Report - COP Prototype

2022 Communication on Progress

BCE - Bell Canada Enterprises

Published date

June 14, 2022

No. of questions

Supplemental files

2021-business-ethics.pdf 2021-ungc-index.pdf 2021-cr-report.pdf 2021-workplace-ethics-human-rights.pdf 2021-our-corporate-responsibility-approach.pdf 2021-november-code-of-business-conduct-bce.pdf bell-supplier-code-of-conduct.pdf 2021-bell-environmental-policy.pdf

CEO Statement

Signed

Governance

Policies and Responsibilities

1. Does the Board / highest governance body or most senior executive of the company:

Issue an annual statement about the relevance of sustainable development to the company

Issue an annual statement that addresses impacts on both people and the environment

Issue an annual statement highlighting a zero tolerance for corruption

Sign off on organizational sustainability targets

Supervise Environmental, Social, and Governance reporting

Regularly review potential risks related to the business model

None of the above

Optional comment

These statements are made through our Corporate Responsibility Report and supporting policies and documents. (Corporate Responsibility Report p. 3-14-16 for example)

2. Does the company have a publicly stated commitment regarding the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a commitment within 2 years	Yes, and the commitment is focused on our own operations	Yes, and the commitment includes our own operations and the value chain	Yes, and the commitment includes our own operations and the value chain along with communities and society
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

https://www.bce.ca/responsibility/key-documents/2021-ungc-index.pdf HR and LR: We commit to human rights though our Code of Business Conduct as well as through the Supplier Code of Conduct & in Workplace infosheet p.2-3 (https://www.bce.ca/responsibility/key-documents/2021-workplace-ethics-human-rights.pdf), Enviroo through CR report and anti-corruption through code of conduct and business ethics files

3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a code of conduct within two years	Yes, focused on employee conduct	Yes, focused on employees and suppliers	Yes, focused on employees, suppliers, and other business relationships
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Our Code of Business addresses our employees for anti-corruption, human rights and labour rights. We have an environmental Policy (https://bce.ca/governance/corporate-governance-practices/2021-bell-environmental-policy.pdf) outlying environmental conduct. Our Supplier Code of Conduct addresses these with suppliers we work with.

4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

	No one is specifically responsible for this topic	Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)	Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)	Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights	Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

All these topics are governed by the highest level of executives in the organization tied to the Board. See p. 14 of our CR report . Corp. Governance Committee and Risk Fund Committee oversees enviro topics, Management Resources and Compensation Committee oversee human resource issues, workplace practices, health and ethics related to human rights and labour rights. The Audit Committee (all tied to the BCE Board) discuss business ethics topics such as corruption (p.2 of business ethics infosheet).

5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

	No formal structure	Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)	Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)	Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)	Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

All these topics are governed by the highest level of executives in the organization tied to the Board. See p. 17-18 of Our Approach infosheet outlying these groups.

Prevention

6. Does the company have a process or processes to assess risk?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

The BCE related committees at the Board assess risk, see p. 109-118 (Business Risk) of our Annual Report https://bce.ca/investors/AR-2021/2021-bce-annual-report.pdf , we assess risk to our suppliers, peoples rights, environmental risks, etc. We also address our risk approach to these topics on p. 19 of Our Approach https://bce.ca/responsibility/key-documents/2021-our-corporate-responsibility-approach.pdf such as through our environmental management system with lines of defense towards risk management.

6.1. During the assessment of risk, which business relationships are reviewed?

	A few suppliers or business relationships [approximately less than 25 %]	Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]	Most suppliers / relevant business relationships [approx. 51 - 99 %]	All suppliers / relevant business relationships outside the supply chain
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

Responsible procurement infosheet (https://bce.ca/responsibility/key-documents/2021-responsible-procurement.pdf) - Prior to entering into a contract with our suppliers, we conduct a risk analysis on the supplier. The purpose of Bell's risk-based assessment is to determine the level of risk associated with a supplier, and to help us determine how to mitigate those risks before a contract is signed. The risk assessment process is questionnaire-based, and upon completion, categorizes a supplier as high, medium or low risk. For suppliers who have a medium or high risk, they are required to complete Bell's corporate responsibility or environmental risk evaluation questionnaire, and can also be asked to provide supplemental information, including: their ethics and labour policy, health and safety standards and environmental policy. Bell's supplier requests are dependent on the type of product or service being provided to Bell and the risk level of the supplier. All new Bell contracts bind suppliers to standards consistent with Bell's Supplier Code of Conduct, with the expectation that the supplier will take all reasonable measures to respect the requirements of the Code through its own operations, and within its own supply chain. Bell's Supplier Code of Conduct was updated in 2020 to reflect the most recent best practices, and outlines standards to ensure that working conditions in our supply chain are safe, that workers are treated with respect and dignity and that design and manufacturing processes are environmentally and ethically responsible. Bell is committed to responsible sourcing, and we consider all activities in our supply chain that fuel conflicts, and that lead to human rights abuse, as unacceptable. We have also updated the Labour and Human Rights section of our Supplier Code of Conduct to reflect the latest International Conventions, including: Freely chosen employment, Young workers, Working hours, Wage and benefits, Human treatment and Non-discrimination and Freedom of Association and collective bargaining.

7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

Enviro risks are monitored, prevented and mitigated through our ISO 14001 certification and ISO 50001 certification (see p.20 of Our Approach https://bce.ca/responsibility/key-documents/2021-our-corporate-responsibility-approach.pdf). Our Human, Labour and Corruption risks are monitored though training, code of conduct awareness, confidential help line, internal controls with internal business units, and whistleblower channels of ethical breaches and investigations. (https://bce.ca/responsibility/key-documents/2021-business-ethics.pdf). More prevention and identification outlined in Code of Business conduct (https://www.bce.ca/governance/code-of-business-conduct/2021-november-code-of-business-conduct-bce.pdf) through our Workplace Harassment and Violence Prevention Policy

Concerns and grievance mechanisms

8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

No, this is not a current priority

No, but we plan to within two years

Yes, we have an informal process (e.g., through supervisors, others)

Yes, we have a formal process

Optional comment

p. 2 of our Business Code of Conduct: https://www.bce.ca/governance/code-of-business-conduct/2021-november-code-of-business-conduct-bce.pdf An unethical behaviour may be reported to your immediate manager. If this won’t meet your needs, is inappropriate, does not provide the necessary level of confidentiality or if you otherwise prefer, you can contact our confidential and anonymous Business Conduct Help Line at clearviewconnects.com on a 24/7 basis or by calling 1-866-298-2942 (toll free). You may also contact the Corporate Secretary or the Chair of the Audit Committee. Whistleblower channels for ethical breaches. P. 4 of Business ethics infosheet: https://bce.ca/responsibility/key-documents/2021-business-ethics.pdf Confidential whistleblower channel for reporting ethical breaches BCE considers it vital that employees have the most effective tools to ask questions or raise issues concerning any ethical dilemma. Our Business Conduct Help Line can be accessed 24/7 by phone (1 866 298-2942) or online (clearviewconnects.com) on a completely anonymous and confidential basis, to ask questions or report concerns relating to issues under the Business Code of Conduct.

8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

	No	Yes
Is the process communicated to all employees/workers in local languages?
Is the process available to non-employees (e.g., contractors, vendors, suppliers)?
Is the process confidential (e.g., whistleblowing process)?
Are there processes in place to avoid retaliation?
Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)
Other (Please provide additional information)

Optional comment

Our Code of Business Conduct is available in the two official languages spoken in Canada - being French and english. This is true for all our documentation. The process is communicated annually to all employees through mandatory training and sign off all employees, managers, executives and members of the Board of Directors must certify annually that they have reviewed and follow the Code. The process is confidential, you can contact our confidential and anonymous Business Conduct Help Line at clearviewconnects.com on a 24/7 basis or by calling 1-866-298-2942 (toll free). + Confidential whistleblower channel for reporting ethical breaches BCE considers it vital that employees have the most effective tools to ask questions or raise issues concerning any ethical dilemma. Our Business Conduct Help Line can be accessed 24/7 by phone (1 866 298-2942) or online (clearviewconnects.com) on a completely anonymous and confidential basis, to ask questions or report concerns relating to issues under the Business Code of Conduct (p.4 of Business ethics file https://bce.ca/responsibility/key-documents/2021-business-ethics.pdf). Any employee who in good faith reports an unethical behaviour will be protected from threats of retaliation, discharge or other types of sanctions that are directly related to the disclosure of such unethical behaviour. No employee will be penalized for inquiring, in good faith, about apparently unethical behaviour or for obtaining guidance on how to handle suspected illegal acts or policy violations. Further, Bell will not allow retaliation for reports made in good faith. In our daily activities, we have a fundamental responsibility to address a broad spectrum of issues. These include: preventing conflicts of interest, protecting company assets, safeguarding privacy and confidentiality, treating customers and the broader public, shareholders, suppliers, our fellow team members and competitors with respect and honesty, fostering a diverse, safe and healthy workplace and protecting the environment. (p.1 of Code of Conduct).

9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

	No process to enable remedy to stakeholders	Remedy available to some stakeholders (i.e., some geographies, employees only)	Remedy is available to all affected stakeholders	Remedy is available to all stakeholders, and suppliers are expected to have similar policies
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

A few tools enable us to identify and address remedies where we have caused an adverse effect. For our suppliers and their implementaiton of environmental and human rights: we perform regular audits to identify adherence, This high-responsibility risk process must undergo rigorous on-site social audits through a third party. Social audits carried out annually by Bureau Veritas analyze compliance with all applicable laws, rules and regulations, including those of related to licensing, labour, wages, worker health and safety and the environment. (p.3 of https://www.bce.ca/responsibility/key-documents/2021-responsible-procurement.pdf); With respect to accounting and auditing matters, our Complaint Procedures for Accounting and Auditing Matters Policy (Complaint Procedures Policy) established by the Audit Committee directs anyone with concerns pertaining to corporate fraud, accounting, internal accounting controls or auditing matters to report such concerns through the Business Conduct Help Line, or, for members of the public, to Bell’s “Complaints and Concerns” line, or directly to the Corporate Secretary. Any director, officer or employee of any business unit who receives a submission from any person, in writing or verbally, regarding a reportable activity, pursuant to the Complaint Procedures Policy, is required to immediately report such submission to the Corporate Secretary, Internal Audit or Corporate Security. Where a submission considered to be a material reportable activity is received, the Complaint Procedures Policy requires the Corporate Secretary to ensure the activity is reported to the Audit Committee Chair, review the activity with the Chief Financial Officer, Internal Audit, Corporate Security, and Audit Committee as appropriate, and whenever possible and appropriate, report back to the employee or third party who reported the activity. (p.6 of https://bce.ca/responsibility/key-documents/2021-business-ethics.pdf); All reports submitted to our anonymous and confidential Business Conduct Help Line are reviewed and, as required, investigated, under the oversight of the Corporate Secretary's Office and our Internal Audit Team. If a report reveals a well-founded issue or concern, responsibility for remediation of system and process deficiencies will be allocated based on ownership while the relevant business segment remains Last update: January 2022 8/9 PUBLIC | BELL CANADA responsible for addressing any employee misconduct through established procedures that include taking recommendations from appropriate corporate groups such as Human Resources, Corporate Security and Legal. The Corporate Security group has the primary responsibility for conducting investigations, except for submissions related to financial reporting, which are handled by the Internal Audit team. Outside advisors are engaged, where appropriate (p.7-8 of Business ethics). Finally, on the environmental side, we annuall audit both internally but also by a third party our processes and adherance to our environmental policy and when identified, evaluate if any externalities have been caused and put in place corrective measures to address this. This is by nature how we get certified for ISO 14001 and ISO 50001. Supplier expectations are highlighted in the Supplier Code of Conduct: https://bce.ca/governance/supplier-code-of-conduct/bell-supplier-code-of-conduct.pdf

Lessons

10. How does the company capture lessons regarding each of the following sustainability topics?

	No lessons are regularly captured	Conducts root cause analyses/investigation of major incidents	Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly	Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Through our ISO 14001 certification, we conduct scheduled annual internal and external audits of our whole operations but also review our system to identify gaps, opportunities and how we can improve and shape our strategy accordingly. For human rights, labour and anti-corruption, we audit and monitor our trends. The HSSEC Oversight Committee focuses its efforts on employees who may be exposed to such risks, and analyses trends in public policy, stakeholder expectations and external events to engage the company in the development of strategies to enhance ethical behaviour and action plans to address emerging compliance risks as appropriate. BCE's Internal Audit Team has oversight, with the Corporate Secretary's Office, of all reports submitted through our Business Conduct Help Line. Every quarter, the Audit Committee receives a report from the Corporate Secretariat on submission activity. The Internal Audit Team is responsible for the review of the effectiveness and efficiency of business processes, the reliability and integrity of information, compliance with applicable laws, regulations, policies and procedures, and is focused on safeguarding company assets for all business units and majority owned subsidiaries within the BCE group. Management evaluates the effectiveness of our internal control over financial reporting annually, based on the criteria established in the Internal Control – Integrated Framework (2013) issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). A component of the COSO framework is the evaluation of conformity with the COSO principles through entity-level controls, which addresses the compliance to the BCE Business Code of Conduct and the Business Conduct Help Line. (p.9 of Business ethics: https://bce.ca/responsibility/key-documents/2021-business-ethics.pdf)

Executive Pay

11. Is executive pay linked to performance on one or more of the following sustainability topics?

Optional comment

p. 14 of CR Report https://www.bce.ca/responsibility/overview/2021-cr-report.pdf 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. In addition, EVPs have 30% of their annual bonuses tied to personal objectives that include a variety of corporate responsibility topics. An example of a metric for human rights is our employee wellbeing and engagement target and metric. For labour, we have a target addressing the health and safety of our workforce. For the environment we have multiple targets addressing climate change and waste. And finally, anti-corruption is addressed through our targets around customer experience complaints and complaints received through the privacy commissioner.

Board Composition

12. Percentage of individuals within the company’s Board / highest governance body by:

	Number/Percentage	Not applicable (Please provide additional information)
Total number of board members (#)	13
Male (%)	61.6
Female (%)	38.4
Non-binary (%)	0
Under 30 years old (%)	0
30-50 years old (%)	7.6
Above 50 years old (%)	92.3
From minority or vulnerable groups (%)	15.3
Executive (%)	7.6
Independent (%)	92.3

Optional comment

See our proxy p. 2 and https://www.bce.ca/investors/AGM-2022/2022-bce-management-proxy-circular.pdf

Data Assurance

14. Is the information disclosed in this questionnaire assured by a third-party?

No assurance for any metrics

Limited assurance for minority of metrics (e.g., GHG emissions only)

Limited assurance for majority of metrics

https://www.bce.ca/responsibility/key-documents/2021-pwc-independent-assurance-statement.pdf We received limited assurance on key ESG metrics- by PwC. See statement above.

Reasonable assurance for minority of metrics

Reasonable assurance for majority of metrics

Other (Please provide additional information)

Optional comment

See p.3 https://www.bce.ca/responsibility/key-documents/2021-pwc-independent-assurance-statement.pdf

Human Rights

Commitment

2. Does the company have a policy commitment in relation to the following human rights issues?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
August 2, 2021
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

https://support.bell.ca/_web/guides/Common/Legal/Bell_Privacy_Policy_Final.pdf https://support.bell.ca/_web/guides/Common/Legal/Bell_Privacy_Policy_Final.pdf

2.1. For each human rights policy, is it:

	Aligned with international human rights standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving human rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of expression
Digital security / privacy
Rights of women and/or girls
Access to culture
Rights of indigenous peoples
Free, prior and informed consent
Rights of refugees and migrants
Access to water and sanitation

Optional comment

https://bce.ca/responsibility/key-documents/2021-data-privacy-information-security.pdf

Prevention

3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human rights issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing /mitigating the risks/impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

See our stakeholder engagement at p. 13-14 of https://bce.ca/responsibility/key-documents/2021-our-corporate-responsibility-approach.pdf

4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
In 2021, Bell continued to make significant investments in people, processes and technology in order to protect confidential and personal information from evolving cyber security threats. As part of a broader industry initiative, we have implemented a new verification regime to prevent wireless numbers from being fraudulently ported and used to circumvent other security protections and to fraudulently obtain access to personal information. We provide our team members with information and on-going training regarding the importance of protecting the privacy of our customers and other team members. Team members and customers are also able to address questions about privacy and obtain support from the Bell Privacy Team through our privacy mailbox, which is continuously monitored. In 2021, we implemented mandatory data governance training for all employees as part of our biannual code of business conduct training program.
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

https://bce.ca/responsibility/key-documents/2021-data-privacy-information-security.pdf p.2 and 5 and 8

5. Who receives training for the following human rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

In 2021, we implemented mandatory data governance training for all employees as part of our biannual code of business conduct training program.

6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

p. 48-49, https://www.bce.ca/responsibility/overview/2021-cr-report.pdf The BCE Board adopted an enhanced data governance policy in 2020, bringing together multiple existing policies and programs in the interrelated areas of privacy, information security, data access management and records management. In 2021, we implemented mandatory data governance training for all employees as part of our biannual code of business conduct training program. ✪ Target: 0 unresolved well-founded privacy complaints from the Office of the Privacy Commissioner of Canada ✪ Target: 100% of selected team members completed Bell’s Be Cyber Savvy information security training program by the end of 2022 ✪ Target: Align to ISO 27001 standard by the end of 2023 ✪ Target: Improve year-over-year phishing simulation report rates Bell considers the International Bill of Human Rights and the core International Labour Organization (ILO) Conventions when adopting human rights best practices, ensuring that they also comply with Canadian human rights laws. Bell has adopted policies as a commitment to fulfill our responsibility to respect human rights, approved by our board or equivalent. Our policies include Bell Mental Health Policy, Bell Health and safety policy, Workplace violence and harassment prevention policy, Code of Business Conduct policy among others.

Response

7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

https://bce.ca/responsibility/key-documents/2021-workplace-ethics-human-rights.pdf` A range of examples are provided to help employees navigate through difficult situations in areas of personal integrity, conflict of interest, sales practices, employee values including harassment and diversity, customer engagement and supplier relations with the goal of reinforcing Bell's commitment to the highest ethical standards and prioritization of positive reputational outcomes when faced with an ethical dilemma. BCE's full Board is entrusted with the responsibility for identifying and overseeing the principal risks to which our business is exposed, including business ethics risks, and ensuring there are processes in place to effectively identify, monitor and manage them. As a Canadian chapter member in the not-for-profit, member-driven ISF, Bell helps drive the evolution of security and risk management practices. We also adhere to a number of international security standards and frameworks, including the Information Security Forum Standard of Good Practice, NIST and PCI DSS. Bell is a founding member of CCTX, which aims to help public and private organizations share cyber threat and mitigation information across industries and sectors in Canada. Bell is also a founding member of the Canadian Security Telecommunications Advisory Committee (CSTAC), where we work together to drive best practices and improve the security and resiliency of Canada's connected world along with other Canadian telecommunications providers, government departments and law enforcement agencies.In February 2021, we launched our Be Cyber Savvy information security training program. This training program includes onboarding to our specialized Cyber Savvy platform, performing phishing simulations and spanning four courses, which team members have a year to complete once they are onboarded. Additionally, we set a new target for an improved phishing simulation report rate for our team members, with the goal to improve our phishing simulation report rate year-overyear. These initiatives enable a stronger cybersecurity culture and greater awareness of cybersecurity risks.

Labour

Commitment

1. Does the company have a policy commitment in relation to the following labour rights principles?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
November 2021 https://bce.ca/governance/code-of-business-conduct/2021-november-code-of-business-conduct-bce.pdf
Forced labour
2020 https://bce.ca/governance/supplier-code-of-conduct/bell-supplier-code-of-conduct.pdf
Child labour
2020 https://bce.ca/governance/supplier-code-of-conduct/bell-supplier-code-of-conduct.pdf
Non-discrimination in respect of employment and occupation
Nov, 2021 https://bce.ca/governance/code-of-business-conduct/2021-november-code-of-business-conduct-bce.pdf
Occupational safety and health
March 2021 https://bce.ca/responsibility/key-documents/2021-health-safety-policy.pdf
Working conditions (wages, working hours)

Optional comment

1.1. For each labour rights policy, is it:

	Aligned with international labour standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving labour rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

https://www.ctvnews.ca/editorial-standards-and-policies#anchor7 The Internal Audit Team is responsible for the review of the effectiveness and efficiency of business processes, the reliability and integrity of information, compliance with applicable laws, regulations, policies and procedures, and is focused on safeguarding company assets for all business units and majority owned subsidiaries within the BCE group. Management evaluates the effectiveness of our internal control over financial reporting annually, based on the criteria established in the Internal Control – Integrated Framework (2013) issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). A component of the COSO framework is the evaluation of conformity with the COSO principles through entity-level controls, which addresses the compliance to the BCE Business Code of Conduct and the Business Conduct Help Line.

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks /impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

Freedom of association and collective bargaining is inherent in Bell. Approximately 39% of the total BCE team members were represented by labour unions as at December 31, 20213. Throughout Canada, unionized employees are members of more than 60 different bargaining units represented by 10 different labour unions. All collective agreements are accessible to team members, with many of the agreements posted on the Company’s intranet. Along with commitments outlined in the Bell Code of business conduct, various collective agreements reinforce the importance of having a fair, inclusive and accessible workplace where everyone feels valued, respected and supported. Working in partnership with team members and union representatives, we have established Local Health and Safety Committees (LHSCs) as well as Corporate Health and Safety Committees (CHSCs) for our operations throughout Canada. In compliance with regulations, our LHSCs and CHSCs include representation from operational and clerical functions and meet periodically to address health and safety challenges and perform workplace inspections.. Our Diversity Leadership Council (DLC) champions DEI across the organization, defining Bell’s DEI strategy and developing company-wide implementation plans for specific actions. The DLC is comprised of 14 diverse senior leaders, including vice-presidents and above, who represent each business unit as well as the markets we serve across Canada. Under their leadership, we work to ensure that our business strategy and human resources policies align with our DEI goals. Prior to entering into a contract with our suppliers, we conduct a risk analysis on the supplier. The purpose of Bell's risk-based assessment is to determine the level of risk associated with a supplier, and to help us determine how to mitigate those risks before a contract is signed. T

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

see p. 19, 30 to 33, 36-37 https://www.bce.ca/responsibility/overview/2021-cr-report.pdf https://bce.ca/responsibility/key-documents/2021-workplace-ethics-human-rights.pdf

4. Who receives training for the following labour rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

https://bce.ca/responsibility/key-documents/2021-health-and-safety.pdf

5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Freedom of association and collective bargaining is inherent in Bell. Approximately 39% of the total BCE team members were represented by labour unions as at December 31, 20213. Throughout Canada, unionized employees are members of more than 60 different bargaining units represented by 10 different labour unions. All collective agreements are accessible to team members, with many of the agreements posted on the Company’s intranet. Along with commitments outlined in the Bell Code of business conduct, various collective agreements reinforce the importance of having a fair, inclusive and accessible workplace where everyone feels valued, respected and supported. GRI 205-2, 415-1 10 Different collective agreement provisions include: • Joint labour-union committees that provide an opportunity to discuss important matters while fostering and improving relationships between the parties • A well-defined grievance procedure • Transfer and job posting procedures to facilitate professional mobility • Advance notice and discussion with unions prior to implementation of significant changes impacting employees. The positive engagement of members of our team represented by unions is contingent on negotiating collective agreements that deliver competitive labour conditions and uninterrupted service, both of which are critical to achieving our business objectives.
Forced labour
We also exert influence through value-chain management. Because of the proliferation of global sourcing and distribution, companies must be aware of potential human rights issues both upstream and downstream. To address this issue, Bell has had a Supplier Code of Conduct in place since 2007, which was recently updated in 2020. Also, the company has adopted measures in our purchasing operations with the objective of avoiding conflict minerals that finance or benefit armed groups. Prior to entering into a contract with our suppliers, we conduct a risk analysis on the supplier. The purpose of Bell's risk-based assessment is to determine the level of risk associated with a supplier, and to help us determine how to mitigate those risks before a contract is signed.
Child labour
We also exert influence through value-chain management. Because of the proliferation of global sourcing and distribution, companies must be aware of potential human rights issues both upstream and downstream. To address this issue, Bell has had a Supplier Code of Conduct in place since 2007, which was recently updated in 2020. Also, the company has adopted measures in our purchasing operations with the objective of avoiding conflict minerals that finance or benefit armed groups. Prior to entering into a contract with our suppliers, we conduct a risk analysis on the supplier. The purpose of Bell's risk-based assessment is to determine the level of risk associated with a supplier, and to help us determine how to mitigate those risks before a contract is signed.
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

More information found here: https://bce.ca/responsibility/key-documents/2021-workplace-ethics-human-rights.pdf

Performance

6. What is the percentage of employees covered under collective bargaining agreements?

	Percent of employees (%)	Unknown
Employees covered under collective bargaining (%)	39

Optional comment

Freedom of association and collective bargaining is inherent in Bell. Approximately 39% of the total BCE team members were represented by labour unions as at December 31, 2021

7. What is the percentage of employees in a trade union or other workers' organization?

	Percent of employees (%)	Unknown	Not applicable (Please provide additional information)
Employees in a trade union or on a worker committee (%)	39

Optional comment

Throughout Canada, unionized employees are members of more than 60 different bargaining units represented by 10 different labour unions.

8. In the course of the reporting period, what was the percentage of women in:

	Percent of women (%)	Unknown
Senior leadership level position	33
Non-executive board	41.6

Optional comment

p.32 https://www.bce.ca/responsibility/overview/2021-cr-report.pdf Senior leadership as vice president and above (target on p.11) https://www.bce.ca/investors/AGM-2022/2022-bce-management-proxy-circular.pdf p.2

9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

	Salary ratio (%)	Unknown	Choose to not disclose
Women / Men (%)
We hope to compile data and disclose for the 2022 fiscal year. Our internal teams and building tracking data internally.

10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

	Frequency of injury	Unknown	Choose to not disclose
Frequency of injury
We disclose time lost accident frequency rate Our overall time lost accident frequency rate in 2021 was 1.121, performance that was below the industry average (1.24). Total reportable health and safety cases decreased by 3.2% year over year Time Lost Accident Frequency Rate = number of time-lost accident cases ÷ number of worked hours × 200,000

Optional comment

Our overall time lost accident frequency rate in 2021 was 1.121, performance that was below the industry average (1.24). Total reportable health and safety cases decreased by 3.2% year over year Time Lost Accident Frequency Rate = number of time-lost accident cases ÷ number of worked hours × 200,000

11. In the course of the reporting period, what was the company’s incident rate?

	Incident rate	Unknown	Choose to not disclose
Incident rate	1.12

Optional comment

Response and Reporting

12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
We currently do not track and publicly report on this item
Forced labour
We currently do not track and publicly report on this item
Child labour
We currently do not track and publicly report on this item
Non-discrimination in respect of employment and occupation
We currently do not track and publicly report on this item
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

At Bell, the health and safety of our team members has been a top priority for 142 years, and we continue to strive to prevent any work-related accidents from occurring. Regrettably, there was one fatality in 2021 due to a workplace accident. In this particular case, a Bell technician was electrocuted upon contact with a public utility’s high-voltage electrical lines. Immediately following the accident, our team undertook a comprehensive review of Bell’s electrical safety program, enhanced our training program, and also retrained technicians on how to work safely near electrical lines. While Employment and Social Development Canada (ESDC) has not yet completed its investigation, they have advised that they are satisfied with our plan.

13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

https://bce.ca/responsibility/key-documents/2021-health-and-safety.pdf We leverage our team members to support 180 local Health and Safety committees across Canada, as well as 10 corporate Health and Safety committees that partner with unions. As required by regulations, these committees represent operational and clerical functions, meet and perform workplace inspections. Collectively, these committees completed more than 6,100 workplace inspections in 2021, identifying and resolving issues, that, left unaddressed, could have contributed to incidents. The Corporate Health and Safety team collaborates with these committees for the development and implementation of prevention programs. Bell is a socially responsible organization with a desire to support the promotion of human rights within our sphere of influence, especially in ways that strategically link to our core business activities. Special attention is paid to the rights of underrepresented groups. Bell Let's Talk, launched in September 2010, is the largest corporate initiative dedicated to mental health with a commitment to date of $129,588,747.75 following Bell Let's Talk Day on January 26, 2022, and a goal of reaching $155 million by 2025. Bell Let's Talk is focused on engaging Canadians to take action to create positive change in mental health, with a strategy built on 4 key pillars: Fighting the stigma, Improving access to care, Supporting world-class research and Leading by example in workplace mental health. As part of our effort to continuously advance our DEI strategy, we consult with members of various identity groups to understand their experiences at work. In 2021, we facilitated a series of virtual feedback consultations, encouraging discussions around workplace experiences and inclusion at Bell. In conjunction with our Bell Team survey results, we analyzed the insights to identify areas of opportunity and look to continuously improve our strategic direction and adopt best practices. BCE considers it vital that employees have the most effective tools to ask questions or raise issues concerning any ethical dilemma. Our Business Conduct Help Line can be accessed 24/7 by phone (1 866 298-2942) or online (clearviewconnects.com) on a completely anonymous and confidential basis, to ask questions or report concerns relating to issues under the Business Code of Conduct. The system is administered by a third-party firm, independent of BCE, specializing in the field. It also allows employees to track the progress of their inquiries online and respond to requests for additional information (when required), and provides BCE with an auditable record of issues. The Business Conduct Help Line received 215 reports and inquiries in 2021. BCE considers it vital that employees have the most effective tools to ask questions or raise issues concerning any ethical dilemma. Our Business Conduct Help Line can be accessed 24/7 by phone (1 866 298-2942) or online (clearviewconnects.com) on a completely anonymous and confidential basis, to ask questions or report concerns relating to issues under the Business Code of Conduct. The system is administered by a third-party firm, independent of BCE, specializing in the field. It also allows employees to track the progress of their inquiries online and respond to requests for additional information (when required), and provides BCE with an auditable record of issues. The Business Conduct Help Line received 215 reports and inquiries in 2021.

Environment

Commitment

1. Does the company have a formal policy on the following environmental topics?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Climate Action
Nov 2021
Water
Nov 2021
Oceans
We currently do not focus on oceans due to the nature of our business and is not material for us.
Forests / Biodiversity / Land Use
Nov 2021
Air Pollution
Nov 2021
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Nov 2021
Energy & Resource Use
Nov 2021

Optional comment

https://bce.ca/governance/corporate-governance-practices/2021-bell-environmental-policy.pdf https://bce.ca/responsibility/key-documents/2021-environmental-management-system.pdf

1.1. For each environmental policy, is it:

	Aligned with international environmental standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving environmental expertise from inside and outside the company?	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

Our environmental policy, creating since 1993 is the flagship of our Corporate Responsibility. It is renewed regularly and approved at the highest level of management. We have been ISO certified since 2009 and have received external feedback to improve and align our policy to global standards while always operating above applicable legal requirements.

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks/ impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

https://bce.ca/responsibility/key-documents/2021-our-corporate-responsibility-approach.pdf p.13-14-15-16 Collaboration takes place with various groups on our key topics like climate change, energy, and waste

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

Yearly, we train our employees on environmental risks and their impacts. https://bce.ca/responsibility/key-documents/2021-environmental-training.pdf We also have our suppliers apply these same policies when engaging with them https://www.bce.ca/governance/supplier-code-of-conduct/bell-supplier-code-of-conduct.pdf We audit our operations for all topics in ISO 14001 and ISO 50001 twice a year, both internally and externally. https://bce.ca/responsibility/key-documents/2021-environmental-management-system.pdf We collaborate with peers as well and respond to governmental regulations https://bce.ca/responsibility/key-documents/2021-our-corporate-responsibility-approach.pdf p.15-16

4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Climate Action
Water
We track our water consumption on a yearly basis In 2021, we installed water-conserving faucet controllers and washroom features in a dozen key buildings and replaced or refurbished cooling towers at six other buildings, contributing to more efficient water use at those sites. Water usage reduction in our administrative offices during this time may be partly attributed to the majority of our office employees working from home (for most of the year) due to the COVID-19 pandemic. https://bce.ca/responsibility/key-documents/2021-water-consumption.pdf
Oceans
Forests / Biodiversity / Land Use
We ask and monitor data on an annual basis and support operaitons to diminish their impact https://bce.ca/responsibility/key-documents/2021-protecting-biodiversity.pdf
Air Pollution
We ask and monitor data on an annual basis and support operaitons to diminish their impact https://bce.ca/responsibility/key-documents/2021-halocarbons.pdf
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

We track public metrics and performance on climate action, waste and energy. Other topics are monitored internally https://www.bce.ca/responsibility/overview/2021-cr-report.pdf p.10

4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?

	Description of targets (e.g., what is the target, absolute vs. intensity, externally verified, on track, etc.)
Climate Action	New target: Increase carbon savings enabled by the use of Bell’s technology (Performance is based on our carbon abatement ratio, which is defined as the number of times by which GHG emissions abated through the use of Bell technologies exceed GHG emitted by Bell’s operations). Currently at 4.5 times
Energy & Resource Use	New target: 1.5°C-aligned science-based targets(SBTs) 1) Reduce our absolute scope 1 and scope 2 GHG emissions8 57% by 2030, from a 2020 base year 2) Reach 64% of our suppliers by spend covering purchased goods and services with science-based targets by 2026 3) Reduce our absolute scope 3 GHG emissions from categories other than purchased goods and services 42% by 2030, from a 2020 base year
Water
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)	New target: Reach and maintain a 15% reduction in total waste sent to landfill by 2025, from a 2019 base year Divert 100% of generated hazardous waste to certified recyclers by 2024 Recover 7 million used TV receivers, modems, mobile phones and WiFi pods between January 1, 2021 and the end of 2023
Oceans

Optional comment

See pages 10-11-12 of https://www.bce.ca/responsibility/overview/2021-cr-report.pdf

4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?

	Progress is reviewed against goals annually or more frequently	Progress is reported internally to the most senior level	Progress is reported externally	Other (Please provide additional information)
Climate Action
Energy & Resource Use
Water
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Oceans

Optional comment

See pages 10-11-12 and 14 of https://www.bce.ca/responsibility/overview/2021-cr-report.pdf 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. The progress is tracked on a yearly basis.

5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Climate Action
Water
Oceans
We do not currently focus on this topic as it is not material for us.
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

We provide remedy on all those topics. Climate and energy, we found solutions: p.7 https://bce.ca/responsibility/key-documents/2021-energy-greenhouse-gas.pdf For water: p.1 https://bce.ca/responsibility/key-documents/2021-water-consumption.pdf for biodiversity: https://bce.ca/responsibility/key-documents/2021-protecting-biodiversity.pdf for air pollution: https://bce.ca/responsibility/key-documents/2021-halocarbons.pdf for waste: https://bce.ca/responsibility/key-documents/2021-circular-economy.pdf

Climate Action

6. What were the company’s gross global greenhouse gas emissions for the reporting period?

Scope 1 Emissions

Full

None

Emissions (tCO2e)

139187

Scope 2 Emissions

Full

None

Emissions (tCO2e)

136535

Scope 3 Emissions

Full

Partial

None

Emissions (tCO2e)

1861651

Optional comment

See https://bce.ca/responsibility/key-documents/2021-energy-greenhouse-gas.pdf

7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

Percent of revenue (%)

Unknown

Not applicable (Please provide additional information)

Optional comment

We invested 500 million dollars in R&D in 2021, nevertheless we do not have the details on where the investment went for renewable energy. You can read more on those investments on p. 9-10-11 https://bce.ca/responsibility/key-documents/2021-energy-greenhouse-gas.pdf

8. Has the organization acted to support climate change adaptation and resilience?

We have taken action to increase organization-wide resilience to climate change

We have taken action to increase resilience in our supply chains

We have taken action to increase resilience in the communities in which we operate

We have provided funding for climate change adaptation and resilience initiatives and projects

We have not taken actions to build climate change resilience in the reporting period

Other (Please provide additional information)

f BCE, became the first Canadian telecommunications company to issue a sustainability bond with the offering in Canada of Cdn $500 million 2.20% MTN Debentures, Series M-56, maturing May 29, 2028. The bond offering raised $497,535,000 in net proceeds, which was to be allocated to both green and social eligible investments, primarily to the “energy efficiency” and “affordable basic infrastructure” categories. As of December 31, 2021, BCE has fully allocated the net proceeds of the sustainability bond to the “energy efficiency” green category and the “affordable basic infrastructure” social category.

Unknown

Optional comment

To continually improve our energy performance, in 2008 we created the Energy Board, a management-level committee reporting to the HSSEC Oversight Committee, 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 and identify and support the implementation of energy-saving initiatives in our facilities (buildings, telecom network and IT infrastructure) and vehicle fleet, and by substituting technology for travel. The Energy Board also oversees progress toward meeting our GHG emissions reduction targets. Bell also fosters innovation and entrepreneurship by engaging with cleantech clusters, such as Écotech Québec, that are focused on accelerating the development of clean technology. Through such partnerships, Bell seeks to support local innovation and liaise with cleantech entrepreneurs to improve our environmental performance. With our Écotech Québec partnership, Bell also has access to 12 leading cleantech clusters from around the world through the International Cleantech Network.

Energy / Resource Use

9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

% of total energy consumption

Unknown

Optional comment

https://bce.ca/responsibility/key-documents/2021-energy-greenhouse-gas.pdf Nearly 57%8 of the 1,776,425 MWh of electricity we consumed in 20219 was from renewable sources, such as water, wind, tides and solar. Of this, 87% was from hydro sources.

Technology

10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

Percent of total revenue (%)

Unknown

Not applicable (Please provide additional information)

Optional comment

We do not track this measure yet.

Sector-specific: Forest, biodiversity, and land use

14. Please report the number and area (in hectares) of sites owned, leased, or managed by the company in or adjacent to protected areas and/or key biodiversity areas (KBA).

	Number	Unknown	Not applicable (Please provide additional information)
Sites
We do not disclose this information. Additionally we are not in the forestry sector.
Hectares
We do not disclose this information. Additionally we are not in the forestry sector.

15. What area (in hectares) of natural ecosystems was converted during the reporting period in areas owned, leased, or managed by the company?

Conversion of natural resources (hectares)

Unknown

Not applicable (Please provide additional information)

We do not disclose this information. Additionally we are not in the forestry sector.

16. Is the company supporting or implementing project(s) focused on ecosystem restoration and protection?

	No	No, but we plan to in the next 2 years	Yes
Forest ecosystem restoration
Other ecosystem restoration
Reforestation
Natural regeneration
Agroforestry
Set-aside land
Biodiversity offsetting
Other (please specify in text box)

Optional comment

We do not disclose this information. Additionally we are not in the forestry sector.

Overall Environment

21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

As part of our energy management system, we reduce electricity usage through optimized facility and equipment heating and cooling, LED lighting conversions, the modernization of network equipment, as well as the consolidation, optimization and virtualization of servers. We have also reduced our fuel consumption through our ongoing fleet modernization and electrification and by investing in wind and solar power technology for cell sites and other installations. Our program includes the ongoing deployment of more fuel-efficient vehicles. In 2021, we replaced 501 older vehicles with electric or more fuel-efficient models. Today, we have 35 electric and 59 hybrid vehicles in service. To learn about fleet modernization at Bell, see the Fleet solutions information sheet on our website. GRI 302-4 8 4 Overall, we have 35 BOMA BEST (Building Owners and Managers Association’s Building Environmental Standards) and 11 LEED (Leadership in Energy and Environmental Design) building certifications. Over 7.5 million square feet of Bell’s occupied space is certified which is equivalent to about 47 baseball fields. To learn more, see the Sustainable real estate information sheet Single-use plastic continues to be an intractable problem around the world. To help address the global plastic crisis, Bell is focused on designing out waste by reducing the purchase and use of single-use plastics. Since 2020, Bell has a company-wide directive on single-use plastics with the objective of reducing plastic waste at the source. The directive targets four single-use plastic categories: plastic bags, promotional items, water bottles and cafeteria items. Our return, repair and reuse system for wooden cable reels – used to wind, transport and lay cables – greatly extends the life of these important tools for our business. In addition, Bell Technical Solutions (BTS) work centres operate repair shops, with the goal of maximizing the lifespan of technicians’ tools and equipment and to reduce material consumption. For more than four years these internal shops at a number of work centres throughout Québec and Ontario have been repairing tools and ladders. TO learn more, see our environment section in the Corporate Responsibility Report https://www.bce.ca/responsibility/overview/2021-cr-report.pdf

Anti-corruption

Commitment

1. Does the company have an anti-corruption compliance programme?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes

Nov. 2021 https://bce.ca/governance/code-of-business-conduct/2021-november-code-of-business-conduct-bce.pdf

Optional comment

https://bce.ca/responsibility/key-documents/2021-business-ethics.pdf The BCE Code of Business Conduct contains rules that apply to everyone within the company as it relates to ethical risks, bribery and corruption and it clearly states our "zero tolerance" approach to fraud, which includes bribery and kick-backs. In addition, it contains specific provisions applicable to gifts, pursuant to which employees are prohibited Many aspects of our business are governed by laws and regulations and compliance with such laws and regulations is basic to ethical conduct. Bell and its directors, executives, managers and other employees are expected to comply with the laws, rules and regulations of all countries in which we operate, as well as the expectations and requirements of our various regulators. These laws include, but are not limited to, telecommunications and broadcasting laws, securities laws, laws prohibiting the corruption of government officials, in Canada and abroad, as well as lobbying, competition, environmental, health and safety and employment legislation. Ethical behaviour, however, goes beyond mere

2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

No, and we have no plans to develop a policy

No, but we plan to in the next two years

Yes, included within a broader policy

Yes, articulated as a stand-alone policy

Optional comment

https://bce.ca/governance/code-of-business-conduct/2021-november-code-of-business-conduct-bce.pdf p.4-5-6 If you have any doubts about a possible conflict, raise the matter with your manager or contact the Business Conduct Help Line at www.clearviewconnects.com or by calling 1-866-298-2942 (toll free). If there is an actual or potential conflict of interest, you must disclose it immediately to your leader and as part of the annual online review process.

Prevention

3. Who receives training on anti-corruption and integrity?

Optional comment

The Code applies to everyone at Bell, including all directors, executives and employees of BCE Inc., Bell Canada and their subsidiaries. Throughout the Code, we will refer to these companies as Bell.

3.1. How often is such training provided?

	One time only	Every year	Every two or more years	We do not collect this data
All employees
Select employees
Contractors
Direct suppliers of the organization
Other – such as partners, clients, etc.
Indirect suppliers of the organization

Optional comment

Everyone at Bell, including members of our Board of Directors, executives and employees, are required to certify annually that they have reviewed and follow the Code of Business Conduct, which contains the rules that apply to everyone within the company as it relates to ethical risks, bribery and corruption. In addition, all employees are required to take mandatory online training on the Code of Business Conduct every two years. Our learning management system automatically reminds all employees to complete their training two years from the date of their last completion. New employees must certify their review of the Code of Business Conduct and complete the online training as part of their onboarding process. All team members are required to complete training in the Code of Business Conduct when they join the company, affirm that they have reviewed the Code annually, and refresh their training in the Code every 2 years.

4. Does the company monitor its anti-corruption compliance programme?

No, we do not monitor the anti-corruption compliance programme

Review issues on ad-hoc basis

Yes, through internal employee self-evaluations

Yes, through automated controls monitoring

Yes, through external independent monitoring

Yes, through other mechanisms

The Health, Safety, Security, Environment and Compliance (HSSEC) Oversight Committee monitors changes in legal and/or regulatory requirements, business Last update: January 2022 9/9 PUBLIC | BELL CANADA operations and policies that could affect BCE’s compliance risks, including risks related to unethical business practices. The HSSEC Oversight Committee focuses its efforts on employees who may be exposed to such risks, and analyses trends in public policy, stakeholder expectations and external events to engage the company in the development of strategies to enhance ethical behaviour and action plans to address emerging compliance risks as appropriate. BCE's Internal Audit Team has oversight, with the Corporate Secretary's Office, of all reports submitted through our Business Conduct Help Line. Every quarter, the Audit Committee receives a report from the Corporate Secretariat on submission activity. The Internal Audit Team is responsible for the review of the effectiveness and efficiency of business processes, the reliability and integrity of information, compliance with applicable laws, regulations, policies and procedures, and is focused on safeguarding company assets for all business units and majority owned subsidiaries within the BCE group. Management evaluates the effectiveness of our internal control over financial reporting annually, based on the criteria established in the Internal Control – Integrated Framework (2013) issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). A component of the COSO framework is the evaluation of conformity with the COSO principles through entity-level controls, which addresses the compliance to the BCE Business Code of Conduct and the Business Conduct Help Line.

Optional comment

BCE considers it vital that employees have the most effective tools to ask questions or raise issues concerning any ethical dilemma. Our Business Conduct Help Line can be accessed 24/7 by phone (1 866 298-2942) or online (clearviewconnects.com) on a completely anonymous and confidential basis, to ask questions or report concerns relating to issues under the Business Code of Conduct. The system is administered by a third-party firm, independent of BCE, specializing in the field. It also allows employees to track the progress of their inquiries online and respond to requests for additional information (when required), and provides BCE with an auditable record of issues. The Business Conduct Help Line received 215 reports and inquiries in 2021.

Response and Reporting

5. Please report the company's total number and nature of incidents of corruption during the reporting year.

	Number of incident(s)	Unknown	Choose to not disclose
Confirmed during the current year, but related to previous years
We do not disclose the type of incidents reported to the Code of Business Conduct line. The Business Conduct Help Line received 215 reports and inquiries in 2021 related to business ethic topics, not exclusively to anti-corruption.
Confirmed during the current year, and related to this year
We do not disclose the type of incidents reported to the Code of Business Conduct line. The Business Conduct Help Line received 215 reports and inquiries in 2021 related to business ethic topics, not exclusively to anti-corruption.

Optional comment

https://bce.ca/responsibility/key-documents/2021-business-ethics.pdf We do not disclose the type of incidents reported to the Code of Business Conduct line. The Business Conduct Help Line received 215 reports and inquiries in 2021 related to business ethic topics, not exclusively to anti-corruption.

6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

Initial case assessment

Internal investigation

Review by risk / ethics committee

Review by board of directors

External audit / review

Other (please provide additional information)

Not applicable/no incidents in the reporting period

Optional comment

https://bce.ca/responsibility/key-documents/2021-business-ethics.pdf BCE's full Board is entrusted with the responsibility for identifying and overseeing the principal risks to which our business is exposed, including business ethics risks, and ensuring there are processes in place to effectively identify, monitor and manage them. While the Board has overall responsibility for risk, the responsibility for certain elements of the risk oversight program is delegated to Board committees to ensure that they are treated with appropriate expertise, attention and diligence, with reporting to the Board on a regular basis. All reports submitted to our anonymous and confidential Business Conduct Help Line are reviewed and, as required, investigated, under the oversight of the Corporate Secretary's Office and our Internal Audit Team. If a report reveals a well-founded issue or concern, responsibility for remediation of system and process deficiencies will be allocated based on ownership while the relevant business segment remains responsible for addressing any employee misconduct through established procedures that include taking recommendations from appropriate corporate groups such as Human Resources, Corporate Security and Legal. The Corporate Security group has the primary responsibility for conducting investigations, except for submissions related to financial reporting, which are handled by the Internal Audit team. Regular reports are also provided to the Governance Committee and the Audit Committee with respect to our ethics program and our oversight of corporate policies across BCE.

7. Does your company engage in Collective Action against corruption?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes (please explain)

Optional comment

Since our operations are held in Canada, we abide by local Canadian standards and corruption is not a high risk in our context. We have fewer than 15 team members in the United States.

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

The BCE Code of Business Conduct contains rules that apply to everyone within the company as it relates to ethical risks, bribery and corruption and it clearly states our "zero tolerance" approach to fraud, which includes bribery and kick-backs. In addition, it contains specific provisions applicable to gifts, pursuant to which employees are prohibited from:  Soliciting, accepting or giving gifts, gratuities, favors or unusual hospitality from or to suppliers or customers, which may compromise - or appear to compromise - their ability to make fair, objective, business decisions or may unfairly influence a business interaction  Soliciting or encouraging gifts, hospitality, entertainment or anything else for personal use  Notwithstanding any other provision of the Code, offering gifts, gratuities, favors or hospitality to public sector recipients or sponsoring public sector events/activities without the express prior consent of BCE's Regulatory and Government Affairs Team Our Code of Business conduct requires that employees report any illegal acts or violations of the Code or other Bell policies and provides instructions on how to do so through our confidential and anonymous Business Conduct Help Line or by contacting the Corporate Secretary or the Chair of the Audit Committee. Furthermore, it clearly states that disciplinary action, up to and including dismissal, will be taken in the event of a violation of the Bell Code of Business Conduct. https://bce.ca/responsibility/key-documents/2021-business-ethics.pdf p.3-4