Comerica Incorporated : Corporate Responsibility Report (Environment)
CMA
Published on 07/02/2025 at 11:39
CEO
Letter
About This Report
About Comerica
Corporate Responsibility at Comerica
Customers Colleagues Inclusion Community Environment
Responsible Business
Additional Information
Comerica's 175-year history speaks to our ability to understand long-term vision while addressing near-term needs. We approach environmental issues like climate change with that same understanding - knowing that our future success depends on the actions we take today.
Scott Beckerman
Senior Vice President,
Director of Corporate Sustainability
Climate Change 56
Reducing GHG Emissions 59
Reducing Paper, Waste and Water Impacts 61
Reducing Environmental Risk Through Credit and 63
Lending Practices
Environmentally Beneficial (Green) Loans 64
Driving Sustainability Engagement and Awareness 65
2024 Comerica Corporate Responsibility Report 55
Protecting and preserving the environment is important to the health and well-being of the people, businesses and communities we serve. As a bank, Comerica is uniquely positioned to help address environmental challenges and support sustainability initiatives across our entire value chain.
We recognize the impact we have through our customer relationships, and we believe the best way to meet the needs of a greener economy is to work with our customers.
Comerica is committed to helping them adapt to a changing business and planetary climate in support of their own sustainability goals. We are also committed to reducing our environmental footprint and were one of the first U.S. regional banks to pledge to reduce our Scope 1 and 2 emissions 100% by 2050.6As of year-end 2024, we reduced these emissions 61% compared to 2012. Beyond our own and our customers' operations, we have several programs in place to drive sustainability awareness for our suppliers
and colleagues.
Comerica's Corporate Responsibility Platform includes a commitment to address climate change because we understand that a changing climate can create conditions that impact our organization and our customers.
We recognize some stakeholders identify climate change as a significant risk and are seeking to better understand how companies, including banks, are assessing these risks. Our key climate-related priorities are composed of both inward- and outward-facing aspects, to build on the 17 years of progress of our sustainability program.
Supporting Customers
We are committed to working with our customers to meet their evolving needs in a greener economy.
Integrating Climate
We will work to integrate climate matters into our strategy, lines of business and approach to
risk management.
Reducing Our Emissions Footprint
We continue working to reduce Comerica's
associated GHG emissions.
6When Comerica's 2050 operational emissions reduction goal was initially set, it was a 100% reduction of our Scope 1 and 2 real estate-related GHG emissions from 2012 to 2050, which covered 99% of our Scope 1 and 2 GHG emissions. In 2021, we extended our goal to include our Scope 1 travel GHG emissions so that all Scope 1 and 2 GHG emissions are included in the goal.
2024 Comerica Corporate Responsibility Report 56
CEO
Letter
About This Report
About Comerica
Corporate Responsibility at Comerica
Customers
Colleagues
Inclusion
Community
Environment
Responsible Business
Additional Information
CEO
Letter
About This Report
About Comerica
Corporate Responsibility at Comerica
Customers Colleagues Inclusion Community Environment
Responsible Business
Additional Information
Climate-Related Commitments and Reporting
Comerica has a significant history of sustainability and climate-related engagement, including reporting to CDP, publishing TCFD reports and providing information on environmentally beneficial lending. This legacy also well positions Comerica for future climate-based regulatory disclosures. Below are select climate-related highlights from our program history.
Corporate Sustainability Office established
Environmental Policy Statement developed
First Sustainability Report published First CDP response issued
Established Green Procurement working team
Enterprise Risk Committee of the Board begins oversight of Sustainability
First disclosure on green lending
First GHG reduction
goal established (15% vs. 2008 baseline)
Environmentally beneficial (green) loan tracking system launched
First GHG Emissions Inventory Management Plan
First third-party verification of Scope 1 and 2 GHG emissions
First generation GHG reduction goal met
Established second GHG reduction goal (20% vs. 2012 baseline)
Master of Sustainability Awareness Program launched
Second generation GHG reduction goal met
Climate Leadership Award for Excellence in Greenhouse Gas Management
Master of Sustainability Awareness Program expanded to all colleagues
Established current GHG reduction goals (50% by 2025, 65% by 2030, 100% by 2050
vs. 2012 baseline)
First TCFD-aligned responses in CDP questionnaire
Received second Climate Leadership Award for Excellence in Greenhouse Gas Management
Comerica joins PCAF
Third GHG reduction goal met (50% by 2025)
Comerica's Corporate Responsibility Platform includes addressing climate change
GHG emissions inventory covers 100% of supply chain
Established Office of Corporate Responsibility (now called Corporate Affairs)
Comerica establishes Renewable Energy Solutions group
Green loans exceeded $2 billion for the first time
Inaugural TCFD Report published
First PCAF-based disclosure on financed emissions
Developed preliminary Climate Risk Framework
Green loans exceeded $3 billion for the first time
Scope 1 and 2 emissions reduction
of 61%
Published second financed emissions disclosure
2024 Comerica Corporate Responsibility Report 57
CEO
Letter
About This Report
About Comerica
Corporate Responsibility at Comerica
Customers Colleagues Inclusion Community Environment
Responsible Business
Additional Information
Environmental Policy Statement Commitments
Climate • Measure, report and reduce our greenhouse gas
(GHG) emissions
Evaluate climate-related risks
Increase awareness of climate-related matters with customers, suppliers and colleagues
Seek profitable opportunities to provide climate-related products and services
Support public policy approaches that harness the power of markets to create and implement cost-effective climate solutions
Resource Conservation
Transparency and Accountability
Implement initiatives to reduce, reuse, recycle and rethink processes to decrease use of natural resources and generation of waste
Reduce our energy, paper and water consumption
Construct new banking centers in ways consistent with our commitment to environmental stewardship
Seek profitable opportunities to provide financial products and services to customers that promote energy conservation and efficiency, water conservation, waste reduction and other environmentally beneficial business practices
Promote awareness among customers, colleagues and suppliers of opportunities to minimize use of natural resources and generation of waste
Provide colleague awareness training to ensure policy is implemented throughout company
Establish systems and procedures to track and assess performance and publish external reports
Periodically engage with external stakeholders for feedback on our sustainability performance
2024 Comerica Corporate Responsibility Report 58
In 2011, we announced our first GHG emissions reduction goal, and in 2018, we were one of the first U.S. regional banks to pledge to reduce our Scope 1 and 2 emissions by 100% by 2050.
Though not "net zero" goals, our GHG reduction goals have been instrumental in guiding our progress. Reducing energy consumption is key to minimizing our Scope 1 and 2 GHG emissions footprint since the majority of our direct GHG emissions are related to energy used to operate our buildings. Efficiently managing our energy use is also important to our bottom line as energy is a significant operating expense.
Reduction of GHG Emissions and Energy Impacts
To guide our environmental strategy and help us reduce Comerica's carbon footprint, we have established quantifiable and measurable GHG emissions goals.
Emissions Type
Direct emissions from fuel combustion and refrigerant leakage (real estate and travel)
Base Base Year
Scope 1 GHG Emissions (tCO2e)8
Year Emissions 2022 2023 2024
2012 6,950 6,242 5,682 5,391
Progress
As of 2024 year-end, we have achieved a 61% reduction in Scope 1 and 2 GHG emissions7against our 2030 goal and have already exceeded our 2025 goal of a 50% reduction.
Goals
Scope 2 market-based GHG emissions9
2012
74,784 29,699 25,570 22,710
Scope 2 location-based GHG emissions
2012
74,784 28,804 29,221 26,749
Scope 2 GHG Emissions (tCO2e)
65% reduction of 2012 base year Scope 1 and 2 GHG emissions by 2030;
Improving Our Renewable Energy Efforts
Comerica contracted with our primary electricity supplier in Texas to provide Renewable Energy Certificates (RECs) associated with our electricity consumption beginning mid-year 2023. In addition, we contracted with our primary electricity supplier in Michigan in a similar way beginning in 2026.
By adopting programs such as these, we are helping to support the renewable energy markets while also limiting our market-based Scope 2 emissions. Our 2024 Scope 2 market-based emissions are 15% lower than the location-based emissions, reflecting the impact of the renewable energy RECs. When using Scope 2 market-based emissions, our overall GHG emissions reductions increase to nearly 66% compared with our 2012 base year.
We also conducted research in 2024 to understand other potential renewable energy opportunities across our key markets. We established our renewable energy strategy, which will align with our relationship-based approach to business by prioritizing:
In-market solutions nearest the communities in which we do business
Longer-term solutions
Attractive cost, complexity and risk profiles
100% reduction of 2012 base year
Scope 1 and 2 GHG emissions
65% 100%
2030 (Goal) 2050 (Goal)
by 2050
Goal progress: 61%
2012 (Baseline)
Scope 1 and 2 GHG emissions
2024 (Progress)
Our Corporate Real Estate team, along with their external partners, manages our real estate-based Scope 1 and 2 GHG emissions goals and energy use. In 2024, we continued to take key actions toward achieving our goal to reduce our Scope 1 and 2 GHG emissions:
Implemented a tiered energy reduction program to match data center load as that load decreased through virtualization
Actively managed building heating and cooling throughout the year to maximize the use of natural conditions and minimize mechanical heating and cooling
Added high-efficiency lighting during select building upgrades
Moving forward, we are evaluating resetting our baseline year from 2012 to 2025, reflecting recent significant changes to our real estate portfolio. We are also evaluating updating our goals to reflect the impact of our reductions in market-based Scope 2 emissions.
7Includes Scope 1 and 2 location-based emissions.
8 tCO2e = metric tons carbon dioxide equivalents.
9The location-based emissions base year of 2012 was used as a proxy for market-based since a market-based
emissions base year was unable to be calculated.
2024 Comerica Corporate Responsibility Report 59
CEO
Letter
About This Report
About Comerica
Corporate Responsibility at Comerica
Customers
Colleagues
Inclusion
Community
Environment
Responsible Business
Additional Information
Disclaimer
Comerica Inc. published this content on June 30, 2025, and is solely responsible for the information contained herein. Distributed via Public Technologies (PUBT), unedited and unaltered, on July 02, 2025 at 15:38 UTC.