Verification Statements Assessment of GRI G3 Application Level

Haley & Aldrich, Inc. has completed an independent, third party review of the 2008 Bristol-Myers Squibb Web-based Sustainability Report against the Global Reporting Initiative G3 Sustainability Reporting Guidelines Version 3.0. The purpose of this assurance engagement was to:

  • Verify the 2007 environmental results of Bristol-Myers Squibb Key Performance Indicators contained in the online sustainability report, and identify the strengths and weaknesses of the underlying systems and programs to support the data presented in the online report.
  • Review Bristol-Myers Squibb sustainability website content that reports overall sustainability performance to assess whether Bristol-Myers Squibb conforms to the G3 reporting guidelines and application level B.

We found that Bristol-Myers Squibb has satisfactorily applied the GRI Reporting Framework, meets the report content requirements as specified by G3, and fulfills the spirit of the Principles concerning Report Content, Report Quality, and Boundary Setting. In our opinion, the content provided for the 2008 Bristol-Myers Squibb Web-based Sustainability Report meets the content and quality requirements of Global Reporting Initiative G3 Version 3.0 Application Level B+.

A copy of the letter detailing the results of this assessment is available here (PDF: 40 KB).

EHS Evaluation Program Attestation

The Cadmus Group, Inc. (Cadmus) was requested by Bristol-Myers Squibb Company (BMS) to verify that the Environment, Health and Safety (EHS) Evaluation Program as described in Corporate EHS Evaluation Technical Standard (ADM-018), is being implemented according to the requirements established in its internal standard and to assess how the program compares to general industry and pharmaceutical company practices.

Cadmus’ review of BMS’ EHS Evaluation Program was based on information obtained from interviews with BMS management and EHS personnel, review of documentation associated with the program, and observation of the EHS field evaluation activities. The data gathering was undertaken during January through March 2007.

In Cadmus’ opinion, the EHS Evaluation Program is viewed by BMS personnel as the company’s compliance authority communicating and supporting external and internal EHS regulatory business obligations. It continues to be a leading audit program relative to general industry standards of performance and is designed and implemented in a manner that is consistent with the provisions of ADM-018. Our opinion is based on the following:

  • Commitment to Assess EHS Performance: BMS places a high priority on assessing and identifying opportunities for improving EHS performance across the organization. This is accomplished through the continued allocation of sufficient resources at the corporate level to plan for and conduct detailed facility reviews, the use of internal team evaluators or outside consultants, and the time allocated on-site to review compliance programs. The allocation of resources to assess EHS performance is a practice that clearly places the BMS program among leading audit programs.
  • Compliance Driver: The EHS Evaluation Program is viewed by BMS staff as one of the principle drivers of compliance performance throughout the company. The linkage between auditing and performance improvement is embedded throughout EHS Evaluation Program processes and facility activities.
  • Competency of Resources: BMS places a high premium on the quality and competency of both internal and external team members to enable the sharing of best practices and regulatory knowledge during the evaluation process. Company personnel noted that the quality of the team members was quite good and firmly support the internal team evaluator program. In-fact, the team evaluator program is viewed by BMS staff as an excellent vehicle to embed EHS knowledge into the line organization and to extract best practices across the organization. The emphasis on the quality and competency of evaluation team resources is an exemplary practice.
  • Adherence to ADM-018: The Lead Evaluators and members of the team adhere to the process of conducting evaluations as outlined in the technical standard. Each step is well planned and executed. Facility personnel commented that the process is consistently implemented and well understood. The professional nature of the onsite evaluation process is an exemplary practice.
  • Preparation and Approval of Action Plans. A detailed set of procedures have been established to prepare, approve, close, and verify that corrective actions are being undertaken to address identified audit findings. The interaction between the Lead Evaluators and the facility in preparing, approving, closing, and verifying evaluation findings is an exemplary practice relative to general industry and pharmaceutical audit practices.
  • Continuous Improvement: The EHS Evaluation Program has implemented a number of actions to continuously improve upon audit program strategies. These activities include the use of an Audit Opinion to help management understand facility audit results, the rollout of TrackWise®–an electronic audit tool, modification of the annual evaluation schedule, and review and update of ADM-018.

In conducting our review, Cadmus noted that several issues associated with the implementation of auditing activities have emerged over the past year. These issues include facility audit scope, an organizational focus on the number of findings instead of a focus on overall EHS performance, resource development process, and the role of the EHS Evaluation Program relative to BMS EHS Directives. We believe these issues should be explored and strategies and tactics adopted by EHS Evaluation Program staff to stay on the leading edge of delivering value to BMS.

The Cadmus Group, Inc.
May 2007