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Audits and Compliance

IBM measures its environmental performance against both external and internal requirements.

Every year, and more frequently for some, IBM’s manufacturing, hardware development and research sites and organizations—such as Product Development, Global Real Estate Operations, Global Asset Recovery Services, Global Logistics and Global Service Environmental Compliance—complete a comprehensive self-assessment. Each year, certain sites are audited for environmental, health and safety compliance by IBM’s Corporate Internal Audit staff. Audit results are communicated to top management. Follow-up, accountability and actions are clearly delineated.

In addition, as part of IBM’s single, global registration to ISO 14001, approximately 25 sites or registered entities are audited annually by an independent ISO 14001 registrar. The company’s manufacturing, hardware development and chemical-using research sites are audited by either the Corporate Internal Audit team or the external ISO 14001 registrar at least once every two years.

Accidental Releases

IBM sites around the world report environmental incidents and accidental releases to IBM management through the company’s Environmental Incident Reporting System (EIRS). IBM’s environmental incident reporting criteria are equal to or exceed legal reporting requirements, and every event meeting IBM’s reporting criteria must be reported through EIRS. Each IBM location must have a documented incident prevention program (including provisions for preventing environmental incidents or their recurrence) and reporting procedure.

In 2011, a total of 27 accidental releases of substances to the environment related to IBM operations were reported through EIRS. Of these, 10 were to air, eight to land, three to water, and six to both land and water.

Emissions to the air included nine releases of refrigerants and one release of a fire suppression gas.

Releases to land included two releases of diesel fuel, two releases of hydraulic fluid and one release each of chilled water, treated domestic water, untreated industrial wastewater and a petroleum substance.

Releases to water included two releases of water from fire protection systems and one release of hydraulic fluid.

Releases to both land and water included one release each of untreated industrial wastewater, chilled water, treated industrial wastewater, potable water, sprinkler water and well water.

The root cause was investigated for all releases and corrective actions were taken as appropriate. None of the releases were of a duration or concentration to cause long-term environmental impact.

Fines and Penalties

One significant measure of a company’s environmental performance is its record of fines and penalties.

In 2011, IBM received 83 successful agency visits worldwide with no fines being assessed.

Over the past five years, IBM has paid three fines for a total amount of $31,000.

Fines and Penalties Worldwide
($ in thousands)
2007 2008 2009 2010 2011
Number 1 0 2 0 0
Fines $1.0 $0.0 $30.0 $0.0 $0.0