76 The ESRM webpage The ESRM Framework (PDF) ESG viewpoints ONLINE RESOURCES 3. Training: Wells Fargo provides a comprehensive BSA/AML and Global Sanctions training program, to help make certain all employees receive adequate and appropriate training to maintain compliance with BSA/AML, Global Sanctions, and ABC regulations and expectations . 4. Independent Testing: Internal Audit provides independent testing of the BSA/AML compliance program . Global sanctions Under the direction of the Corporate BSA Officer, the Financial Crimes Risk Management Global Sanctions Office provides oversight of the companywide Global Sanctions Compliance Program . The Global Sanctions Office leads the implementation of, content updates to, and compliance with the Global Sanctions Policy, which is applicable companywide and outlines Wells Fargo’s requirements for complying with economic sanctions laws in jurisdictions where Wells Fargo operates . Anti-bribery and corruption Wells Fargo has zero tolerance for bribery and corruption in any form . The Financial Crimes Risk Management Anti-bribery and Corruption Governance team is responsible for companywide leadership, support, and independent oversight of Wells Fargo’s ABC Compliance Program . This includes developing and maintaining the ABC Policy, which is applicable companywide and outlines Wells Fargo’s requirements for complying with applicable bribery and corruption laws and regulations . Environmental and social risk management As a provider of financial services for customers in nearly every sector of the economy and around the world, we must consider the environmental and social impacts of our lending and investments, in addition to traditional financial risk . Our ESRM Framework (PDF) and policies include due diligence requirements that help us identify, evaluate, and manage the environmental and social risks associated with our lending and investments . As our understanding of these complex issues evolves, we aim to update our ESRM requirements and strive to adhere to global best practices for managing environmental and social risk . Our stakeholder engagement helps us to better understand changing environmental and social expectations that can create risk in our business, and we apply what we learn to our policies and practices . Performance trends can be found in the Wells Fargo ESG Goals and Performance Data (PDF) .