A Purpose-Driven Financial Services Company

Our approach to operating ethically and sustainably has always been core to our business and culture. Over the last decade we have taken deliberate steps to formalize our environmental, social and governance (ESG) strategy, measure our performance and report our progress with transparency.

Our ability to integrate sustainable business practices into our operations is critical to delivering long-term value to our clients, customers, associates and community. In order to meet increasing and changing expectations an enormous commitment is required by all companies, and we are well positioned to execute. Data reflects 2019 ESG report. (*Data updated December 2021)

Ethical Decision-Making

Drive global growth and long-term success through integrity, ethical decision-making and transparency.

37.5% Board diversity
(female representation)*
99% Associates completing annual ethics training
81% Say on Pay Support – executive compensation score*
$0 Significant fines or
monetary sanctions

Management Approach

Business Integrity and Ethics

Business integrity, ethics and compliance with all applicable laws and regulations governing our business are among the guiding principles that influence planning and decisions related to Bread Financial’s operations and success. In a world of competing demands and rising expectations, we believe a strong ethical culture is essential to protecting our reputation, driving growth and preparing us for any challenge. To foster this culture of integrity and accountability, our Board of Directors and executive leaders start by setting the tone at the top. 

We operate under a comprehensive Code of Ethics, which covers numerous aspects of conduct expected of our associates. We also maintain supplementary codes of ethics for our Board of Directors and senior financial officers, which address additional standards and guidance applicable to their roles. Associates must certify annually that they have read, agree to and adhere to the Code of Ethics (99.3% of associates completed the Code of Ethics training in 2020); and every two years, they complete a more in-depth online Code of Ethics training, which addresses a variety of topics addressed in the code. Additional training is provided to associates on a regular basis covering topics such as global anti-corruption, insider trading, harassment and discrimination, retaliation, conflicts of interest and antitrust.

Our Corporate Ethics Office provides quarterly ethics reports to the Nominating and Governance Committee of our Board of Directors to keep it apprised of ethics-related complaints and investigations, and to help them assess and understand the Company’s corporate culture. Significant ethics-related complaints are also reported to the Audit Committee. 

We value and respect the opinions and insights of our associates and encourage them to raise their concerns. If an associate is aware of or suspects a violation of our Code of Ethics, they have a responsibility to report it. Associates have a variety of channels to ask questions or report concerns, including their supervisor or manager, Human Resources, legal, the Corporate Ethics Office or via our Ethics Helpline. The Ethics Helpline can be reached by phone or online around the clock, and associates may remain anonymous if they wish (except where prohibited by local law).

Corporate governance

We have a long tradition of good corporate governance, with rigorously stress-tested processes and controls, and comprehensive policies. Our Board of Directors continues to develop, support and oversee the implementation of responsible, stakeholder-centric practices consistent with the evolving governance environment, our stakeholders’ expectations and the commitments we’ve made to them.

Bread Financial has recently updated its pay for performance criteria to align with a broader range of financial and non-financial metrics.

Risk management

Our approach to Enterprise Risk Management identifies and manages risks related to the achievement of strategic, financial, compliance and operational objectives.

Our key risks and mitigation strategies are documented, monitored and reviewed quarterly. The Company’s Board of Directors reviews management’s assessment of enterprise risk as well as risk mitigation strategies twice a year. The Board may request additional review should they deem it appropriate or necessary. These risks are also reviewed alongside our sustainability strategy and priorities to ensure alignment of key issues across functions company-wide.



Lead in data-driven marketing and loyalty programs, ensure the secure and responsible use of data, adhere to responsible lending practices and display an unwavering commitment to service.

40.2M Active cardholder accounts
44 Credit card complaints per million active accounts (low among credit card banking peers)
+.70% Above industry average in customer satisfaction (lowest CFPB complaint volume per million active accounts)
0 Data breaches

Management Approach

Fair and Responsible Banking

We are committed to building trust and providing outstanding service to our clients and cardholders. Comenity Bank and Comenity Capital Bank are the banks behind Bread Financial's branded consumer credit programs. We work with top companies and some of the best-known retailers to extend their brands with their customers through innovative private label, co-brand and commercial credit card programs.

Credit and lending

As a leading provider of branded credit programs, fair and responsible lending is core to our cardholders' journey with us. Our credit programs create a win-win for consumers and clients. Significant consideration and detail go into ensuring the consumer credit application and underwriting processes are administered fairly. 

We adhere to a straightforward, transparent, impartial and equitable process for our lending practices. This is made possible through our fully automated proprietary process, which has been rigorously calibrated to accurately analyze and issue credit based on unbiased statistical modeling criteria. For further assurance, each year we employ an outside third party to conduct an extensive review of our credit portfolio and evaluation metrics, screening for any evidence of unintentional bias or discrimination to further ensure fair and responsible lending protocols.

Issuing credit responsibly also means taking care not to overburden cardholders with credit limits that surpass their ability to repay. We similarly apply advanced analytics and customary industry strategies to establish appropriate limits that give consumers the appropriate level of credit access and spending power and meet the needs (and are in the best interests) of both cardholders and our clients. Full-time dedicated resources continually examine and evaluate our models to ensure we maintain accurate and consistent thresholds.

Customer care

Delivering an exceptional customer experience is at the heart of our business practices, and our award-winning Care Centers are dedicated to creating that positive experience for our valued cardholders throughout every interaction. Whether communicating approved credit, answering cardholder questions or collecting a payment, we recognize that every opportunity to connect with cardholders counts. Advancing our customer-centric approach is an ongoing imperative. 

We continue to make investments in our call analytics capabilities, which enable us to gauge customer sentiment and apply greater focus on enhancing the customer experience. The sooner we can gather insights from customers, the faster we can improve the resources and information available to our customers and associates.


Respecting consumer privacy and safeguarding information are central to everyone's role at Bread Financial. Our commitment to good data governance and protection in these critical areas remains fundamental to our ability to help our clients understand and build relationships with their customers.

Identify and address risks 

Bread Financial uses a multi-faceted approach to identify and address data security risks. We monitor cyberthreat intelligence feeds and play an active role in collaborating with peers and industry groups such as the Financial Services Information Sharing and Analysis Center (FS-ISAC). Additionally, Bread Financial leverages leading technology solutions to detect, prevent and identify risks to the organization. These tools are managed around the clock, 365 days a year.

Should a data-security incident occur, we document it in accordance with our formal Incident Response Plan, and actions prescribed under that plan will be deployed. We evaluate and test the Incident Response Plan annually through tabletop exercises that include executive leadership.

External audits and vulnerability assessments 

We conduct regular external audits and vulnerability assessments based on leading protection standards. We also conduct quarterly updates and biannual incident response drills. In 2017, we adopted the NIST Cybersecurity Framework and continue to perform a biannual maturity assessment. In 2020, 99% of our employees completed Information Security Policy awareness and training.

Consent and use 

The Company maintains clear privacy and security statements that are provided to consumers at the point of data collection to ensure the transparent communication on the Company's collection, use, sharing and retention of the consumer's personal information. The following commitments are included:

  • We will notify consumers in a timely manner in case of policy changes or a data breach. 
  • Our collection and processing of user data is limited to the stated purpose. 
  • We have clear and accessible mechanisms for consumers to raise concerns about data privacy.



Our associates are the backbone of our business. Cultivating an inclusive, respectful workplace that develops and empowers our associates has always been critical to our success. As employees increasingly seek a strong, purpose-driven culture, including open communication and flexible work options, we are adopting talent strategies that keep pace with these expectations — engaging associates through data-driven feedback, technology and customization, just as we're doing for our clients and end-consumers.

6,000 Total number of associates*
62% Total workforce diversity
(female representation)
44% Senior leadership diversity
(female representation)
12.98% Voluntary turnover

Management Approach

Open Feedback Culture

One of the many things that elevates Bread Financial and makes it dynamic is that we take our associates' feedback seriously. Annual engagement surveys and quarterly pulse surveys bring attention to various organizational issues and help us ensure our workplace works for our associates. We then use those survey results to do the following:

  • Gauge the effectiveness of our work environment and identify opportunities for improvement.
  • Evaluate the effectiveness of policies and programs.
  • Develop action plans to challenge the status quo and address priority issues.
  • Conduct post-survey communications to keep associates informed of results and progress.

Training and development

Bread Financial offers a variety of online and on-site structured training, coaching, tuition reimbursement for external courses and on-the-job learning opportunities. In 2020, the Company invested nearly $10 million in training and development, a 35% increase in dollars per associate since 2017.

Another important component of associate development is regular formal performance reviews for all permanent employees aligned with career advancement. The 2020 implementation of Workday — a best-in-class digital system that integrates and enhances employee task management — proved especially valuable in this area by enabling us to advance our practices and improve leadership accountability surrounding the performance appraisal and feedback process.

Associate well-being

There's a well-established connection between associate health and well-being and an associate's ability to do his or her best work. Our data also tells us that associates who join one of our on-site fitness centers, undergo company-provided health checks or participate in our 401(k) plan are significantly more likely to stay with the Company. For these reasons, we have long had programs to support associate physical, mental and financial well-being.

We continue to offer an innovative concierge service model with a completely customizable, patient-focused approach. Benefits administrators work as advocates for our associates rather than gatekeepers. The goal is to always point our people to the right resources at the right time. Not only can they expect improved outcomes, but having health care advocates navigating the service on their behalf will also save them time and money. Since implementation, we've seen use rates go up. While that may create added cost for the Company, we know that it means our associates are getting healthier and are happier with the service — which, in the long run, means less time lost to illness, increased efficiency and greater overall associate satisfaction.

Diversity, Equity and Inclusion

We work to reflect the diversity of the cardholders, clients and associates by embracing different backgrounds, viewpoints, ethnicities and talents.

Consistent with our values, our Code of Ethics states that we will not discriminate based on race, color, religion, religious dress and grooming, gender, pregnancy, age, national origin, disability, sexual orientation, marital status, citizenship, veteran status, gender identity, transgender status or any other protected status.

Beyond the Code, and basic protection of individual rights, we actively promote diversity, equity and inclusion (DE&I). Bread Financial has established business resource groups that provide an opportunity for professional development, education, and social and community involvement for our associates from unique backgrounds.

At the Board and leadership levels, the focus has been on promoting gender and skills diversity. While demographics have been the focus of associate diversity efforts in the past, the Board of Directors adopted the Rooney Rule in 2019, which is a commitment to include women and underrepresented minority candidates in every pool from which Board nominees are chosen. Our Board is also regularly briefed on our diversity performance, including gender make-up, gender leadership, Board refreshment and pay equity.

Events from last year — the COVID-19 pandemic, social and civil unrest, and the presidential election — offered many lessons and laid deep divisions among us. Conversely, one of the silver linings was that these events provided the impetus for significant and meaningful change.

In 2020, we reignited our commitment to DE&I, employing a DE&I consulting firm to help us define our road map for continued progress through employee focus groups, an inclusion survey, leadership training and a thorough review of our policies and practices. These activities resulted in a new strategic framework, focus areas and vision for success.



Over the years, as our organization has grown, we’ve steadily increased our global community investment and volunteerism, recognizing the need for successful companies like ours to employ our resources in a way that both strengthens our communities and helps create a future where our business and local economies flourish.

$7.5M Community investment (donations)
$1.2M Data for Good investment (donations)
10,000hrs Community investment (volunteerism)
5.56% Supplier diversity spending

Management Approach

While all businesses tailor their approach to meeting the needs of their respective associates and local communities, we have enterprise-wide goals, guidelines, programs and governance that guide our decision-making and align our efforts.

Corporate responsibility representatives from each line of business are critical for partnering on grant making, best practices, data collection and reporting. For international grant making, we rely on the consultative expertise and nonprofit equivalency determination of the Silicon Valley Community Foundation.

We continue to evolve our community investments commensurate with the evolution of our business. Our focus areas are based on what’s most important to our associates, where our communities need the most support and how we can promote a sustainable economic environment. In addition, we prioritize investments that connect associates, align with our expertise, are geographically inclusive, provide measurable impact, and enhance our brand and reputation.

The following efforts highlighted our community support work in 2020.

Community Investment

We donated more than $7 million to charities focused on children, education and independence and oversaw the redemption/donation of $2.1 million worth of AIR MILES rewards to charitable causes. In addition, we donated computers, monitors and iPhones to support students needing access to technology for remote learning. We also received an “Outstanding” Community Reinvestment Act rating for the fourth consecutive year.

Associate Programs

We conducted our annual promotion of matching gifts and Dollars for Doers programs and we ran a double-match campaign in 2020 for racial equity causes. Also, associates contributed more than $1 million through campaigns and programs.


We placed increased focus on skills-based volunteerism, lending associate talent to benefit nonprofit organizations’ missions. At the Mid-Ohio Food Collective, we dedicated a work team to assist in the development of their data and analytics platform. We also developed marketing materials for Directions for Youth and Families. For Motionball, a national youth empowerment nonprofit in Canada, we created marketing materials and prepared a data analysis of their donor database.

Community Reinvestment

Under the Community Reinvestment Act (CRA), passed in 1977 as a measure to expand access to credit, federally insured depository institutions like Comenity Bank and Comenity Capital Bank have an obligation to support the credit needs of the communities in which they are located.

Comenity and Comenity Capital are subject to regulatory supervision by the Federal Deposit Insurance Corporation (FDIC) and the Consumer Financial Protection Bureau (CFPB), in addition to state supervision in Delaware and Utah, where the bank's respectively headquartered. In our most recent FDIC examination, we received the highest rating of “outstanding” for our activities under the CRA.

The bank's holistic approach to community reinvestment engages and connects local stakeholders and resources, as well as community development investments and services, to meet the greatest needs of the communities it serves. These programs are led by an officer appointed by the bank’s Board of Directors, with oversight from respective bank committees.



We recognize that the natural environment is under increasing strain: ecosystems and wildlife are being threatened and climate change is creating a growing uncertainty for societies and economies. Climate change and associated risk is real and relevant to our clients and associates — and we are taking action.

16% Electricity from renewable sources
45,233MT CO2e Greenhouse gas emissions (total)
84% Electricity sourced from the grid
146,124GJ Total energy consumed

Management Approach

Reducing Our Carbon Footprint

Bread Financial has an ongoing commitment to reducing our greenhouse gas (GHG) emissions to help combat climate change. Our efforts extend to all lines of business, stakeholder groups and our work in the community.

The starting point of our efforts to reduce our carbon footprint is capturing our GHG inventory, which details and quantifies our emissions. We completed our ninth inventory in 2020, and we are using the results to better understand and manage our impacts and to report to the CDP. The GHG inventory also provides the basis for ultimately setting science-based emissions reduction targets. Given our divestiture of Epsilon, which occurred in July 2019, only the emissions for the period of January 1 to July 31, 2019, while Epsilon was operating, are included in our 2019 inventory. Epsilon was fully removed from the 2020 GHG inventory. This divestiture triggered a restatement of base and all intervening historical year emissions.

Among the actions taken in 2020 to reduce our carbon footprint, the most significant was a comprehensive optimization of our U.S. real estate that will produce a lasting, long-term decrease in our emissions. We also planted 580 trees in honor of BrandLoyalty’s 25th anniversary for each associate.

Using Resources Efficiently

Our GHG inventory indicates that some of our biggest environmental impacts are energy consumption, paper usage and, prior to COVID-19, associate commuting — so that’s where we focus our environmental efforts.

Energy conservation

Facility managers are responsible for conservation projects at their respective buildings. Improvements have been made by upgrading to energy-efficient LED lighting and removing desktop printers in existing buildings. However, the biggest gains come from new facilities that are designed for efficiency from the start: LoyaltyOne’s headquarters has received LEED Platinum certification and the Company has been recognized as one of Canada’s Greenest Employers.

In 2020, employee communications focused on environmental education and awareness, and saving energy while working from home. At AIR MILES, the Company launched its first environmentally focused employee resource group, called Sustainables.

Paper and plastic

The majority of our paper purchase is based on the needs of our clients. Paper is used in client-driven marketing materials and cardholder or collector statements, although many clients are shifting from print to digital formats. We’ve made strong gains internally by switching from individual desktop printers to multi-function devices (MFDs), which are shared by multiple users and discourage unnecessary printing. MFD defaults are set to double-sided black-and-white printing.

In 2020, BrandLoyalty launched a focus on smart packaging, which resulted in the removal of plastic from the packaging of their reward products.


Efforts to minimize emissions from commuting include work-from-home programs, which are rare for the industry, electric car charging stations, and bike racks and on-site shower facilities to encourage cycling to work. In 2019, we launched a business-wide evaluation of our office footprint, which resulted in a significant number of associates moving to work-from-home arrangements and will help us reduce energy consumption and commuting-related emissions. With an additional 16% of AIR MILES’ frontline workforce moving to home offices in 2019, a full 84% of its frontline associates now work from home on a full-time basis.

In March of 2020, 95% of associates moved to work from home due to the COVID-19 pandemic, and remained such through the duration of the year.

Our headquarters in Columbus, Ohio, participated as an Acceleration Partner in the Smart Columbus “Smart Cities” initiative aimed at inspiring and motivating employees to drive electric and drive less. As a partner, we committed to five engagements: appointing a program leader, encouraging executives to buy electric vehicles (EV), installing charging infrastructure, educating our associates on smart mobility and incentivizing behavior change. Smart Columbus’ goals are to bring the city’s EV adoption rate to at least 1.8% by 2020 — a four-fold increase that would put more than 3,600 electric vehicles on the road — and decrease single-occupant vehicle commuter traffic by 10%.

To contribute to these goals during the program, Bread Financial installed electric charging stations, offered a $2,000 (post-tax) EV rebate for associates in the Columbus region and $1,000 (post-tax) rebate for non-Columbus associates. We hosted a Ride & Drive Roadshow and a EV 101 lunch and learn to educate associates on the benefits of driving electric.


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