PERFORMANCE
PURPOSE
THAT MATTERS
BHLB
2022
ENVIRONMENTAL,
SOCIAL & GOVERNANCE
REPORT
1Berkshire Hills Bancorp, Inc. — BHLB | berkshirebank.com » 2022 esg Report

 Table of Contents/Overview »
 About This Report »
  Letter »
  Community Comeback »
 Materiality and Stakeholder
Engagement »
 Investor Performance Summary
and  Disclosure »


 Homeownership »
 Small Business Lending »
 Community Development
Lending and Investments »
 Sustainable Finance
and Impact Investments »
 Financial Wellness and
Economic Inclusion »

 Business Ethics and Consumer
Financial Protection »
 Customer Satisfaction »
 Data Privacy, Cybersecurity
and Fraud »
  Risk Management »
 Responsible Asset Management »

 Board Overview »
 Risk Management
and Compliance »

 Human Capital Management »
 Health and Wellness »
 Diversity, Equity and Inclusion »

 Corporate Giving and
Berkshire Bank Foundation »

 Climate Change and Natural
Resource Management »

 Awards and Recognition »

  Scorecard »
  Disclosure »
  Content Index »
BERKSHIRE BANK
  )
Berkshire Hills Bancorp, Inc. () is the parent company

as a leader in environmental, social and governance ()
performance, demonstrating that corporations can deliver

generations. It also differentiates through its DigiTouch
SM
strategy that combines extraordinary community bank service
with convenient, user-friendly technology enabled through


To be a high-performing, leading socially responsible community
bank in New England and beyond.


businesses and organizations by making banking available where,
when and how it’s needed.

Where you bank matters.
BERKSHIRE BANK AT A GLANCE
 Assets:
 Retail Banking,
Consumer Lending & Payments,
Commercial Banking, Wealth
Management and Private Banking, as

national, direct small business lending
division providing  loans
 
s and
MyTeller
SM
s in Massachusetts,
New York, Vermont, Connecticut
and Rhode Island
 More than

  Boston
 
in western Massachusetts
TABLE
CONTENTS
OF
CT
MA
NH
RI
VT
NY
2Berkshire Hills Bancorp, Inc. — BHLB | berkshirebank.com » 2022 esg Report
HOW TO CONNECT
We value your active engagement.
If you would like to connect with us to offer your




berkshirebank.com »


berkshirebank.com/help »

investorrelations@berkshirebank.com »

csr@berkshirebank.com »

foundation@berkshirebank.com »

@BerkshireBank »

facebook.com/BerkshireBank »

linkedin.com/company/berkshirebank »

@berkshirebank »

This report presents the material topics and impacts
of our Environmental, Social, Governance and


noted. This report encompasses all of Berkshire Hills
Bancorp’s wholly owned operations and activities.
Throughout this report, “Berkshire Bank” or “the
Bank” refers to Berkshire Bank. “” or “the
Company” refers to Berkshire Hills Bancorp.
All data reported in currency is in  and abbreviated
to (thousands),  (millions) and (billions). This


U.S. securities laws, and the information contained
herein should not be read as necessarily rising to the
level of materiality of disclosure required in securities


Berkshire Hills Bancorp’s Corporate Responsibility
report is based on globally recognized reporting
frameworks and standards, including the 
Foundation’s International Sustainability Standards
Board ()  Commercial Bank disclosure

Related Financial Disclosure (), and the Global
Reporting Initiative () standards. We continue to
monitor the reporting landscape to ensure it aligns
with best practices as well as the size and complexity
of our operations.

Berkshire Hills Bancorp
 »
Berkshire Hills Bancorp
 »
Berkshire Hills Bancorp
Corporate Governance Website »
s)


s) provide
a plan for action to address challenges across the
globe. The Company’s corporate responsibility














REPORT
ABOUT
THIS
3Berkshire Hills Bancorp, Inc. — BHLB | berkshirebank.com » 2022 esg Report
DEAR STAKEHOLDERS,
Berkshire has always been at the forefront of empowering the




We’ve long understood that purpose and performance matter.

to invest more in our business and stakeholders. It allows us to create
an ecosystem of positive impact and value through the totality of
our environmental, social and governance  activities, which


As we write this letter, the American and global economies are

sector. Against this backdrop, we remain resolved to maintain our
position of strength and buoyed that our sense of purpose will not
only guide us through but continue to enhance our performance.
Our brand promise — where you bank matters — is more true now
than ever. Berkshire stands ready to help all its stakeholders navigate
these challenging times and reach what we know are better days
ahead. Over the last year, we helped unlock the potential for all our
stakeholders as we elevated our impact and furthered progress on
Berkshire’s Exciting Strategic Transformation . A few of many

 Issuing the 

 Releasing our 
 Launching the 
  for our employees
 Listing in  and 

 Being recognized by Newsweek as one of 
 and by the 

 Exceeding our   goal to become one of the
leading  banks in the country
 Delivering meaningful progress on our 

in low- and moderate-income neighborhoods and lending over


people in homes, and building a green and equitable economy.
They are meaningfully contributing to our improved performance,
leading to new business opportunities, deepening relationships with
consumers and attracting the best talent.
We’ve stood by our customers, employees, shareholders and

We will always remain purpose-guided and performance-driven
as we continue on our path toward becoming a high-performing,
leading socially responsible community bank in New England
and beyond.
Our ability to deliver on that vision starts with you. It starts with your
relationship with Berkshire as a customer, employee, shareholder
or community partner. Together, we can build a better approach
to banking that leads to endless possibilities for all of us. We invite you

Onward and upward.
(He, Him, His)

(He, Him, His)
, Corporate Responsibility
THAT MATTERS
PERFORMANCE
PURPOSE &


Achieved  top
quartile  score
based on aggregated 
rankings, solidifying position
as a leader among socially
responsible banks


Launched the Center
for Women, Wellness & Wealth
to provide women with
tools to help create a future

and wellness


Sustainability Bond
by a U.S. public community
bank holding company with
 in assets


Raised the minimum
starting pay for employees



Released Sustainable Financing
Framework to guide Berkshire’s



Delivered meaningful

Community Comeback
program aimed at addressing
four areas critical to the
long-term vibrancy and success

fueling small businesses;


and empowerment; and funding
environmental sustainability


a listing of awards
and accolades »
1
4Berkshire Hills Bancorp, Inc. — BHLB | berkshirebank.com » 2022 esg Report
 Community Comeback,


Exciting Strategic Transformation ().
The plan focuses on strengthening all of our communities and unleashing
the untapped potential within every community we serve through four key



our neighborhoods and employees, and strengthen our diversity, equity

toward the achievement of the plan, helping communities across our footprint.
BEST




 

Small Business Lending $587 $1.5

Mortgage Lending $1.25B $2.5
Community Contributions $5.5 $15
Employee Volunteer Time $901
$3
equivalent
Socially Responsible Investments under Management $41 $50

Lending for Low- and Moderate-Income Neighborhoods $1.7 $2.5
Lending for Minority Mortgage Borrowers $164 $200
Individuals Impacted by Financial Wellness
Programming***
351,845 300,000
Socially Responsible Customer Bank Accounts 180,231 

 $36 4 $300
Renewable Electricity Usage 90% 100%

             


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$5B for local communities
5Berkshire Hills Bancorp, Inc. — BHLB | berkshirebank.com » 2022 esg Report
Our 


our stakeholders today and into the future. Top material topics are outlined below.
These topics drive the content, structure and scope of our report and program.
Detailed information on our most recent Materiality Assessment can be found on
our website at berkshirebank.com/esg. »

 Board Governance
 Risk Management and Compliance

 Recruitment, Retention, Training
and Engagement
 Diversity, Equity and Inclusion
 Health and Wellness

 Business Ethics and Consumer
Financial Protection
 Customer Satisfaction
 Data Privacy, Cybersecurity
and Fraud
  Risk Management

 Community Investments

 Financing Environmental
Sustainability
 Climate Change
 Energy and Natural Resource
Management


 Homeownership
 Small Business Lending
 Community Development Lending
and Investments
STAKEHOLDER ENGAGEMENT
It’s our goal to engage stakeholders clearly, honestly and respectfully to
understand current and emerging trends that impact our business operations.
We work together to identify topics that demand our attention. We are proactive
and responsive to the unique needs of all stakeholders, evaluating each of their

meaningful engagement with our stakeholders is critical to improving our business
and communities.
  
Employees
Performance reviews, training and
development, surveys, emails, intranet,
employee assistance fund, employee town
halls, community visits

performance and rewards, work-life balance,
customer focus, future of Berkshire
Customers
Meetings, phone calls, emails, satisfaction
surveys, social media
Customer service, communication, account
offerings, fees, branch locations/hours, digital
accessibility and personal service, privacy and
data security
Shareholders
and Investors
Phone calls, emails, annual shareholder
meeting, quarterly earnings calls, shareholder
outreach, conferences, non-deal roadshows
Evolution of company leadership, continued
 plan
progress, human capital management
practices,  performance, cybersecurity
Communities
Meetings, conferences, forums, social
media, email, foundation grantmaking,
 volunteering, stakeholder listening
sessions, industry/chamber memberships,
community rooms
 Community Comeback, housing, small
business support, labor market, diversity,

Government
and Regulators
Meetings, webinars,  and compliance
reviews, emails, phone calls
Strong regulatory partnerships, commitment
to risk governance, support for mission
and vision
Suppliers Meetings, phone calls, emails, surveys, events Procurement opportunities, supplier diversity

Organizations
Meetings, email, social media, conferences,
stakeholder listening sessions, foundation
grantmaking,  volunteering,
board service
 Community Comeback, funding,
volunteer opportunities, labor market,
diversity, equity and inclusion



&



&
6Berkshire Hills Bancorp, Inc. — BHLB | berkshirebank.com » 2022 esg Report
Throughout this report, we reference topics contained in the  Foundation’s
International Sustainability Standards Board  Commercial Bank
disclosure standards. Our investor performance summary presents the topics
and standards that are most relevant to our operations and highlights where
those quantitative and qualitative measures can be found. If a standard is not

could cause a competitive disadvantage; or is not collected in a manner that
allows us to correlate it to an  standard. Detailed analysis relevant to all our
stakeholders is shared on subsequent pages throughout this report.
   

-
(1) Number of data breaches, (2) percentage
),
(3) number of account holders affected
Not disclosed
-
Description of approach to identifying and
addressing data security risks
Data Privacy, Cybersecurity and Fraud
pg. 12




-
(1) Number and (2) amount of loans outstanding

business and community development

(1) 4,286 (2) $289
Small Business Lending pg. 7

(1) 76 (2) $318
Community Development Lending and
Investments pg. 8
-
(1) Number and (2) amount of past due

designed to promote small business and
community development

(1) 207 (2) $6.6

(1) 0 (2) 0
-
Number of no-cost retail checking accounts
provided to previously unbanked or
underbanked customers
180,231*
Financial Wellness and Economic
Inclusion pg. 9
-

initiatives for unbanked, underbanked or
underserved customers
157,862
Financial Wellness and Economic
Inclusion pg. 9




-
Commercial and industrial credit exposure
by industry
See chart FN-CB-410a.1 on pg. 8
-
Description of approach to incorporation
of environmental, social and governance 
factors in credit analysis
ESG Risk Management pg. 14
   

-
Total amount of monetary losses as a result
of legal proceedings associated with fraud,
insider trading, antitrust, anticompetitive behavior,
market manipulation, malpractice or other

Not disclosed. Material legal
proceedings are included in Part I,
Item 3 of the 2022 Annual Report on

-
Description of whistleblower policies
and procedures
Business Ethics and Consumer
Financial Protection pg. 10 and
Business Code of Conduct and
Anonymous Reporting Line


-
Global Systemically Important Bank  score,
by category

-
Description of approach to incorporation of
results of mandatory and voluntary stress tests
into capital adequacy planning, long-term
corporate strategy and other business activities
Disclosed as part of Part 1, Item 1a,
Risk Factors and Part 2, Item 7
Management Discussion and Analysis
of our 2022 Annual Report on Form



-
(1) Number and (2) value of checking and

(b) small business
Personal
(1) 253,804 (2) $2.6
Small Business
(1) 5,599 (2) $388
-

(a) personal, (b) small business and
(c) corporate
Personal
(1) 44,072 (2) $2.8
Small Business
(1) 4,286 (2) $289
Corporate
(1) 4,144 (2) $5.3



SUMMARY

7Berkshire Hills Bancorp, Inc. — BHLB | berkshirebank.com » 2022 esg Report
HOMEOWNERSHIP
Berkshire recognizes that owning a home does more than put a roof over your
head. It is the key to unlocking upward economic mobility, helping our

made all the more important given the housing market trends that took place in
the communities we serve. Rising interest rates, home prices and low inventory

market. Despite these headwinds, Berkshire continues to assist its borrowers,


prior years, to help individuals realize the dream
of homeownership.

assistance program and adopted alternative credit underwriting standards for
those with no credit history for select mortgage products. These programs were
all aimed at assisting low- and moderate-income borrowers as well as those from
underrepresented populations. In addition, Berkshire offers a comprehensive
suite of mortgage options, including the Federal Home Loan Bank of Boston Home
Equity Builder Program,  Residential Program,  Mortgages and the 
Loan Program, along with numerous state and local programs to meet each
borrower’s unique needs. If customers run into challenges paying their bills,

help get people back on track.
 Community

achieve the dream of homeownership. Thanks to the collective efforts of Berkshire


SMALL BUSINESS LENDING
Small businesses are the backbone of our main streets and local economies.
As they continued in their recovery from the global 

recession and an increasing interest rate
environment. Despite the state of the economy,

many small businesses throughout our market,
most remain optimistic about their future. That’s
in part because Berkshire, as it always has, stands by its small business customers,

and help make the best ones possible.


one of the top  lenders in the Country providing several  and traditional
lending solutions as well as a full suite of depository, cash management and
merchant services.
We understand the outsized impact small businesses have on local communities
and that’s why, as part of our  Community Comeback program, we set a
goal to fuel the untapped potential of the business community by increasing

prepare entrepreneurs for success, as well as increasing representation among
historically marginalized populations. Since the launch of the program, Berkshire

we continue to expand partnerships with organizations such as the Initiative for
a Competitive Inner City , Valley Venture Mentors, EforAll and dozens of
others. In addition, Berkshire created special-purpose credit programs, such as
The Futures Fund, to further assist business owners from marginalized and
underrepresented communities.
Dollar value of
mortgages originated
$1.1
Dollar value of loans
outstanding to support
small businesses
$289


needs and is proud to partner with customers, like Common
Roots Brewery, who share in our commitment to sustainability
and community impact.



&
8Berkshire Hills Bancorp, Inc. — BHLB | berkshirebank.com » 2022 esg Report
COMMUNITY DEVELOPMENT LENDING
AND INVESTMENTS

sector and individual stakeholders to deploy its capital in a manner that helps
unleash the potential of every community. We harness our expertise to catalyze
economic development in urban and rural communities across our footprint
through our community development lending and investment programs.
Our community development lending program encompasses activities aimed at



growth and delivering on our  Community Comeback. The Bank has a total
 for all community development loans.

 in community development
investments at year-end. During our most recent Community Reinvestment Act
(
Satisfactory for Lending and Outstanding for Community Development
Investments. Our  exam results and other formal and informal regulatory
guidance help inform goal-setting and the Company’s strategy. We will always
look to meet all our communities’ credit needs regardless of  code or income.

Wholesale Trade $689
Manufacturing $328
Real Estate, and Rental and Leasing $29 9
Health Care and Social Assistance $173
Finance and Insurance $163
Arts, Entertainment and Recreation $146
Retail Trade $142

Technical Services
$87
Administrative and Support, and Waste
Management and Remediation Services
$68
Transportation and Warehousing $57
SUSTAINABLE FINANCE & IMPACT INVESTMENTS
Berkshire became 
 


Sustainable Financing Framework, including renewable electricity generation;
green buildings; renewable energy technology, storage and manufacturing;



a Morningstar Company, for its impact and alignment with the International
Capital Market Association’s 



and, where feasible, qualitative and quantitative measures of the expected
environmental or social impact.
Beyond the issuance of its sustainability bond, Berkshire looks for innovative ways
to advance its  positioning and its strategic business priorities through


solutions to residential and commercial clients. This includes the Mass Save® 


investments in Small Business Investment Companies  and other strategically
aligned assets that are within risk appetite and drive a competitive rate of return.
The Company also has a strong tax-credit business whereby it makes targeted
investments in low-income housing tax credits , historic tax credits 
and solar tax credits to further Berkshire’s  goals and strengthen its Community
Reinvestment Act  performance. These investments help bring to life

while providing an appropriate return to the Bank consistent with its capital and
tax strategies.

originated
$67
 $318

held at year-end
$71
berkshirebank.com
Berkshire Sustainable
Financing Framework
June 2022
FINANCIAL ACCESS & AFFORDABILITY
9Berkshire Hills Bancorp, Inc. — BHLB | berkshirebank.com » 2022 esg Report

Berkshire launched the Center to provide women with tools to help

partnerships with community organizations, specialized experts and

philanthropic coaching and development support, and complimentary
portfolio reviews through Berkshire Bank Wealth Management.


addressing the longevity risk that women face through a transformative
approach to wealth management, which centers on balance, stability,
growth and overall wellness.
FINANCIAL WELLNESS AND ECONOMIC INCLUSION

wealth. From our founding to serve those working in textile mills and factories
to our vision today to be a leading socially responsible community bank in New
England and beyond, we have been unwavering in our belief that good for some
isn’t good enough. Berkshire sets itself apart from its peers through a focus on
exceptional customer experience that’s driven by its 
SM
commitment
to combining extraordinary personal service with convenient, user-friendly

performance on environmental, social and governance  matters.


bring the "unbanked" and "underbanked" into the banking system. We provide

programming and partnerships, including our

Wellness. These services are available in person
from Berkshire Bankers, over the phone and through





that features online resources that offer information, activities and conversation


community organizations and at targeted events, to increase their reach and



GreenPath Financial Wellness, to get the counseling and support they need
to realize their full potential.
Our DigiTouch
SM


inclusion, making banking available when, where
and how customers want it. Berkshire has robust

s and s across its New England and New York
footprint. MyTeller
SM
interactive teller machines
provide greater access across our footprint for
individuals looking to do basic banking services,
fully accessible online and mobile channels, and
a best-in-class digital online account-opening
experience. This makes creating a new account from
anywhere effortless, while improving fraud detection
and risk-based decision-making. Our unique, complimentary MyBanker Program
brings the Bank to the customer based on their preference by providing a personal

customers, regardless of wealth, in person, by phone and video conference.

by offering several no- and low-cost checking and savings accounts to young
adults, senior citizens, the underbanked, active-duty military members, and

extra fees, monthly or annual maintenance fees or minimum average balance
requirements. The Company continues to work toward building economic equity

solutions and programs, including its MyFreedom Checking account, nationally
 
special-purpose credit program that provides access to a low-interest, low-barrier-

around technical assistance to minorities,  and other businesses owned



and provides the opportunity to start a committed banking relationship.
Number of individuals

inclusion programming
157,862
Number of low-/no-cost
retail checking accounts
180,231

Berkshire invited local businesses, entrepreneurs,
artists and start-ups to participate in our retail
pop-up program. Selected applicants were
granted a series of opportunities to sell their
products, grow their customer base, and increase
their knowledge and skills at a dedicated
Berkshire storefront and at the Big-E, the third
largest fair in the United States. The program
is targeted toward businesses owned by
women, people of color and those from the
 community.
berkshirebank.com/cwww »
FINANCIAL ACCESS & AFFORDABILITY
10Berkshire Hills Bancorp, Inc. — BHLB | berkshirebank.com » 2022 esg Report
BUSINESS ETHICS AND CONSUMER FINANCIAL PROTECTION

Berkshire works to uphold the highest ethical standards
in all areas of our business through a combination of formal
policies, procedures, employee training and governance
mechanisms. The Company also works to ensure its
customers and consumers are informed and protected

Berkshire maintains a Code of Business Conduct and
Employee Handbook, which applies to all company
employees and operations. Employees must attest their
adherence to the Code of Business Conduct upon beginning
their employment and attest again annually. The Code
covers topics such as bribery, corruption, insider trading,
gifts, political activity, equal employment opportunity,

complete annual training to ensure compliance with the
Code and other applicable policies designed to protect
consumers. We also have numerous other policies and
procedures to help identify corruption and support a strong
culture of compliance applied across all operations.

Bribery and corruption are illegal and can expose

other penalties, up to imprisonment, as well as cause

Be  values, vision, Code of Business Conduct and
Employee Handbook set expectations for how employees
should perform within the workplace. Berkshire’s Code
of Business Conduct and Employee Handbook include

payments and lay out strict anti-bribery and anti-facilitating
payments provisions.

Our Anonymous Reporting Line and Whistleblower Policy
establish the standards and procedures to ensure that
handling of any complaint related to violations of our Code
of Business Conduct, any wrongdoing, including fraud or
embezzlement, or any questionable, unethical or suspicious
accounting or auditing matters comply with management’s

all Company operations and employees. Employees receive
annual training and regular communications across multiple
channels, including a feature on the Company’s intranet
homepage that promotes access.
Upon receipt of a complaint, the Audit Committee chair
or other Audit Committee designee will determine if the
complaint pertains to accounting matters. If the complaint
is determined to pertain to accounting matters, the Audit
Committee chair or Audit Committee designee will submit
the complaint to the full Audit Committee, which will
then investigate the matter and take corrective action as

with Human Resources’ assistance. If the complaint is
determined to not involve accounting matters, the Audit
Committee chair or Audit Committee designee may direct
the complaint to other appropriate Board Committees,
 
outside legal or other advisors to review and, if and as
necessary, conduct an investigation for determining
appropriate action.

Berkshire is committed to fair and transparent marketing
practices and maintains strong relationships with its
regulators. The Company promotes products, services and

of its communities, building trust with consumers. The
Company’s comprehensive Marketing Advertising
Policy, which applies to all operations, further outlines
expectations for fair and responsible marketing, which
includes transparent pricing information, use of clear and
bold print and compliance with all regulations, including
Unfair, Deceptive or Abusive Acts or Practices ,
Truth in Savings Act, Fair Housing Act, Equal Credit
Opportunity Act, Truth in Lending Act, Fair and Accurate
Credit Transactions  Act, The Interagency Statement
on Retail Sales of Non-Deposit Investment and Insurance
Products, Consumer Protection for Bank Sales of Insurance,
 
reviews all marketing materials before their posting to ensure
accordance with the appropriate regulations. Oversight
of Berkshire’s marketing and advertising falls to the ,
Director of Marketing. The Compliance Committee provides
further management-level oversight, and the Board’s Risk
Management, Capital and Compliance Committee provides
board-level oversight. Employees receive annual training on
fair advertising and all applicable compliance regulations
impacting Berkshire’s advertising and marketing initiatives.


regulations for responsible sales and compensation
practices. It may engage in sales and marketing programs



including the Federal Communications Commission’s 
Telephone Consumer Protection Act 
Federal 

with all requirements of  (Unfair, Deceptive and
Abusive Acts and Practices) through clear, concise and
meaningful advertisements, disclosures, and other sales and
marketing collateral used in any sales solicitation program.
Berkshire maintains a Sales Solicitation Policy that covers all
employees and operations and governs all types of sales
activities. All customer-facing employees and those
engaged in any type of sales solicitations are required to
complete annual trainings related to ethical sales practices,
marketing and compliance to ensure they have the knowledge,
understanding and skills to deliver a superior customer
experience, comply with regulations and offer solutions that


As a community-driven lending institution, Berkshire
implements respectful and conscientious collection activities
grounded in applicable law to preserve consumers’ rights.
This includes educating borrowers to maintain proper
payment habits throughout the life cycle of a loan. Berkshire
Collections teams always strive to be tactful and sympathetic
to the borrowers’ circumstances, while educating them
on the importance of making payments and maintaining
a good credit rating. Our Collections Department also

organizations to educate delinquent borrowers and help

Collections Department receive regular, ongoing training on
best practices, compliance requirements and procedures.
The department also maintains detailed procedures that
outline the Company’s debt collection practices and
complete quarterly monitoring reviews to ensure that we
are operating within regulations and our own policies.
Our Consumer Debt Collection Policy, which applies to
the Bank’s operations, helps ensure compliance with all
applicable laws and ensures that our policies and procedures
are guided by the Fair Debt Collection Practices Act. It is to


11Berkshire Hills Bancorp, Inc. — BHLB | berkshirebank.com » 2022 esg Report

a relationship of understanding, trust and cooperation.

solutions and alternatives to rectify the borrower’s
delinquency within the shortest period of time, while also
preserving bank safety and soundness requirements.



comprehensive  programs that include established
internal policies, procedures and controls, a designated 
/

testing of the program by an independent audit function.

terrorism or other illegal activity. Because of this, it is the
responsibility of the Board of Directors and all employees to
not only comply with the requirements of the Bank Secrecy
Act but to be proactive in the prevention of these activities
and vigilant in looking for activities at the institution that may
constitute money laundering.
Berkshire maintains a comprehensive Bank Secrecy Act/
Anti-Money Laundering Policy designed to ensure
compliance with all applicable regulations and laws as well
as support strong risk management practices. The policy
applies to all Company operations and includes our customer

Customer). The policy details the requirements for our 
/


services along with exceptions. The policy also contains
Berkshire’s commitment to identify unusual and suspicious

steps and actions against those who attempt to use its

Our policy includes the appointment of a 
/

who has day-to-day responsibility for the  and 
efforts, a system of internal controls, self-monitoring and
independent testing, customer due diligence and training.
Our employee training program includes provisions to ensure
that all personnel, including senior management, who have
contact with customers, who see customer transaction
activity or who handle cash in any way, receive appropriate

/
 training at least annually. We have a detailed
reporting process that includes currency transaction
reporting , suspicious activity reporting , a task-
force and ongoing record-keeping requirements. Berkshire
maintains extensive procedures for high-risk customers
and products or services as part of the policy. This includes
enhanced due diligence and monitoring requirements.

compliance with all regulatory requirements and details
all the steps Berkshire undertakes to verify the identity of
all its customers, along with risk management and board
oversight. In addition, not less than annually, our Internal Audit
Department, or a suitable vendor of their choosing, reviews
the Bank’s compliance with the Bank Secrecy Act and its

/
 policy. The policy is reviewed and approved annually
by applicable Committees and the Board of Directors.


solutions to meet our customers’ needs. Our Products
and Services Development Policy creates a governance

and enhanced products and services to ensure risks are

are developed and implemented consistent with sound risk
management practices and align with the Company’s overall
business plans and strategies. Proposed products also must

of consumers consistent with the Company’s Be 
values and applicable laws and regulations.
Risk management for new products and services is a shared
responsibility of various stakeholders across the Company,
including the full Board of Directors, Risk Management,
Capital and Compliance Committee of the Board, Enterprise
Risk Management Committee, Products and Services
Development Committee, Executive Management and
Line of Business Owners. Our Products and Services

solutions are delivered consistently with our values, ethical
standards, policies and practices. The committee oversees


provides guidance and oversight during the due diligence
and implementation of proposed products and services,
as well as monitors results to ensure compliance with risk

regulatory requirements. All products undergo a thorough
risk assessment, which includes, but is not limited to, an

reputational risks. This includes an evaluation of the social
impact, along with any social/environmental risks related to
the proposed product or service. To further ensure those
risks and opportunities are appropriately mitigated and
,
Corporate Responsibility serve as voting members of the
committee. Through its formal assessment process, the
committee helps ensure that new products and services are

launched. Berkshire maintains monitoring systems to ensure
it continuously monitors the social impact and risks of its

best interests of its customers and communities. In addition,
customer-facing employees receive annual training for all
new products and services.
CUSTOMER SATISFACTION
Berkshire views our customers’ satisfaction as paramount
to our success and, as such, has incorporated publicly
disclosed measures and goals into our  plan to enhance
our current performance. The Company’s goal is to be in the
top quartile of all banks in New England in its Net Promoter
Score, a measurement of customer loyalty that predicts

multiple programs in place to monitor, measure and evaluate
customer satisfaction, as well as address and resolve any
complaints brought to our attention.

Head of Retail Customer Experience to drive integrated
improvements in how our customers perceive Berkshire
across the franchise. These efforts complement our ongoing
partnership with  Power, who completes an ongoing
comprehensive survey of our customers’ satisfaction with
our in-branch and digital experiences. This partnership
allows us to gain valuable insights into our customers’
experience, monitor perceptions, evaluate performance and
identify opportunity areas. Our customers shared several
areas where they felt Berkshire could enhance its offerings,
including customer communications, account options,

service. As a result, we are taking a number of steps to
address these opportunities, including developing new
programs, services, enhancing employee training and
upgrading our customer communications. Berkshire has
already implemented new customer service training
programs and expects to roll out expanded customer call
Percent of customer
complaints addressed
100%
RESPONSIBLE BANKING
12Berkshire Hills Bancorp, Inc. — BHLB | berkshirebank.com » 2022 esg Report
center hours, a new online and mobile experience,
and onboard additional communications resources.
We expect that these collective actions will help improve
our customers’ experience and contribute to our culture
of service excellence.
Another key dimension to how we deliver an exceptional
customer experience is in the management of customer
complaints. When we receive customers’ complaints, we
make sure to successfully address and resolve them as
quickly as possible. The Board of Directors Risk Management,
Capital and Compliance Committee provides Board-level
oversight of the Company’s complaint management process,
which is managed by staff in our Compliance Department
in close collaboration with all business lines. Complaints are
written statements, including emails, letters, faxes, social
media posts or verbal comments indicating dissatisfaction
with a product or service. In some cases, regulations include

received. All business lines have a responsibility to respond
to and resolve customer inquiries and complaints. All
complaints are documented and tracked to ensure they
are resolved to a high level of customer satisfaction.
Our complaint management system also allows us to
identify trends, elevate those trends and implement
mitigating measures to address and ultimately reduce
instances of dissatisfaction.


reduction is due to multiple factors, including enhancements
to our complaint resolutions processes, customer experience
improvements, a continued return to more normalized pre-
pandemic conditions and activities that continue to be rolled
out as part of our  plan. We continue to strive to resolve all

customer complaints were addressed.
DATA PRIVACY,
CYBERSECURITY AND FRAUD

information of our customers is a top priority. As a community

risks relating to the use of technology and cybersecurity,
including denial of service attacks, ransomware, hacking

information or the creation of unauthorized transactions.

 Risk Factors.
Our information and cybersecurity function is designed to
mitigate these risks proactively. It includes a comprehensive
Information Security Program containing technical,
administrative and physical controls and additional policies,
processes and procedures to assist with safeguarding

or destruction. It will also help protect our information

destruction, loss, misuse, theft or denial of service.
  The Company’s
Information Security Program provides direction for

integrity, and availability of the Company’s information
assets, including customer information under guidelines
established as part of the Gramm-Leach-Bliley Act .
This program informs the organization of the administrative,
technical and physical safeguards in place to adequately
protect nonpublic personal information, as well as comply
with applicable laws and regulations. The Information
Security Program sets forth the Company’s commitment
to the continual review and improvement of policies,
processes, procedures and standards for evaluating
electronic and physical methods of accessing, collecting,
storing, using, transmitting, disposing of and protecting
customer information. The Company leverages relevant
expectations from the Federal Financial Institutions
Examination Council  and uses standards from the
National Institute of Standards and Technology ,
among others, to control data security risk, as well as to
assess the maturity and effectiveness of the program.
  The purpose of the Acceptable
Use Policy is to clearly establish each member of the
Company’s role in protecting its information assets and
communicate minimum expectations for meeting these

Company to implement a comprehensive systemwide
Information Security Program. The policy applies to all
users of computing resources owned, managed or
otherwise provided by the Company. Computing resources
include all Company-owned, licensed or managed
hardware and software, email domains and related
services, and any use of the Company’s network via a
physical or wireless connection, regardless of the ownership
of the computer or device connected to the network.
  The policy provides a
framework for classifying and protecting information for
the Company and aids in determining the appropriate

involves the assignment of a label to data indicating the


in this policy. The label then assists the Company with
ensuring proper safeguards are in place for the data.

Berkshire’s Data Governance Program.
  The policy establishes
requirements for security monitoring and event
management to detect unauthorized activities on company
information systems. Frequent monitoring and logging
components are required to effectively assess information
system controls, operations and general security. This

audit requirements for user activities, exceptions and
information security events; logging activities and actions
required to resolve system fault errors; guidelines for the
frequency of reviewing audit logs; protection of audit logs

integration of suspicious audit events and investigation
into incident response processes.
  The Security


information assets and encompasses the  infrastructure,
the information that infrastructure supports and the
Company’s regular business operations. The policy
ensures that a plan of action and approved procedures
for incident handling, investigations and responses,
including details of the tasks, roles, responsibilities and
accountabilities is maintained, reviewed and updated
as appropriate. It also ensures security incidents are
categorized and prioritized to ensure continuity of core
services within the Company and Berkshire is prepared
to effectively respond and contain security incidents.
 
Vulnerabilities create security weaknesses that can
be exploited by criminals and other adversaries. The
purpose of this policy is to ensure the company reduces
risks resulting from exploitation of published technical
vulnerabilities. The company ensures all applications
are fully supported by the vendor, maintains all support
and maintenance agreements for the lifetime of the
application, includes language in contracts requiring

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13Berkshire Hills Bancorp, Inc. — BHLB | berkshirebank.com » 2022 esg Report
timely updates of applications, obtains timely information
about technical vulnerabilities of systems and applications
in use, evaluates its exposure to such vulnerabilities,
takes appropriate, timely measures to address the
associated risk, including, but not limited to, the patching
of vulnerabilities.
The Information Security Program and all applicable policies
apply to all Company operations, and all employees receive
annual training. Routine security assessments and internal/
external audits are conducted on a minimum of an annual
basis to ensure internal controls are adequate. Updates and
oversight on the information security program are provided
by management to the Replace with Risk Management,
Capital and Compliance Committee of the Board of Directors

The Company continually reviews and invests in new
technologies and cybersecurity professionals to mitigate
threats and adhere to regulatory requirements.
Cybersecurity resources are dedicated to protecting the



to numerous laws and regulations, including Gramm-Leach-
Bliley and Sarbanes-Oxley acts. The Company leverages
relevant expectations from the Federal Financial Institutions
Examination Council  and uses standards from the
National Institute of Standards and Technology 
to help manage cybersecurity risk by organizing information,
enabling risk management decisions and addressing
emerging threats.

 A top-down focus on cybersecurity from our Board
of Directors, Board Risk Management, Capital and
Compliance Committee and executive management to
prioritize cybersecurity initiatives based on risk, emerging

 Robust enterprise risk governance and oversight to
enforce adherence to cybersecurity frameworks, policies
and standards, and to meet compliance initiatives and
requirements to ensure proper data protection, including
encryption of all data and clear policies governing access
and control of data
 
security tool stacks and continuous security assessments
to ensure proper risk mitigation based on emerging threats
 Strong security controls on customer-facing applications,
including multifactor authentication and fraud monitoring
 Strong partnerships with industry-leading, third-party
security providers for system monitoring, threat
intelligence and incident response, along with robust
third-party due diligence practices that include ongoing
monitoring of critical third-party service providers.
In addition, we expect third parties to maintain a system
of technologies, policies, procedures and controls to
detect and prevent fraud, unauthorized access or use
and disclosure of any customers’, employees’ Company

 Implementation of cybersecurity through investing in
highly skilled talent and leveraging technologies to
identify and mitigate existing and emerging threats
 Promotion of cybersecurity through employee awareness
and cybersecurity-related training focusing on email/
internet security, social engineering and protecting
customer information
 Implementation of a comprehensive
vulnerability management program
to continually assess the threat and
vulnerability landscape, along with
leveraging industry-leading tools and intelligence to
detect, evaluate, prioritize and track vulnerabilities
through remediation
 Comprehensive cyber insurance policy to ensure
coverage is in place to protect the bank, its employees,
customers and shareholders
 Collaboration with threat intelligence organizations,
law enforcement agencies and partners to keep abreast
of cybersecurity threats
 Commitment to notify stakeholders in a timely manner
in case of policy changes or data breach, obtain user
data through lawful and transparent means with explicit
consent where required, and collect and process user
data that is limited to the stated purpose
If a data security breach is discovered, the Company has
a comprehensive security incident response plan that

including those impacted based on state and federal
requirements. Potential corrective actions are taken to
prevent a similar breach from happening in the future.
The Company also maintains a business continuity program
that addresses crisis management, business impact, and
data and systems recovery.

Berkshire adheres to all federal and state regulations as


service. The Company maintains a comprehensive
Privacy Policy, which applies to all operations, to protect


the Company’s information-sharing practices. This includes
a commitment to collect and process data that is limited to
its stated purpose and collected through lawful and
transparent means, a commitment to notify individuals in a
timely manner in the event of a policy change or data breach
and clear terms governing the collection, use, sharing and
retention of data. Berkshire’s privacy policy and statements
outline the Company’s practices and consent requirements
surrounding the handling of personal data and govern

deletion of their data.
All employees are educated at least annually about the

information security and privacy. In addition, security
procedures have been implemented that help prevent
unauthorized access to consumer and customer information
and will safeguard information that is exchanged with third
parties in accordance with applicable laws and regulations,
including the Gramm-Leach-Bliley Act  and the Federal
Right to Financial Privacy Act .
The Company incorporates privacy and data security
considerations throughout its operations, including the
development of new products, services and programs.
Berkshire provides regular, ongoing resources to its

website and hosted webinars. Each year, the bank celebrates
fraud prevention week with a series of internal and external
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14Berkshire Hills Bancorp, Inc. — BHLB | berkshirebank.com » 2022 esg Report
communications programs and customer events. Berkshire’s
fraud prevention experts are regularly featured in regional
media outlets. They raise awareness of emerging trends,
provide best practices and tips to help prevent fraud.
Robust ongoing training and Berkshire’s Fraud Crushers
Program, which rewards employees for helping to protect
our customers’ privacy and preventing fraud, further
amplify the Company’s strong commitment to privacy
and fraud prevention.
ESG RISK MANAGEMENT
We understand that  risks can lead to reputational,
operational, strategic and credit risks affecting both short-
and long-term stakeholder value as well as our communities.
Our approach to managing  risk is grounded in our
Enterprise Risk Management  program and integrates
social and environmental considerations into our due
diligence and business processes. 

 This helps ensure we have an appropriate

measurement, monitoring, assessment, controlling and
reporting of -related risk.

 risk management is having a strong
governance structure, which integrates oversight across
the enterprise.
  is responsible
for overseeing all aspects of the Company, including
 to ensure we are effectively identifying, monitoring
and mitigating social, cultural and environmental risks.
These efforts are incorporated across the enterprise and
into strategic planning.
 

Board, the  sets the tone for  at the Company. It
helps oversee management’s implementation of the 
program and ensures  risks are appropriately controlled.
  Berkshire maintains an extensive
management committee structure, including the 
committee, which is responsible for overseeing all aspects
of  within the organization. The committee monitors
performance and ensures appropriate strategies are in
place to identify and mitigate  risk.
 
 The executive management
team is responsible for promoting and communicating
the Company’s  commitment. The  is the head of
Berkshire’s  activities and is responsible for facilitating
the development, implementation and execution of the
overall  program.
  The business unit heads are ultimately
responsible for the line-of-business functions and for the

They are accountable for implementing strategies approved
by the  and  in a manner that complies with
policies, rules, regulations and supervisory requirements.
They are also responsible for the implementation,
integrity and maintenance of management information
systems used to monitor and report on  risks and
controls within their areas of responsibilities.
  All employees are accountable and
responsible for adhering to the Company’s 
policies and completing annual training. Credit and
Lending teams, along with business line employees,
also receive training on social and environmental

of responsibilities. Employees are also responsible
for helping to identify opportunities in their areas of
responsibility and advising their managers of potential
ways to enhance responsible and sustainable business
performance and mitigate  risks.

Berkshire uses a variety of tools and information systems,
and maintains a framework to identify, assess and manage
existing and emerging  risks in its operations and

reporting as part of the  framework and guidance
from regulatory agencies, nongovernmental organizations
and broader stakeholder engagement. The primary tool
for identifying these risks is through a base-tier and mid-tier
risk assessment process, which assesses  risks and their

investments and broader communities.
Business units are ultimately responsible for mitigating 

identifying potential base-tier risks within their respective
functions. These risks are documented in the Company’s
risk register. In addition, the Company completes an
annual mid-tier  risk assessment to evaluate the bank’s
operations, lending, and investment activities for potential
exposure to  risks. This assessment includes a detailed
review of risks and potential impacts across the Company’s

assessments are completed when potential  risks rise
to a level requiring proactive monitoring and possible
interventions. The results of all these risk assessments inform
Berkshire’s forward  risk management strategies to
ensure it’s controlling and mitigating the risk.

After identifying and determining the appropriate response
to  risks, Berkshire continuously monitors these risks,
impacts on its business activities and the effectiveness of its
risk mitigation strategies. This includes monitoring of the
external environment and government regulation, proactive
stakeholder engagement, ongoing  risk assessments
and review of monthly reporting to identify shifts in the
Company’s exposure to sectors at highest potential to be
impacted by  matters.

Berkshire maintains comprehensive  due diligence
methodologies to ensure it mitigates potential  risks.
These due diligence processes and standards apply across

businesses encompassing all Company and subsidiary
operations. These due diligence processes are based on
Company operating standards, sound risk management
practices and third-party guidance, including the Equator
Principles. Standard due diligence is conducted for all
lending, investment and depository relationships, while
enhanced due diligence is triggered based on the

and severity of potential environmental or social impacts.
In some cases, these are also escalated to the 
Percent of employees completing
Corporate Responsibility
Policy Training
99%
Activities granted exceptions
from Responsible and Sustainable
Business Policy
0
RESPONSIBLE BANKING
15Berkshire Hills Bancorp, Inc. — BHLB | berkshirebank.com » 2022 esg Report
Standard due diligence is conducted for all lending,

social and environmental risks are well understood and

reversible. All due diligence begins with frontline staff and
involves credit, risk, lending, investment and consumer

or transaction. The process generally includes, but is not
limited to, research, ensuring compliance with all federal,
state and local laws and permits, assessment of
creditworthiness and screening against all applicable
company policies. If, during this process, staff determine
the customer, business, borrower or business activity poses

Sustainable Business sections of Berkshire’s credit, loan,

pose heightened risk for severe environmental or social
impacts, enhanced due diligence is triggered.
Enhanced due diligence includes a deeper analysis of
topics, risks, documentation and assessments related to
the transaction or relationship to ensure the company
understands the full scope of potential impacts across risk
categories and to its stakeholders. In some cases, a formal
social and/environmental impact assessment is conducted

commitment, policies and procedures in place to minimize,
manage, mitigate and monitor impacts. In such cases where
a borrower can demonstrate appropriate mitigating
measures, a transaction may be allowed to move forward
but is treated as an exception-based loan and may be

Due to the severity of  risks and potential impacts to
stakeholders, Berkshire maintains an exclusionary business
list which includes, but is not limited to, private prisons and

has no direct exposure to oil and gas extractors/producers,
coal mining, arctic drilling, palm oil and many other socially
or environmentally sensitive areas, and generally will not do
business with industries exposed to substantial social and
environmental risks.

The Company protects itself from potential  risks and
associated impacts through a system of formal controls.
Collectively these controls are designed to protect the

operational impacts and enhance its positioning as a leading

  An extensive collection of
Board and Management committees is responsible for
overseeing operations and for ensuring that  risks

in accordance with Company standards.
  Company policies are designed to manage
 risks in a consistent manner and align with the

and oversight standards to effectively manage  risk

procedures across businesses and functions. These
policies, which apply to all Company operations and

 
provides guidance to employees on the Company’s
environmental, social and governance  activities,
business practices, codes and commitments.
  provides guidance on
environmental due diligence requirements prior to
entering into, and throughout the life of, any real estate
transaction secured by commercial properties or
multifamily properties. The purpose of environmental
due diligence is to assess the nature and extent
of environmental conditions of the collateral and
any associated risk posed by those environmental
conditions in order to make sound business decisions
and underwriting.
  contains guidelines to be used by
management in the execution of the overall corporate
investment securities portfolio. This includes a list
of prohibited securities that addresses social and
environmental risks such as Oil and Gas Extraction,
Production, and Pipeline Construction, Petroleum
and Coal Products Manufacturing, Mining, Firearms,
Ammunition and Weapons Manufacturing, Private
Prisons or Detention Centers, Companies with known
environmental violations by a local, state or federal
agency or government that caused irreparable harm
to biodiversity, critical habitats, the environment or are
otherwise inconsistent with the Company’s Responsible
& Sustainable Business Policy.
  Outlines the types of deposit products
offered and governance of common account-related
activity to manage and mitigate risks associated
with deposit accounts. This includes processes for
addressing and completing further due diligence

heightened social, environmental and reputational risks
due to their involvement in highly sensitive activities
such as certain nongovernmental entities, Oil & Gas
Extraction, Mining, Support Activities for Mining and
Oil Pipeline Construction, Chemical, Petroleum and
Coal Products Manufacturers, Firearms & Ammunition
Manufactures and Retailers, and Private Prisons and
Detention Centers.
 
that emphasis is placed on sound client selection,
overall loan quality, attentive credit administration,
regulation compliance, and proactive risk recognition,
while continuing to pursue new business. The
responsible and sustainable business section of this

 risks, such as oil and gas and mining sectors,
receive appropriate due diligence and are treated as

rigorous  standards. As a result, there is no exposure
to oil and gas extraction, producers, coal mining and
other environmentally sensitive industries. The policy
also includes a list of prohibited businesses, including,

The policy helps ensure respect for biodiversity,

are consistent with the Company’s Responsible or
Sustainable Business Policy commitments.
  Berkshire maintains a formal
due diligence framework for its business activities,
which applies to all operations, and includes a standard
and enhanced layer of due diligence with triggers and
escalation processes. This process is further detailed in
the “ Due Diligence” section of this report.
  Due to the severity of  impacts
associated with certain industries, Berkshire prohibits/
excludes select industries exposed to substantial  risk.
Exclusions are included in applicable Company policies.
RESPONSIBLE BANKING
16Berkshire Hills Bancorp, Inc. — BHLB | berkshirebank.com » 2022 esg Report
The  Committee periodically reviews these lists of
industries and updates as appropriate.
  The Company regularly
engages with its stakeholders to understand current
and emerging trends that may affect its business and
inform response and mitigation tactics to  risks.
  Berkshire provides employee
training and ongoing communications to ensure
employees learn about relevant  matters that could
impact the Company and its management of  risks.
These materials are delivered across several platforms
to ensure employees receive information that is concise,
digestible, understandable and relevant to their roles
and responsibilities. These include both formal and
informal training on applicable Company policies along
with  risk briefs as emerging risks materialize.
The goal of these efforts is to help employees understand
how  risk events could impact the Company and its
stakeholders as well as educate them on the steps the
Company is taking to mitigate those risks.
Our comprehensive approach to identifying, preventing and
mitigating  risks prioritizes and protects our stakeholders
and communities, while supporting responsible risk-based
decision-making and driving competitive returns.
RESPONSIBLE ASSET MANAGEMENT
Berkshire has a duty to act in the best long-term interests of
our stakeholders. We believe that environmental, social and
governance  matters can affect the performance of our
corporate investment portfolios as well as the portfolios of
our clients. As such, Berkshire analyzes  factors through
the investment process and engages on  matters with
issuers, as appropriate. Ultimately our goal is to identify

communities and our long-term sustainability.
Our Wealth Management division has developed Socially
Responsible Investing  Portfolios for clients, which
are constructed to maximize impact through an extensive
due diligence process that leverages multiple  data
aggregators, alongside proprietary research and company
engagement. In addition, Berkshire built the portfolios to
include mission-aligned companies with solid track records
across  metrics and strong fundamental attributes that
positively contribute to the long-term sustainability of
communities. The  
so while they are a small component of the division’s existing
overall assets under management/administration, they grew

While Berkshire is not currently a formal signatory of the
Principles for Responsible Investment, it has adopted
and incorporated those principles into its policies and
operations. Berkshire’s corporate investment policy
integrates  considerations and contains guidelines to
be used by management in the execution of the overall
corporate investment securities portfolio. This includes
a list of prohibited securities such as Oil & Gas Extraction,
Production, Pipeline Construction, Petroleum and Coal
Products Manufacturing, Mining, Firearms, Ammunition
and Weapons Manufacturing, Private Prisons or Detention
Centers, along with companies with known environmental
violations by a local, state or federal agency or government
that caused irreparable harm to biodiversity, critical habitats,
the environment or are otherwise inconsistent with the
Company’s Responsible & Sustainable Business Policy.
RESPONSIBLE BANKING
17Berkshire Hills Bancorp, Inc. — BHLB | berkshirebank.com » 2022 esg Report
One of the responsibilities of the Board is to identify, evaluate
and select director nominees. We ensure the composition
of our Board aligns with our long-term strategic direction.
The Board periodically assesses the size of the Board and
reviews the composition of its membership to ensure that
the appropriate knowledge, skills and experience are


Reserve Bank of Boston President and CEO Eric S. Rosengren



Board’s expertise in support of  and strengthening
its governance oversight. The average tenure and age of

impact of Board policies for maximum tenure and age.



Corporate Governance/Nominating; Corporate
Responsibility and Culture; Risk Management, Capital and
Compliance; Audit; and the Compensation Committee.
All committees are currently independent.

In order to drive forward our vision to be a leading socially
responsible community bank, our Board of Directors and
executive management understand the critical importance
of  matters to our future success and the success of our
stakeholders. That’s why we were one of the r s t banks
in the countr y to establish a dedicated committee of
our Board of Directors to oversee ESG matters
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 Responsibility/
, Environmental Sustainability, Climate Change, Diversity,
Equity and Inclusion and Culture programs. The committee
is appointed by the Board to approve policies and oversee
management’s implementation of programs.
In addition to the committee, the full Board periodically
receives presentations on Berkshire’s  program, the
 Community Comeback and other sustainability
matters. The Board receives reports on climate risk as well
as activities underway to help mitigate those risks and
capitalize on the transition to a lower-carbon economy.
It reviews the Company’s annual climate risk assessment,
evaluates those risks and opportunities and uses the results
to inform its strategic planning process. The Board’s
oversight further enhances controls over , alongside
the Company’s management-level  Committee, which
includes members of the executive management team
and monitors and approves strategies designed to identify,
measure, control and enhance the Company’s /
Corporate Responsibility performance.

Our philosophy is to provide an executive compensation
program that rewards creation of long-term value for our
shareholders, promotes sound risk management and aligns
with our vision of being a leading socially responsible
community bank.


 Attract and retain highly talented executives
committed to our success
 Pay for performance
 Align executive interests with those of our shareholders
 Manage risk through oversight and compensation
design features and practices

 
performance-based
BOARD OVERVIEW
Our corporate governance practices guide us as we look
to deliver on our vision to be a high-performing and leading
socially responsible community bank in New England and
beyond. The Company’s Board of Directors is responsible
for promoting and acting in the best interests of all
shareholders of the Company. The Board is the ultimate
decision-making body, except with respect to those matters
reserved for shareholders. The business and affairs of the

of the Board. The Board’s responsibilities include nominating
directors, selecting the , succession planning, completing
a periodic self-assessment and evaluating strategy and
performance of the Company and . Additional
information on board meetings, attendance and tenure

The Company maintains a formal shareholder engagement
process to ensure the perspectives and views of its owners
are regularly reviewed by the Board and senior management.
This includes engagement on  matters such as diversity,
climate change, sustainability and other social topics.



brings a diverse background of skills, tenure, age and
experiences that are necessary to oversee Berkshire’s
Exciting Strategic Transformation , exercise

All members of the Board are up for annual election.


) are women


) are ethnic minorities — resulting in two thirds
gender and ethnic diversity of the Board.
 
Board Committees Audit Compensation
Corporate
Governance
and Nominating
Corporate
Responsibility
and Culture
Risk Management,
Capital and
Compliance


 


&
18Berkshire Hills Bancorp, Inc. — BHLB | berkshirebank.com » 2022 esg Report
 A meaningful portion of pay is equity-based to align our
executives with shareholder interests
 

Berkshire’s short-term incentive  program includes a
 component in the calculation of the total 
plan funding. This measurement is based on a qualitative
assessment of Berkshire’s  rankings, its social/community
impacts, and other results of its  initiatives, which include
sustainability items. The introduction of this  component

in developing and implementing its  and sustainability


value for shareholders, manage risk and support our vision.
The sustainability items are further incentivized through the
overall qualitative operation of our compensation program.
This is fundamentally addressed through the operation of our
 strategic plan, which sets out top quartile  rankings
 targets
(including sustainability targets).
Executive base salaries, and the individual payouts under our
short- and long-term incentive plans, include an assessment
of individual performance, which is evaluated qualitatively for

achievement was included in the evaluation of  and 

 Community Comeback


 in lending for low-

and overall greenhouse gas  emission reduction.
Additional information on our executive compensation

Compensation Discussion and Analysis.
RISK MANAGEMENT
AND COMPLIANCE
Our Enterprise Risk Management 
direction of our Senior Executive Vice President, Chief Risk

independent oversight and challenge of risk-taking activities

governance, organization, culture, framework, risk appetite
and development of a risk management platform to ensure
appropriate monitoring and controls are in place. The 

information into a holistic picture of the corporation’s risk

reports sources and amounts of risk to executive leadership,
management committees and the Board of Directors.
Berkshire maintains a comprehensive framework of
management committees to provide oversight to all areas of
the bank. Our Policy Committee, which reports directly to the
Board’s Risk Management, Capital & Compliance Committee,

policies to ensure they align with governance best practices,
our values and the complexity of our operations. All our
policies apply to all Company operations.

The Compliance function, under the direction of our

ensure the Company complies with the letter and the spirit
of all federal and state laws and regulations that are applicable
to its operations, including those involving civil rights, fair
lending, community reinvestment and anti-money
laundering. Adherence to compliance requirements limits

damage to the Company’s reputation. The Company
operates under the premise that keeping customers
informed and treating them fairly is good business. Our
Compliance Program includes oversight and reporting,
written compliance policies and procedures, monitoring,
corrective action, training, complaint management, change
management and independent audit and risk assessments.
Employees are required to complete a suite of training
courses based on their functional responsibilities.

Our Internal Audit Department serves as a third line of
defense evaluating the design and effectiveness of our risk
framework and its results. The department helps provide


defense. Results are reported to the executive leadership
and the Board of Directors according to our Internal Audit
Policy. Audits are completed based on a risk-based
assessment and audit plan. Culture and ethical standards
are assessed in various audits to help ensure Berkshire is
holding itself to the highest ethical standards and has



continuing education annually, including ethics and
governance training. The 

year, performed by the Audit Committee. The Audit
Committee of the Board also oversees our Anonymous
Reporting/ Whistleblower line and policy.

 Anonymous Reporting
Line/Whistleblower
Policy
 Bank Secrecy Act/
Anti-Money Laundering
Policy
 Bank Security Program
 Code of Business
Conduct
 Compliance Risk
Management Policy
 Community
Reinvestment
Act Policy
 Corporate Governance
Policy
 Crisis Management Plan
 Deposit Policy
 Enterprise Risk
Management Program
 Fraud Risk
Management Program
 Hedging Policy
 Information Security
Program
 Loan Policy
 Marketing and
Advertising Policy
 Public and Media
Relations Policy
 Privacy Policy
 Responsible and
Sustainable Business
Policy
 Reputation Risk
Management Program
 Third-Party Risk
Management Policy
 Capital Planning Policy
 Investment Policy
 Interest Rate Risk Policy
 Funds Management &
Liquidity Policy
 Data Governance
Program
 Model Risk
Management Program
LEADERSHIP & GOVERNANCE
19Berkshire Hills Bancorp, Inc. — BHLB | berkshirebank.com » 2022 esg Report
Berkshire’s people are the driving force behind its progress on Berkshire’s Exciting
Strategic Transformation  plan and vision of being a high performing, leading
socially responsible community bank in New England and beyond. The Company’s
approach to human capital management is grounded in its corporate values and

 Strong oversight and risk
management practices
 Recruitment
 
 Training, development,
engagement and retention
 Health and wellness

The Board of Directors has ultimate responsibility for the strategy of the Company.
The Compensation Committee of the Board of Directors oversees executive
compensation matters and the Corporate Responsibility & Culture committee
oversees company culture as well as diversity, equity and inclusion performance.



capital related risks, such as the labor market shortage, rising labor costs and
employee retention and designs strategies to mitigate those risks. Strong human
capital management is viewed as integral to the Company’s transformation and


Berkshire operates in a highly competitive labor market with strong competition for
top talent. The Company relies on and continues to recruit employees with the right
mix of skills, expertise and experiences based on current openings and forecasted
needs. The Company leverages several strategies to support its talent pipeline and
talent acquisition activities, including formal advertising, postings on targeted career

of experienced external recruiters for key management and specialized positions.
Berkshire also has a small internal team of talent recruitment professionals.
Berkshire maintains a hybrid work model to expand its access to top talent and

effective in meeting the demand for talent, demonstrated by the Company’s strong
track record of attracting high-caliber talent across retail, commercial, wealth
management, business banking, technology and operational areas. In addition, as
market disruptions from mergers remain and recessionary pressures impact other
industries, Berkshire will continue to leverage its differentiated brand and unique
market positioning to hire community-focused bankers from its competitors and
attract high-performing operational talent from outside the industry.


labor costs for all businesses. Berkshire is not immune to these economic
pressures. The Company continually evaluates its compensation strategies and

 
performance and retain top talent at all levels of the Company. Against this
backdrop, and in keeping with the Company’s socially responsible mission,


opportunities for employees to earn higher compensation and bonuses for strong

Berkshire provides comprehensive medical coverage, paid vacation, personal

employer match, long-term disability insurance, and group term life insurance.
In addition, Berkshire offers a day care reimbursement program, a dependent care




offers volunteer-time off, a matching-gift program, an employee assistance
program, regular performance reviews, professional development and the
You 


Training and development programs provide employees with the knowledge
and skills needed to succeed and have upward career mobility. They are critical

having an engaged workforce. Ultimately an engaged workforce drives high levels
of retention, which reduces human capital risks and expenses, and advances
Berkshire’s progress and performance.
1,310
Employees
67%
Women
54%
Women in
manager roles
42%
Women in
executive
manager roles
~7 year
Average
tenure
97%
Employees
benets
eligible
~44
Average
age
At a Glance
HUMAN


20Berkshire Hills Bancorp, Inc. — BHLB | berkshirebank.com » 2022 esg Report
The Company provides several learning and training programs consistent with

have regular performance assessments to identify strengths and areas for
further growth. Berkshire continues to reskill and upskill employees from across
the Company, helping them advance along career paths by taking on new
responsibilities and roles. The Company offers a mentoring program for high

provide managers and leaders with the knowledge and skills they need to drive
change, effectively manage their teams and grow. These programs are offered
across a variety of mediums and channels to improve accessibility. Berkshire
is committed to providing pathways for its employees to grow and maintains

workforce was promoted in the prior year.
Berkshire encourages its employees to participate in appropriate educational
opportunities to expand their professional experience, aid them in their current

Company. As such, the Company offers educational assistance along with access

for Financial Training  programs. All courses must be approved by the
employee’s supervisor, division head, and the Human Resources Department prior


Regular full-time employees may request to enroll in one  course or one college
course per semester. After one year, full-time employees are eligible for two 
courses or two college courses per semester that are business or banking related,
directly related to the employee’s present position, or are required for completion

Part-time employees are eligible to take one  course or one college course per
semester directly related to their present position, or that’s required for completion


to the institution at the time of enrollment. In addition, employees may request
reimbursement for textbooks and course materials purchased for each Company-

Berkshire continues to monitor the progress of its efforts to evaluate the
effectiveness of programs and strategies on engagement. A comprehensive
annual employee engagement and pulse survey is conducted to identify strengths
and opportunity areas within the organization. Overall, employees felt there was
a strong spirit of teamwork, that Berkshire genuinely cares for its communities
and they have strong relationships with their direct managers. Action plans are

expectations. Beyond a formal engagement survey, Berkshire provides regular
opportunities for managers and employees to ask questions, raise concerns and
make suggestions for ways to build a better and stronger company. This includes
regular quarterly employee town halls and leadership forums, an employee
suggestion program called Better, Faster, Stronger and regional gatherings
that provide employees with direct access to Company leaders.
While Berkshire has been impacted by higher-than-average turnover due to labor
market disruptions, it is seeing positive momentum because of the actions it has

 Launched companywide reward
and recognition program
 
 Introduced wellness day
 Enhanced line-of-business
incentive plans
 Established career paths for

 Increased starting wage
 Offered mentoring program
 Implemented robust employee
communications program
Collectively these efforts have led to 
 and being named a Forbes America’s Best
Midsize Employers.
HEALTH AND WELLNESS
As the world began to emerge from the  pandemic, Berkshire continued
to proactively manage impacts to protect the health and safety of its employees,
customers and communities. During the height of the pandemic, the Company
provided protective equipment to frontline employees, including masks
and gloves, and offered all additional paid sick time, paid vaccine time, paid

schedules for remote employees and premium pay for onsite employees,
and it maintained full pay for employees with schedules that were reduced as
a result of the pandemic.


wellness employee resource group. The Company, through its insurance provider,

calendar of various wellness-related activities. Since physical and mental health go

resources and webinars, along with its You  Fund to assist employees

employee assistance program that includes counseling services and resources
for those experiencing mental health
challenges. To further support the needs
of its workforce, Berkshire introduced
a wellness day to provide a day off for
employees to disconnect, recharge
and take care of themselves in whatever
way works best for them.

Berkshire continues to evolve and enhance its human capital management
strategies to drive organizational growth in support of  while combating risks,
such as the labor market shortage and rising labor costs. The Company expects
to maintain its hybrid workplace over the long term and invest in technology.
While technology will play a bigger role in the future of Berkshire, helping to

its ability to deliver value to its customers, shareholders and communities.

and socially responsible vision will continue to be a differentiator in the market.
You FIRST Employee Assistance Fund helps
colleagues impacted by hardships
HUMAN CAPITAL MANAGEMENT
21Berkshire Hills Bancorp, Inc. — BHLB | berkshirebank.com » 2022 esg Report
DIVERSITY, EQUITY AND INCLUSION
Creating a diverse, equitable and inclusive  workplace is an essential
enabler to continuing to drive forward progress on Berkshire’s Exciting Strategic
Transformation , its  Community Comeback and vision. Ultimately

it operates, that its employees feel valued and can reach their full potential,

economic growth of underrepresented populations and communities. The
Company’s advances those goals through an integrated approach grounded

 Strong oversight and governance practices
 Recruitment and talent management
 Education and training
 Workplace programming through employee resource groups (s)
 Financial solutions that drive economic equity
 
and entrepreneurship
 Supplier diversity

The Company has a strong foundation of governance practices to ensure that
diversity, equity and inclusion are embedded into Berkshire’s business activities.
This includes the Corporate Responsibility & Culture Committee of the Board
of Directors, which has ultimate oversight responsibility. Berkshire’s Diversity,
Equity and Inclusion Committee, which reports to the Board committee, provides
additional management-level oversight to the Company’s programming and
 
Company’s DEI programming.

Berkshire continues to improve representation within its workplace through
recruitment initiatives while enhancing its internal talent pipeline to ensure





communities in which it operates. It works to develop and implement strategies
aimed at increasing representation at each level of the Company. For example,
Berkshire provides mentoring programs, including one aimed at supporting
women sponsored by our Power of Women Employee Resource Group. In
addition, the Company regularly reviews the gender and ethnic diversity of its
workforce at the employee, manager and executive management level. Based
on those reviews, the Company develops programs to improve representation
across each level of the Company. As a result, Berkshire improved representation
across most key workforce diversity measures compared to the prior year.

Berkshire Bank is an equal-opportunity employer and always has pursued a policy
of equal employment for all of its employees and applicants for employment,
without regard to genetic information, race, color, ancestry, citizenship status,
religion, sex (including pregnancy), sexual orientation, marital status, familial status,
gender identity and expression, national origin, age, physical or mental disability,
status as a disabled or Vietnam-era veteran of the United States Armed Forces, being
a member of the Reserves or National Guard, or status in any group protected
by federal, state or local laws. The Company strives to further its commitment to
equal employment opportunity by recruiting, hiring, compensating, training and

inclusion in one of the categories delineated above.
Annually, the Company completes a review of pay and performance measures to
ensure that all employees, regardless of gender and ethnicity, in comparable roles
are compensated equitably. As a result of Berkshire’s intentional and impactful


 Understand Berkshire’s Be  Values
 Feel their manager is accessible
 Feel their manager respects them
 Spirit of cooperation and teamwork
 

Berkshire unveiled a new rewards and recognition
program to better recognize and incentivize employees
who go above and beyond through both peer-to-peer
and manager recognitions.
HUMAN CAPITAL MANAGEMENT
22Berkshire Hills Bancorp, Inc. — BHLB | berkshirebank.com » 2022 esg Report
efforts to date, Berkshire was listed in the Bloomberg Gender Equality Index and
Human Rights Campaign’s Corporate Equality Index.

In addition, Berkshire offers seven Employee Resource Groups (s), each
playing an integral role for employees and the culture of the company. Every
Employee Resource Group provides a safe space for dialogue, education and
collective action on topics relevant to their members and the Company. Through
the s, employees’ concerns and ideas to strengthen Berkshire’s culture are
elevated to members of management and the Diversity, Equity and Inclusion
Committee for action, empowering employees to collectively be engines of
positive change within the workplace. In addition, our ERGs help the Company
facilitate important cultural shifts, update policies, host important cultural

while creating a more inclusive workplace.

Berkshire provides a full suite of diversity, equity and inclusion trainings. The
trainings help build understanding and provide employees with knowledge,
skills and tactics they can put into practice. All new employees complete training
at the time of hire and current employees complete annual -related trainings.
The Company intends to roll out enhancements to its training program, which
will include required annual and elective courses for all employees and hiring

hiring and retention strategies going forward.

A diverse base of third-party partners is important to achieving our operational
goals, supply chain resilience and vision. We look to have a third-party base that

inclusion and utilization of minority-owned, women-owned and traditionally
underrepresented third parties in our procurement of products and services.
We encourage employees to seek out potential third parties and facilitate
connections with underrepresented suppliers. Berkshire continues to integrate

dramatically increased its spend with diverse suppliers, due to enhanced
partnerships with the Greater New England Minority Supplier Development
Council and the Boston Chamber of Commerce’s Pacesetters program.

 
 
 
 
 
 



Percent of Women in Workforce 67%
Percent of Ethnic Minorities in Workforce 16%
Percent of Women on the Board 33%
Percent of Ethnic Minorities on the Board 33%
Percent of Women in Manager Roles  54%
Percent of Ethnic Minorities in Manager Roles  11%
Percent of Women in Executive Management 42%
Percent of Ethnic Minorities in Executive Management 17%
Percent Disabled in Workforce 3%

HUMAN CAPITAL MANAGEMENT
23Berkshire Hills Bancorp, Inc. — BHLB | berkshirebank.com » 2022 esg Report
CORPORATE GIVING AND BERKSHIRE BANK FOUNDATION


sustainable communities. Through our philanthropy and by
harnessing the collective skills and resources of our employees,
we’re helping turn possibilities into realities for individuals across
 in our
 in philanthropic grants
through Berkshire Bank Foundation. The foundation aims to

populations that have been disproportionately and unfairly
underserved. The foundation focuses on three areas to achieve
its mission by supporting programs that aim to provide everyone

 providing support to entrepreneurship and
small business growth through access to education, capital
and technical assistance with an emphasis on greater access to
minority, women and -owned businesses
 supporting programs that create a path
to upward economic mobility and overall well-being with an
emphasis on the “underbanked” and “unbanked” populations.
 facilitating access to quality, affordable housing


time homeownership for people of color, women and other
marginalized communities.
Through our  Community Comeback, we expect to increase
 by the end


and adults looking to pursue higher education.

We understand that being a committed community partner is about
more than writing a check. It’s about taking action and harnessing
all that a business has to offer to lift up our communities. We provide
our employees with paid time off to be part of the , our
nationally acclaimed Employee Volunteer Program, and offer a
Matching Gifts program to help amplify the philanthropic efforts
of all our Berkshire bankers. From individual- and group-based
volunteer engagements to pro bono and Board service, the 
empowers employees to be change agents to address essential
needs and help organizations run more effectively. Last year

in the program, nearly three times the national average. They


 in donated volunteer time through
its 
LIFTING UP OUR
COMMUNITIES

$3.5 MILLION

$2.8 MILLION


71%


94%
23,063

518

Berkshire’s signature day of community action, Xtraordinary




Berkshire and EforAll are working together to accelerate
economic and social impact by harnessing the power of
inclusive entrepreneurship. Through accelerator programs,
pitch contests and virtual workshops, we’re helping close the
opportunity gap and create employment.


24Berkshire Hills Bancorp, Inc. — BHLB | berkshirebank.com » 2022 esg Report

Climate change manifesting in the form of both physical and transition risks could
adversely, either directly or indirectly, affect Berkshire’s operations, businesses,
customers, communities and stakeholders. As the transition to a low-carbon
economy accelerates, new policy emerges and market dynamics shift, Berkshire
expects that its efforts to manage its environmental footprint, mitigate the
risks associated with climate change and support the transition will allow it to
strengthen its positioning as a high performing, leading socially responsible
community bank.
The Taskforce on Climate-Related Financial Disclosure  recommends
companies communicate practices around the governance of environmental
matters, strategy, risk management, and metrics and targets used to assess risks,
opportunities and Company performance. Berkshire’s Climate Change disclosure
contained below is aligned with  recommendations. The Company continues

scope and complexity of its operations.

Berkshire is actively managing climate-related risks and opportunities at the board,
management and employee levels. The Company’s Board of Directors Corporate
Responsibility & Culture Committee provides oversight on sustainability and
climate change. Management and the board evaluate climate-related risks and
opportunities and incorporate the results of risk assessments and discussions
into strategic planning, product development, programming and relevant risk-
mitigating measures. All business risks are also integrated into our Enterprise Risk
Management program and discussed by other applicable Board Committees,
including the Risk Management, Capital and Compliance Committee. Both
Committees report to the full board.
Beyond board level oversight of climate matters, Berkshire maintains an 
committee comprising senior executives throughout the Company, including the
, , ,
Corporate Responsibility. The committee reviews climate risks and opportunities,
and ensures robust management oversight. Collectively, management is
responsible for the line-of-business functions and integration of sustainability
activities within their respective departments, including implementing programs,
policies and management systems. Our Responsible and Sustainable Business
Policy guides our codes, principles and commitments, including our Environmental
Sustainability Principles, which govern our operations.

Berkshire’s Enterprise Risk Management  organization and Corporate

measurement, monitoring, assessment, controlling and reporting of climate-
related risk. In order to help effectively meet that mandate, Berkshire continues
to work to integrate climate risk into all elements of its  program. Each of
Berkshire’s business areas consider climate-related risks and opportunities within

potential for climate risk across our lines of business on an ongoing basis. We
understand that some climate-related risks may manifest over a long time period,
while other events or developments could drive a more immediate impact.
In response, Berkshire continues to enhance its capabilities to assess, monitor
and mitigate potential short- and long-term risks posed by climate change in a


Berkshire uses a variety of tools, information systems, and maintains a framework
to identify, assess and manage existing and emerging climate risks across the
organization. This includes formal analysis and reporting as part of the 
framework and guidance from regulatory agencies and governmental agencies.
The primary tool for identifying these risks is through a base-tier and mid-tier risk

Berkshire uses publicly available climate scenarios and weather information to
detect potential severe weather events which could impact its operations within its
footprint over short, medium and long-term horizons. For transition risk, Berkshire
uses publicly available climate scenarios and guidance to identify industries at the
highest risk to be impacted by the transition to a lower carbon economy as a result
of increasing regulation, shifting consumer preferences and policy.
Business lines are responsible for identifying potential base-tier risks within their
respective functions. These risks are documented in the Company risk register.
In addition, the Company completes a mid-tier climate change risk assessment to
evaluate the bank’s operations and lending activities for potential exposure to

companies, sectors and overall portfolio concentrations. Risks are assigned a risk
rating using the Company’s  framework. The results of the risk assessment
guide Berkshire’s forward climate management and environmental sustainability
strategies to ensure it is actively managing the risks and opportunities.
CLIMATE CHANGE AND NATURAL RESOURCE MANAGEMENT


25Berkshire Hills Bancorp, Inc. — BHLB | berkshirebank.com » 2022 esg Report

After identifying and determining the appropriate response to risks, Berkshire
continuously monitors these risks and its business activities over various scenarios
as well as the effectiveness of its risk mitigation strategies. This includes monitoring
of the external environment and government regulation, proactive stakeholder
engagement, ongoing climate risk assessments and review of the monthly
reporting to identify shifts in the Company’s exposure to sectors at highest
potential to be impacted by transition or physical risks. Berkshire expects to
continue to advance its capabilities to qualitatively and quantitatively evaluate
and monitor potential impacts.

The Company protects itself from potential climate risk events and associated
impacts through a system of formal controls. Collectively these controls are

and environmental impacts and enhance its positioning as a leading socially

  An extensive collection of Board and Management
committees is responsible for overseeing operations and for ensuring

accordance with Company standards.
  Company policies are designed to manage climate risks in a consistent

control and oversight standards to effectively manage climate risk within the

functions. These policies, which apply to all Company operations, include but
are not limited to the Responsible & Sustainable Business Policy, Environmental
Loan Policy, Investment Policy, Deposit Policy and Loan Policy-General.
  Berkshire maintains a formal due diligence
framework for its business activities, which applies to all operations, and
includes a standard and enhanced layer of due diligence. These processes
are detailed in the  Risk Management section of this report.
  Due to the severity of climate impacts associated with
certain industries, Berkshire prohibits/excludes select industries exposed to
substantial climate risk. These exclusions are included in applicable Company
policies, including, but not limited to, the Loan Policy General and Investment
Policy. The  Committee periodically reviews these lists of industries and
updates as appropriate. As a result, Berkshire has no direct exposure to fossil
fuel producers/extractors and coal mining, and generally does not do business

  For residential and commercial properties secured

to carry appropriate insurance coverages. These mitigating measures help

properties within Berkshire’s portfolios.


opportunities arising from a transition to a low-carbon economy. Utilizing our
climate risk management framework, the results of our climate change risk
assessment, as well as widely used climate scenarios, Berkshire evaluates the
Bank’s operations and lending activities for potential exposure to transition and
physical risks resulting from climate change. These transition and physical risks


programs. The results of the risk assessment are shared with business line partners
to discuss mitigating activities, as well as appropriate management and board
committees in alignment with our governance framework.
As a bank, it’s important for us to understand and assess how climate risks could


commercial real estate portfolios  as well as our commercial and industrial
 portfolio. To assess the vulnerability of our residential and commercial real
estate portfolios, we evaluated how physical risks, such as direct damage from
hazards, could impact property values, repayment and residual values. Ultimately,

the portfolio. Our  portfolio is most vulnerable to transition risks. To assess
transition risk, we looked at Berkshire’s  portfolio at the industry level using
 and then assessed
each sector’s vulnerability based on how these industries operate today.
We focused on industries most vulnerable to transition risk.

Our assessment processes primarily look at the two main sets of climate risks


  is the risk that occurs with the movement toward lower carbon,
greener energy systems and economies as the world reduces its reliance
on fossil fuels and other carbon-intensive industries. Transition risks over
short-, medium- and long-term horizons can include changes in consumer
preferences, additional regulatory requirements or policy such as taxes, and
use of new technologies. Such developments could increase Berkshire’s, its
customers’ and third parties’ operating costs, reduce demand for services
from select customer segments and impact current strategies. Reputation and
customer relationships could be damaged as a result of Berkshire’s practices
related to climate change mitigation as well as through its or its customers’

climate related risks. Over the long term, transition risks could also manifest
in potential credit impacts affecting borrowers’ ability to repay obligations,
increasing operating costs, creating stranded assets, uncertainty of residual
values and potential loan losses.
Over the short term, the likelihood and impacts of transition risks are expected
to be muted, but as we look out over medium- and long-term horizons,
existing legislation and further shifts in the economy will begin to elevate
risk levels leading to an increased probability for impacts. Approximately
 portfolio is exposed to the highest level of transition risk
over the long term. These transition risks are managed through ongoing
monitoring, existing industry exclusions, due diligence processes, policies,
insurance requirements, business continuity planning, target setting and
product development.
ENVIRONMENTAL SUSTAINABILITY
26Berkshire Hills Bancorp, Inc. — BHLB | berkshirebank.com » 2022 esg Report
  is the direct effect of more frequent extreme weather-related
events or changing weather patterns on a physical asset or property such as
homes or commercial real estate. The physical risks of climate change over
short-, medium- and long-term horizons include weather-related events, such

extreme heat, rising sea levels and more severe droughts. Such events could
disrupt Berkshire’s operations and impact customers or third parties on which
Berkshire relies, including through direct damage to physical assets and
indirect impacts from supply chain disruption and market volatility. This could
impact borrowers’ ability to repay obligations, devalue physical assets resulting
in uncertain residual values and affect third parties’ ability to deliver on service
expectations. In turn, this could lead to operational disruptions, loan losses
and an inability to fully recoup funds due to uncertain residual values over
long-term horizons.
Over the short and medium term, the likelihood and impacts of physical risks
are expected to be episodic and isolated, but as we look out over longer-term
horizons, changes in water levels around low-lying areas as a result of global
warming and/or more frequent weather-related events will begin to elevate


commercial real estate portfolio could be exposed to varying levels of

through ongoing monitoring, due diligence processes, policies, insurance
requirements, balance sheet management, business continuity planning,
target setting and product development.




across sectors to power the transition to a lower-carbon economy, Berkshire
 in low-
 Community Comeback. In addition, we believe
that Berkshire is equipped to build resilience in our communities and across our

 Improving our own operational performance by accelerating our 
reduction targets, reducing energy consumption, increasing our use of
renewable energy, reducing surplus real estate holdings and strengthening
the integration of climate change matters into additional business processes.
We’ve made steady progress in all these areas, increasing our use of renewable

 emissions, and selling surplus real estate. In addition to the environmental

our  positioning.
 Growing our business to harness the momentum of the low-carbon

development, socially responsible investing  portfolios and more,

such as our MassSave® Heat Loan.

, as it explores
additional innovative opportunities to collaborate with the public and private
sector to accelerate the transition. This included the issuance of a sustainability


while lowering its cost of capital.
 Helping our customers and partners become more climate resilient by sharing

Berkshire regularly assesses opportunities as part of its normal business
operations and strategic planning to ensure it’s appropriately sourcing, evaluating,
integrating and capitalizing on opportunities as market demand and government
policy shift and risk-mitigating strategies strengthen.

The Company is conscious of the impact of its own operations on the environment
and works diligently to measure, monitor and mitigate its direct and indirect
environmental impacts. To set the foundation for future progress, Berkshire
 inventory and limited operational


 emissions
within our inventory.




including solar and wind, and are well on track to achieve that goal through virtual
net metering, power purchase agreements and greening of the grid. As of year-



across its New England and New York markets.


by supply chain disruptions that affected its ability to source recycled as well as
 and  products. It expects its paper consumption to return to recycled 
and 
optimization effort to further reduce our environmental footprint and we





  
Commercial Real Estate $506 
Residential Mortgage $4.7 
ENVIRONMENTAL SUSTAINABILITY










 
Real Estate $218MM 15% Medium Medium-High
Utilities $39MM 3% High Medium
Transportation $36MM 2% Medium-High Medium-Low
Insurance ~$3MM <1% Medium High
Mining $425M <1% High Medium
Oil and Gas Extraction/

$0 0% High High
Retail Trade (Gas
Stations)
$18MM 1% High Medium-High
Agriculture $2MM <1% Medium Medium

looked at Berkshire’s 
System 


27Berkshire Hills Bancorp, Inc. — BHLB | berkshirebank.com » 2022 esg Report
energy usage, enhances our security posture and increases uptime to better
serve our customers. Collectively, these efforts will help drive further reductions
in  emissions as Berkshire continues to mature its program.

Berkshire continues to minimize its use of and impact on natural resources as well
as reduce waste within its operations. As part of Berkshire’s responsible and
sustainable business policy, the Company has laid out a clear commitment to
protect critical habitats and biodiversity as well as a policy to reduce waste within






consumptions, and we encourage employees to use reusable drinking containers
and packaging.



our plans, programs and initiatives to reduce our emissions, as well as capitalize
on the many business opportunities arising from the transition to a lower-carbon
economy. In the future, we expect to complete a more detailed scenario analysis,

management program and begin to develop a plan to achieve net zero and
eventually become a net-positive organization.


 







 465,717 thm 1,681.6 2473.6 69%
 12,933 thm 152.2 81.6 2%
 41,976 thm 30.1 313.9 9%
 520,626  1,8 63.9 2869.2 80%

 8044 MWh 0 0 0%
 943 MWh 1,182.3 225.6 6%
 943  1,182.3  6%







 29.6 21.2 <1%
 374.8 343.6 9%
  129.5 4%
   



  
MA  5113
CT 100% 1135
RI 100% 353
  
VT 78% 231
NY 100% 2055
PA 100% 100
*deregulated sites only
ENVIRONMENTAL SUSTAINABILITY
28Berkshire Hills Bancorp, Inc. — BHLB | berkshirebank.com » 2022 esg Report
It is not our goal to receive accolades, but it is
our hope that the recognition we have earned
might mean we are doing something right.
SUSTAINABLE BUSINESS NETWORK
Massachusetts Sustainable Business of the Year — Bank
BEST OF THE BERKSHIRES
Best Mortgage
BEST PLACES TO WORK FOR LGBTQ+ EQUALITY —
HUMAN RIGHTS CAMPAIGN
CORPORATE EQUALITY INDEX

BLOOMBERG GENDER-EQUALITY INDEX

FORBES
America’s Best Midsize Employers
NEWSWEEK
America’s Most Trustworthy Companies
COMMUNITAS AWARDS
International Leadership Award for Corporate Social Responsibility

BOSTON BUSINESS JOURNAL



&
29Berkshire Hills Bancorp, Inc. — BHLB | berkshirebank.com » 2022 esg Report
 





 Dollar Value of Mortgages Originated $24 0 $1.1

Dollar Value of Loans Outstanding to Support Small Businesses $342 $289
Number of Loans Outstanding to Support Small Businesses 5,080 4,286
Number of Small Business Loans Past Due 165 207
Dollar Value of Small Business Loans Past Due $9 $6.6



 $48 $67
Number of Community Development Loans Outstanding 70 76
 $242 $318
Number of Community Development Loans Past Due 0 0
Dollar Value of Community Development Loans Past Due $0 $0

Held at Year-End
$149 $71


Number of Individuals Impacted by Financial Wellness Programming 246,335 157,862
Number of Low-/No-Cost Retail Checking Accounts 183,856 180,231




Percent of Employees Completing Ethics
or Code of Conduct Training
100% 99%
Code of Business Conduct 
Whistleblower Policy/Anonymous Reporting Line 
Privacy Notice 
Online Privacy Notice 
Number and Amount of Anti-Competition Fines 0 0
Number & Amount of Fines for Bribery and Corruption 0 0
Number & Amount of Fines for Marketing and Labeling 0 0

Number of Customer Problems Referred to Our Complaint Center 2,644 1,636
Percent of Customer Problems Addressed at Year-End 97% 100%



Number of Cyber Breaches  
Percent of Employees Completing Information Security and Fraud Training 100% 99%
Number of Information Security Presentations to Board/Board Committee
(Annually)
3 3

Number of Transactions Granted Exceptions from Responsible and
Sustainable Business Policy 
0 0
Percent of Employees Completing Corporate Responsibility Policy Training 98% 99%
Responsible and Sustainable Business Policy 
 Risk Management Overview
Pg. 1



Dollar amount of Socially Responsible Assets  Under Management $25 $41
Percentage of  Assets Under Management <1% <1%
 






Corporate Governance Policy 
Number of Board Directors* 13 12
Number of Independent Directors* 11 11
Percent of Women on Board* 25% 33%
Percent of Ethnic Minorities on Board* 33% 33%
Board Committees










 Rating  
Number of Hours of Compliance Training 7,820 9,127
Number of Hours of Operational Audit 18,992 20,320




Total Number of s 1,319 1,310
Total Employee Count 1,337 1,337
Number of Full-Time Employees 1,291 1,282
Number of Part-Time Employees 56 55
Number of Temporary Employees 18 2
Retention Rate 64% 71%
Turnover Rate 31% 27%
Voluntary Turnover 28% 25%
Involuntary Turnover 3% 2%
Promotion Rate 23% 20%
Average Tenure (Years)  
Average Age (Years) 43 43.6
Minimum Wage (P/Hr) $15 $17
Percent of Employees Covered by Collective Bargaining Agreements 0 0

APPENDIX 
30Berkshire Hills Bancorp, Inc. — BHLB | berkshirebank.com » 2022 esg Report
 





Diversity, Equity
and Inclusion
Percent of Women in Workforce 67% 67%
 53% 54%
Percent of Women in Executive Management ( 46% 42 %
Percent of Ethnic Minorities in Workforce 15% 16%
 10 % 11%
Percent of Ethnic Minorities in Executive Management ( 23% 17%
Percent of Disabled in Workforce 3% 3%
Gender Pay Equity  
Percent of Employees Completing Diversity, Equity, Inclusion and Bias Training 97% 99%
Health and Wellness
 99% 97%
Number of Workplace Accidents 17 20
Number of Workplace Fatalities 0 0

Community
Investments
 619 518
 $2.7 $2.8
 78% 71%
Total Dollar Value of All Community Contributions $3.7 $3.5
Percent of Employee Participation in Xteam® Volunteer Program 82% 94%
Number of Hours of Volunteer Service 14,584 23,063
Number of Company Volunteer Events 69 168

Energy and Natural
Resource Management
Number of Environmental Fines 0 0
Amount of Paper Recycled  
Percent of Company Electronics Recycled 100% 100%
Percent of Sustainably Harvested and Environmentally Conscious Paper 5% 5%
Percent of Paper Reduction (from 2014 Baseline) 74% 78%
Total Electricity Usage (Mwh) 10,454 8,987
Total Renewable Electricity Usage (Mwh) 5,513 8,044
Total Nonrenewable Electricity Usage (Mwh) 4,941 943
Percent of Nonrenewable Electricity Usage  
Percent of Renewable Electricity Usage 53% 90%
Climate Change
 $74 $290
Scope 1  Emissions () 1,863.9 2,869.2
Scope 2  Emissions () 1,182.3 225.6
Scope 3  Emissions () 404.4 494.3
GHG Intensity (TCO2E/
USD Revenue)
Scope 1 & Scope 2 0.00000701 0.00000748
 

Describe the board’s oversight of climate-related risks and opportunities “Climate Governance” pg. 24 of this report
Describe management’s role in assessing and managing climate-related risks and opportunities “Climate Governance” pg. 24 of this report

Describe the organization’s processes for identifying and assessing climate-related risks “Risk Management” pg. 24 of this report
Describe the organization’s processes for managing climate-related risks “Risk Management” pg. 24 of this report
Describe how processes for identifying, assessing and managing climate-related risks are
integrated into the organization’s overall risk management
“Risk Management” pg. 24 of this report


short, medium and long term
“Strategy Risks and Opportunities”
pg.   of this report
Describe the impact of climate-related risks and opportunities on the organization’s businesses,

“Strategy Risks and Opportunities”
pg.  of this report
Describe the resilience of the organization’s strategy, taking into consideration different
climate-related scenarios, including a 2° or lower scenario
“Strategy Risks and Opportunities”
pg.   of this report

Disclose the metrics used by the organization to assess climate-related risks and opportunities
in line with its strategy and risk management process
“Metrics and Targets” pg.   of this report
Disclose Scope 1, Scope 2 and, if appropriate, Scope 3  emissions
and the related risks
“Metrics and Targets” pg.   of this report
Describe the targets used by the organization to manage climate-related risks and opportunities
and performance against targets
“Metrics and Targets” pg.   of this report
APPENDIX  
This document contains forward-looking statements (within the meaning of the
Private Securities Litigation Reform Act of 1995). There are several factors that
could cause actual results to differ signicantly from expectations described in the
forward-looking statements. For a discussion of such factors, please see Berkshire’s
most recently led reports on Forms 10-K and 10-Q, which are available on the SEC’s
website at www.sec.gov. Berkshire does not undertake any obligation to update
forward-looking statements.
Banking products are provided by Berkshire Bank: Member FDIC. Equal Housing
Lender. Berkshire Bank is a Massachusetts chartered bank.
Investment products are NOT FDIC-INSURED, are NOT A BANK DEPOSIT, NOT
GUARANTEED BY THE BANK, NOT INSURED BY ANY FEDERAL GOVERNMENT AGENCY
and MAY LOSE VALUE.
Rev. 4/14/2023
WHERE YOU BANK MATTERS
How your bank puts your money and its own
resources to work in your community through
investments and lending has a direct impact
on ensuring a better tomorrow for everyone.
We bring this message to life in unique and
compelling ways with our new “Where You Bank
Matters” marketing campaign as part of our
ongoing efforts to revitalize and sharpen the
focus of our brand.
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OPENING
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facebook.com/BerkshireBank »
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PERFORMANCE
BHLB
2022
PROGRESS
ANNUAL REPORT
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