Regulatory Compliance
• Pay Equity
• Diversity & Inclusion
• Employee Development & Engagement
• Customer Satisfaction

Foster Sustainable Communities

• Economic Development & Business Growth
• Education
• Community Investments – Giving & Volunteerism
• Financial Inclusion
• Environmental Responsibility/Natural Resource Management

Finance the Future

• Responsible Finance
• Homeownership
• Community Development Lending/Investments
• Small Business Lending

Social & Environmental Governance

Responsible & Sustainable Business Policy

As part of our efforts to build a more socially responsible company, we’re proud to share our Responsible & Sustainable Business Policy. This policy provides guidance on our social and environmental business practices, principles and commitments. The policy empowers our employees to act in accordance with our Be FIRST values to help ensure we operate responsibly, inclusively, and sustainably, fulfilling our purpose of financially empowering our communities, reducing the wealth gap and helping all individuals realize life’s exciting moments.
 
The policy includes the following major sections:

• Roles & Responsibilities
• Responsible & Sustainable Business Culture
• Responsible & Sustainable Business Commitments
• Environmental Sustainability Principles
• Third Party Responsible Business Principles
• Exceptions

Please click here to view the full policy. Additional company policies can be found by visiting our Investor Relations website.
 

Social & Environmental Responsibility Risk Management:

Our social and environmental responsibility risk management approach is based on our Enterprise Risk Management program and integrates social and environmental considerations into our due diligence and business processes. The company understands that social, environmental and culture risks can lead to both reputational and strategic risk affecting both short and long-term shareholder value as well as our communities. Our approach ensures we implement effective controls and programs to mitigate, monitor and manage those risks.

This includes:

• FDIC Diversity & Inclusion Self-Assessment- Completed annually to assess the strengths and risks of the company's Diversity and Inclusion program, including workplace employment practices, procurement and business practices as well as practices that promote transparency of organizational commitments to Diversity and Inclusion.
• Social Responsibility & Culture Risk Assessment- Completed annually, based on the company's Enterprise Risk Management framework, to ensure there are proper controls in place to monitor, mitigate and control social, environmental and culture risks. When ineffective controls or new risks are identified, the company implements action plans to improve performance and protect the company and its stakeholders. The final results are reviewed with executive management and the company's Corporate Responsibility & Culture Committee.
• Emerging Risk Briefing(s)- Regular briefs are provided to the credit and lending teams, as well as other impacted business lines, on potential emerging social, environmental and culture risks that could impact business activities. The briefings provide guidance to front line teams to ensure risks are addressed appropriately.
• Social & Environmental Credit Risk Due Diligence- Standard due diligence is conducted for all lending transactions when the social, environmental and reputational risks are well understood and expected to be relatively low, site specific or completely reversible for the borrower, business activity, industry or community. Due diligence begins with front line staff. The process generally includes, but is not limited to, research, ensuring compliance will all federal, state and local laws and permits, assessment of creditworthiness and screening against all applicable company policies and procedures. If, during this process, staff determine the borrower, business activity, industry or community poses heightened social, environmental or reputational risk because the transaction is subject to the Environmental Loan Policy or other company policies then an enhanced level of due diligence is conducted. Enhanced due diligence includes a deeper analysis of topics, documentation, assessments and risks related to the transaction to ensure the company understands the full environmental and social impact. Assessments are conducted by front line staff along with subject matter experts. Assessments may result in additional performance standards and ongoing monitoring which must be met before a transaction can be approved. Transactions that meet internal thresholds will be approved but may include covenants, representations and warranties related to the borrower’s social and environmental performance.

Berkshire Hills Bancorp Corporate Responsibility & Culture Committee

The joint Corporate Responsibility and Culture Committee of the Board of Directors of Berkshire Bank and Berkshire Hills Bancorp, Inc., is responsible for overseeing the management of the Company’s enterprise-wide Corporate Social Responsibility, Diversity & Inclusion, and Culture programs. The Committee is appointed by the Board to:

• Review, approve, and recommend programs and policies to the Board that are designed to identify, measure, monitor, control, and enhance Corporate Social Responsibility, Diversity & Inclusion, and Culture performance;
• Oversee management’s implementation of Corporate Social Responsibility, Diversity & Inclusion, and Culture programs to foster belonging, enhance reputation, mitigate risk, promote competitive advantage, engage employees, and meet stakeholder expectations; and,
• Monitor the performance of the Corporate Social Responsibility, Diversity & Inclusion, and Culture programs and policies by setting goals, examining social and culture risks, as well as reviewing opportunities and threats that could affect the Company.

Read the committee's full charter here.

To learn more about our stakeholder engagement, materiality process, social & environmental governance policies or to engage with us, please contact: csr@berkshirebank.com