IBM's corporate environmental policy provides the strategic framework for the company's global environmental management system (EMS). This policy calls for environmental leadership in all of the company's business activities.

Achieving leadership is enabled through the implementation of IBM's EMS, which integrates corporate directives governing the company's conduct and operations worldwide. These directives cover areas such as energy conservation and climate protection, product stewardship, pollution prevention, chemical and waste management, and environmental evaluation of suppliers, as well as incident prevention, preparedness, response and reporting. It is through the consistent implementation of its EMS that IBM ensures operations are executed with the same protective standards for the environment in every country where IBM conducts business.

IBM's EMS is executed by employees from across all of its business organizations. Its structure and programs are designed to integrate environmental considerations throughout the company's operations.

Under the direction of the Vice President, Corporate Environmental Affairs and Product Safety, and Chief Sustainability Officer, IBM's Corporate Environmental Affairs staff is responsible for establishing the company's worldwide environmental affairs strategy, the EMS requirements, and for monitoring its implementation.

The company's environmental programs are implemented by professionals at manufacturing, development and research sites around the world. Within operating units, IBM executives are responsible for the environmental performance of their respective business functions or locations. Every employee is expected to follow IBM's corporate environmental policy and report any environmental, health or safety concerns to IBM management. Managers are expected to take prompt action when faced with a potential violation of the corporate policy or directives. In addition, IBM's Business Conduct Guidelines, the company's code of business conduct and ethics for all IBM employees, includes a section highlighting employee responsibilities for protecting the environment.

Setting voluntary environmental goals is an important part of IBM's EMS. The company maintains a range of environmental goals designed to address the significant environmental aspects and impacts of its operations, and to drive continual improvement of its environmental performance. IBM's goals cover energy and climate change, conservation and biodiversity, pollution prevention and waste management, supply chain and value chain, and our global environmental management system.

Relevant environmental training is integral to the proper functioning of the EMS. All IBM employees worldwide are periodically required to read and certify their compliance to IBM's Business Conduct Guidelines. These Guidelines cover areas in which employees have a responsibility to the company, and they include the awareness of and compliance with IBM's corporate environmental policy and other environmental requirements. Environmental training is commensurate with employees' job responsibilities.

IBM employs a variety of mechanisms to monitor and measure the effective implementation of its EMS requirements. These include:

Professional Self-Assessment Program

Every year, IBM's manufacturing, hardware development and chemical-using research locations and organizations -- such as hardware product design groups, real estate operations, data centers, procurement, logistics, asset recovery services, and business services -- complete a comprehensive environmental self-assessment. The professional self-assessment program consists of a series of IBM specific environmental checklists which are used to provide the company the ability to assess its overall environmental performance globally on a consistent basis. The checklists cover both manufacturing and hardware development locations and nonmanufacturing locations at a geographic level, product groups and service activities.

Applications for global environmental data reporting

IBM uses various applications for global environmental data reporting and monitoring, such as the IBM Envizi ESG Suite for tracking, analyzing, monitoring and reporting its energy consumption and greenhouse gas emissions data.

These applications are used to collect global environmental data that is used in IBM's annual environmental reporting as well as in periodic updates on performance and programs that go to senior management. They also are used to monitor environmental performance and identify areas for improvement.

Corporate audits

IBM has an environmental audit program which is implemented by the company's Corporate Assurance and Advisory Services (CAAS) organization. This is a comprehensive risk-based audit program which is independent of the Corporate Environmental Affairs staff. Periodically, based on environmental risk criteria, certain IBM sites or environmental processes are audited by the CAAS staff.

ISO 14001 and 50001 surveillance audits

As part of IBM's global registration to ISO 14001, approximately 10 sites or registered entities are audited annually by an independent ISO 14001 registrar. The ISO 14001 surveillance audits are used to verify implementation of IBM's global EMS.

IBM's Energy Management Program is an integral part of our global EMS. As such, any entity pursuing ISO 50001 certification is required to have been certified under our global registration to ISO 14001 before it can be integrated into our global ISO 50001 registration.

In 2022, IBM received 26 agency inspections at its locations worldwide. No fines or penalties resulted from these inspections. Over the past five years, IBM has paid two environmental fines totaling $8,000; a $500 fine resulting from an unplanned release of drinking water in 2021 and a USD 7,500 fine resulting from a regulatory inspection of an IBM location in 2020 during which the agency identified inaccuracies in the emergency equipment list portion of the location's hazardous waste contingency plan. In both instances, corrective actions were taken to prevent recurrence.