in the Supply Chain
As part of our longstanding corporate commitment to environmental leadership across all of our business activities, IBM is committed to working with environmentally and socially responsible suppliers. The objectives of our requirements for suppliers and our supplier evaluation programs include:
- Preventing the transfer of responsibility for environmentally sensitive operations to any company lacking the commitment or capability to management them properly
- Reducing environmental and workplace health and safety risks
While examples of this commitment have been highlighted in other sections of this report, the following table provides key milestones of this leadership over the past four decades.
Environmental Evaluations of Suppliers
- 1972 Established a corporate directive requiring the environmental evaluation of suppliers of hazardous waste services
- 1980 Expanded our environmental evaluations of suppliers by establishing a second corporate directive to require the environmental evaluation of certain production-related suppliers
- 1991 Further expanded our environmental evaluations of suppliers, adding a requirement that product recycling and product disposal suppliers be evaluated
- 2002 Nongovernmental organizations raised a concern about electronic waste being exported to some non-OECD countries. Though we confirmed that IBM was not shipping hazardous electronic waste products to non-OECD countries, we added a requirement to assess our suppliers and certain subcontractors they may use to handle recycling and/or disposal operations in non-OECD countries
- 2010 Established a requirement that all of IBM’s first-tier suppliers establish a management system to address their social and environmental responsibilities—and that they cascade this requirement to their suppliers
IBM’s environmental evaluations of suppliers
IBM’s environmental requirements for its suppliers are set forth in a corporate directive that governs the contracts by which we:
- Specify and/or furnish chemicals, process equipment or
contaminated equipment involved in production
- Procure materials, parts and products for use in hardware applications
- Procure hazardous waste treatment and/or disposal services
- Procure product end-of life management services
Specific environmental requirements are documented in our contracts with suppliers conducting these types of activities. These may include requirements related to chemical content, chemical management, waste management, spill prevention, health and safety and reporting, to mention some of the most relevant ones.
For hazardous waste and product end-of-life management suppliers, IBM conducts an on-site review of the supplier facility’s environmental, health, safety and industrial hygiene management program; its medical screening and monitoring programs; and a review of its environmental, health and safety audits for the previous three years. We evaluate these suppliers prior to entering into a contract with them and then again every three years thereafter to ensure their operations and commitment to workplace safety and sound environmental practices continues to meet our requirements. The audits are conducted by IBM’s Corporate Environmental staff or by environmental professionals under the direction of this staff.
IBM’s hazardous waste and product end-of-life management supplier audits are comprehensive in the scope of the environmental aspects covered. The following provides a summary of the scope of the environmental aspects of the audits:
- Facility operational activities, capabilities, capacities and services
- Waste management services, treatment, recycling or final disposal methods, processing capacity and facility construction design (floors, docks, secondary containment)
- Treatment and recycling methods for the hazardous and nonhazardous special wastes generated by supplier’s operations
- Environmental, health and industrial safety and hygiene management plan, training, fire and safety equipment, emergency response plan, personal protective equipment, chemicals used and safety data sheets, evacuation plans, first aid, medical screening and monitoring programs, etc.
- Environmental and corporate responsibility
- Social and environmental management system
- Applicable legal requirements and compliance
- Permits, licenses and other applicable regulatory requirements, regulatory agencies and contacts
- Compliance history (notices of violation, government citations, public complaints and summary of inspections and findings)
- Environmental programs including:
- Air emissions, water discharges and water consumption
- Underground storage tanks and piping systems
- Spill prevention, containment and response
- Environmental liabilities and insurance coverage
IBM also requires its hazardous waste and product end-of-life management suppliers to track the shipment and processing of any hazardous materials they handle for IBM and report that information to us.
Waste processing (treatment, recycling or disposal) and Product End-of-Life Management (PELM) in non-OECD countries
As we do with all of our environmental programs, IBM manages its hazardous waste and product end-of-life management programs to the same high standards no matter where in the world we are operating. Doing so can be particularly challenging in some countries when processing infrastructure (treatment, recycling and/or disposal) that meets IBM’s requirements is lacking.
If there are no suppliers in a country that meet IBM’s environmental and safety requirements for hazardous waste or product processing, the waste generated by IBM’s operations is shipped to facilities in other countries where those requirements can be met. This shipping is done in compliance with country laws and regulations and the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal.
Though rare, there are sometimes situations in which local processing of waste is not possible and shipping to IBM-approved suppliers in other countries is not allowed due to legal requirements. In these situations, IBM will store wastes and product end-of-life materials in properly contained and managed storage facilities until suitable processing facilities are available.
An example of a recent concern brought to IBM’s attention in this area is the recycling of lead acid batteries. Some interest groups have expressed concern about companies which may export lead acid batteries from the United States to Mexico or other countries, where the batteries may be recycled in operations that are not properly protective of the workers or the environment. All lead acid batteries disposed of by IBM are covered under IBM’s hazardous waste management program and are recycled at IBM-approved facilities within the country where they are generated, whenever possible. IBM does not export used lead acid batteries from the United States or any other country where suitable recycling facilities are available within the country.
IBM’s Social and Environmental Management System (S&EMS) requirement for all its Suppliers
In 2010, IBM established a requirement that all first-tier suppliers establish a management system to address their social and environmental responsibilities. Our objective in establishing this requirement was to help our suppliers build their own capability to succeed in this area.
These suppliers are required to:
- Define, deploy and sustain a management system that addresses their intersections with their employees, society and the environment
- Measure performance and establish voluntary, quantifiable environmental goals
- Publicly disclose results associated with these voluntary environmental goals and other environmental aspects of their management systems
- Cascade these requirements to their suppliers who perform work that is material to the products, parts and/or services supplied to IBM
More information on these new supplier requirements may be found in the Supply Chain section of this report and on IBM’s Supply Chain Environmental Responsibility website.