2014 Corporate Responsibility Report

Audits and compliance

IBM measures our environmental performance against both external and internal requirements, and we take prompt and decisive action when any issues are identified.

Every year, and more frequently for some, IBM’s manufacturing, hardware development and research locations and organizations — such as product development, Global Real Estate Operations, Global Asset Recovery Services, Global Services Environmental Compliance, and Supply Chain — complete a comprehensive self-assessment. IBM’s Corporate Internal Audit staff may also conduct environmental, health and safety audits. Audit and self-assessment results are communicated to top management. Follow-up, accountability and actions are clearly delineated.

In addition, independent external audits are conducted on a scheduled cycle as part of IBM’s single, global registration to ISO 14001:2004. Approximately 25 IBM locations and relevant business organizations (known as registered entities) are audited annually by an independent ISO 14001 registrar. Our manufacturing, hardware development and chemical-using research locations and organizations are audited by the ISO 14001 registrar every 12-30 months.

An independent registrar also audits IBM’s Energy Management Program and enterprise-wide database for managing energy consumption information, against the ISO 50001:2011 standard, as part of IBM's single global Environmental Management System. Annually, between six and eight of our ISO 14001 registered sites are audited for conformance to the ISO 50001 standard.

On an annual basis, using a sampling approach, the registrar audits between 15 and 25 of IBM's ISO 14001 registered entities to verify energy savings calculations from conservation projects and to validate the accuracy of the energy bill data entry process. The audited entities typically cover 30-60 percent of IBM's global annual energy consumption. During these audits, the registrar tests a sample of the energy consumption records in the enterprise-wide database, comparing the consumption values on the energy bill to the database entries. The audits provide an independent check on the accuracy of energy data and greenhouse gas (GHG) emissions reporting by IBM locations globally. The results of this testing are used in a separate validation audit of the corporate GHG emissions reporting process and data. The results of the latest audits can be found on the IBM environmental reporting, disclosure and verification webpage.

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 applicable 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 2014, a total of 11 accidental releases of substances to the environment related to IBM operations were reported through EIRS. Of these, four were to air, five to land, and two to water.

Emissions to the air were four releases of refrigerants due to minor leaks in refrigeration systems. Releases to land were four releases of cooling tower water and one release of chilled water. Releases to water were two releases of chilled water containing additives. The root cause was investigated for all releases and corrective actions were taken as appropriate. None of the releases was 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 2014, IBM received 87 agency visits worldwide with two Administrative Citations issued by the San Jose Department of Environmental Services Watershed Protection Division as a result of two separate incidents at the same site. Both incidents involved an overflow of water from the cooling tower basin that reached nearby storm drains. IBM paid two fines totaling $1,125. Corrective actions were taken to prevent recurrence, including review and revision of site procedures, retraining of personnel, and installing additional automation.

IBM paid two additional fines in 2014 for two Notices of Violation (NOV) issued by the California Regional Water Quality Control Board (RWQCB) in September 2013 associated with groundwater remediation at a former IBM site. The NOVs were for effluent exceedances — one during a National Pollutant Discharge Elimination System (NPDES) sampling event in 2007, and the other resulting from a leak in a pipeline from an extraction well in 2012.The pipeline was repaired and reinforced immediately after the leak was detected. IBM paid two fines of $3,000 each for these incidents.

Over the past five years, IBM has paid seven fines with a total amount of $81,939.

Fines and penalties worldwide

($ in thousands)

2010 2011 2012 2013 2014
Number 0 0 3 0 4
Fines $0.0 $0.0 $74.8 $0.0 $7.1