Environmental reporting, disclosure & verification

Under IBM's single, global registration to ISO 14001, approximately 20 IBM sites or registered entities are audited annually by an independent ISO 14001 registrar. These audits of IBM's environmental management system include sampling and verification of the implementation of the company's internal requirements, and monitoring and measurement as reported through a variety of mechanisms and tools used to provide the information for IBM's environmental and corporate responsibility reporting and for management review.

In addition, IBM's emissions inventories are audited three ways: 1) by the Financial Industry Regulatory Authority (FINRA) under the company's participation in the Chicago Climate Exchange (Canada, Mexico, and the United States), 2) by the U.S. Environmental Protection Agency (EPA) under its participation in Climate Leaders (Global), and 3) by Bureau Veritas Certification North America as part of IBM's ISO 14001 third party audits of location and country/region operations.

• The FINRA audit for the Chicago Climate Exchange involves selecting a sample of the inventory data points, facility electricity, fuel, or PFC usage, and reviewing the billing data to verify that the bill data matches the submitted inventory data. Geographically, this audit covers IBM's operations in Canada, Mexico and the United States. Approximately 18% of the data points are sampled.
• Through its participation in the U.S. EPA's Climate Leaders program, IBM's emissions goal data and its progress toward the company's GHG emissions reduction goal worldwide is reviewed. IBM receives technical assistance from the U.S. EPA in identifying the most appropriate emissions factors and in completing the documentation required to support the Inventory Management Plan (IMP). The U.S. EPA performs desktop reviews of both the inventory data and IMP to ensure they meet U.S. EPA's quality standards. The U.S. EPA also conducts a risk-based on-site IMP review to ensure that the management plan is being well implemented at the facility level.
• IBM worked with Bureau Veritas Certification North America, its ISO 14001 registrar, to establish an audit protocol for its locations' energy management systems. A location energy audit includes matching the bill data to the data the location has input into the Utility Accountant, an application IBM uses to manage its energy inventory.