EHS management system

Our Environment, health and safety management system builds on the foundation of our commitment and our principles of integrity: Standards of Business Conduct & Ethics. It provides the structure for implementing proactive sustainable business practices associated with our products and operations. Its threefold purpose is to ensure compliance with internal and external requirements, drive continuous improvement and support the company's strategy to be a global biopharmaceutical company helping patients prevail in their fight against serious disease. The Bristol Myers Squibb EHS management system encompasses the following elements:

General

Our companywide EHS management system provides the foundation for effective EHS governance in support of our overall business strategy. The EHS management system helps to:

• Ensure compliance with both internal and external EHS requirements
• Identify and manage EHS risks
• Drive continuous improvement
• Support implementation and review of our Corporate Environment, Health & Safety Policy.

We based the EHS management system on facility-level EHS programs supported by proactive business unit and corporate EHS functions. Specific requirements are in place to govern each functional level.

EHS & sustainability overarching governance

Our Mission and Commitment are fundamental elements of our corporate culture. They set forth our concern for the interests and expectations of our employees, shareholders, customers, suppliers, the communities and countries where we do business, and the world in which we live. Among other things, our Commitment is a formal commitment to conscientious citizenship. It supports environmental progress, a safe work environment and policies and practices that fully embody the responsibility, integrity and decency required of free enterprise.

The Board Committee on Directors and Corporate Governance (CDCG) has responsibility for oversight of social and public policy. The CDCG members are all independent directors. The CDCG charter enumerates the responsibility as considering matters relating to corporate social responsibility and public policy as a global corporate citizen. EHS and sustainability strategy are included within this scope. The CDCG determines the qualifications and expertise for Board membership and oversees performance.

Sustainability and its obligations are visible within the organization. The most senior position with operational responsibility for environmental, health, safety and sustainability aspects is the global head and vice president, EHS & Sustainability, who reports to the executive vice president, and general counsel. The executive vice president and general counsel reports to the CEO. Business unit presidents are held accountable for implementation of our Commitment and EHS Policy within their units. Sustainability is integrated into the different functions and operations. A senior level cross-functional Sustainability Council was established in 2009 to drive alignment and integration of current and emerging strategic sustainability priorities.

Bristol Myers Squibb has established an Office of Corporate Compliance headed by the chief compliance and ethics officer. The chief compliance officer reports directly to the CEO, and provides reports to the CEO, the chairman of the board, the executive vice president and general counsel, the Board of Directors and the Audit Committee.

The sustainability performance of the Company is reflected in the company’s annual economic, social and environmental reporting. Economic performance is covered in the Bristol Myers Squibb Annual Report. Progress against the Sustainability 2020 goals including detailed environmental metrics, has been communicated companywide and to external stakeholders through the Bristol Myers Squibb sustainability website. Social performance is also covered in the Foundation Annual Report. The global head and vice president, EHS & Sustainability meets with the Board of Directors to review performance and strategy on EHS and sustainability issues as requested by the Board.

EHS management leadership & accountability

To most efficiently meet EHS goals, objectives and expectations, we have clearly defined the responsibilities of corporate and facility-level management and EHS professionals, enabling us to meet internal EHS goals, objectives and expectations, and comply with EHS regulations. The global head and vice president, EHS & Sustainability (CEHSS) establishes an effective system to develop policies, directives and guidance. Internal documents include expectations for employees, contractors, suppliers and management. Our EHS Policy sets forth our commitment to conduct our business in a safe and environmentally sustainable manner. This policy was approved and signed by our CEO on August 4, 2010. Our EHS directives contain detailed information for our facilities and functional business areas. They address our EHS management system and form the basis of our EHS requirements worldwide. The directives may exceed local regulations.

We use a combination of key performance indicators, EHS metrics and goals to drive improvement, and publish global EHS performance results to inform stakeholders of our commitment and progress.

EHS strategy & planning

We develop and review EHS strategic plans to address resource requirements to meet regulatory requirements, capital plans and sustainability goals. Global EHS & Sustainability and business management provide the financial and human resources to maintain compliance, support programs, drive innovative leadership initiatives, review capital investments, and maintain and improve staff competencies to carry out their environment, health and safety responsibilities.

EHS risk identification & control

We have effective processes in place for risk identification, monitoring and mitigation, incident management related to employee and environmental protection, facilities and assets, products, compliance, reputation, EHS security-related matters, business continuity and communications.

Business continuity & emergency preparedness

We have established plans to address emergency preparedness and incident management response in support of EHS and business continuity. We strive to reduce the impact of events and minimize the potential for reoccurrence.

Change management

Effective systems are in place to address current and emerging regulations and standards, operational changes, global sustainability trends, process safety management, acquisitions and divestitures due diligence, and rapid new business integration to manage potential EHS impacts.

Corrective & preventive actions

To continually drive improvement, we maintain corrective and preventive action systems for action plan development, tracking performance and completion in support of the evaluation/audit program and in response to EHS incidents.

Product stewardship

We maintain a system to continuously review and improve the environmental impacts and safety of our operations and products.

Supply chain partner management

We recognize that third parties have an important role in our success. We maintain a system to identify and resolve supply chain EHS risks, such as regulatory, distribution, hazardous materials transportation and third-party manufacturing. We strive to conduct business only with third parties who share our commitment to our Standards of Business Conduct and Ethics for Third Parties (3P Standards). We encourage third parties to adopt and apply the 3P Standards, and to have processes and/or systems in place to support operating in compliance with all applicable laws, regulations, guidelines and industry codes. Specific requirements for adherence to the 3P Standards are included in contracts with third parties.

Compliance & self-assessment process

Our company’s audit processes include independent and objective corporate audits of environment, health, safety and transportation compliance, and adequacy of EHS management systems to support on-going compliance; and facility self-assessments of compliance and possible need for changes in site procedures.

The EHS audit function, within the Global Environmental, Health, Safety and Sustainability Department, has the responsibility to plan and conduct the audits, train and select team auditors, report audit results to management and monitor action plans through closure.

All manufacturing, research and development facilities, as well as distribution and office locations, are evaluated based on a criticality index of risk and maturity of facility management systems. The frequency of audits range from 18 to 24 months for manufacturing facilities, 24 to 36 months for research and development and finishing and packaging facilities, and 36 to 48 months for offices, warehouses and distribution facilities. Corrective and preventive action (CAPA) plans are developed and implemented to close open EHS audit findings. The CAPAs are tracked by an internal automated system and the lead evaluator of the audit until closure.

Verification of closed audit CAPAs are also routinely conducted during the year at facilities that pose the highest risk. In addition, all CAPAs at all facility locations are verified during the next audit cycle.

One method of maintaining a system for quality assurance of our EHS audit process is to periodically secure the services of an independent third party EHS audit firm to conduct an audit of the BMS Audit Program. The objective of this review is to determine if internal BMS EHS audit systems are functioning effectively to maintain and continually improve EHS performance, and verify that the EHS Audit Program is operating in conformance with established procedures and selected external consensus standards. A copy of the most recent audit attestation letter can be found on our Verification statements page.

Guidelines addressing contract manufacturers and suppliers require business units to conduct EHS assessments of the facilities and operating practices of contract manufacturers and selected suppliers. See our suppliers page for more information.

Continuous improvement & learning

We review and update the EHS Policy, EHS management system, EHS directives and company programs as appropriate to ensure their continued effectiveness. Results of EHS audits are used to maintain and continuously improve EHS performance company-wide. There is a process for employees to report workplace EHS issues and concerns. Additionally, we encourage dialogue with employees through educational initiatives and functional and cross-functional committees. Externally, we actively seek to engage with stakeholders.

EHS training and awareness programs are provided to address the policy, goals, technical and professional subject matter, and the importance of complying with EHS regulatory and company requirements.

Employees and contractors working at our facilities are educated and trained to conduct their activities safely and in an environmentally responsible manner.

We provide guidelines for training both new and experienced employees. In addition, facility environmental coordinators and other full-time EHS professionals must complete, at company expense, annual EHS training related to their job assignments. Other company education initiatives include corporate and divisional intranet websites, employee publications, functional and cross-functional group meetings, management awareness training, and topic-specific training and manuals.

Among the training provided, Bristol Myers Squibb regularly holds learning and development webinars on a variety of technical EHS topics. The sessions are targeted to EHS and related staff (e.g., engineering and maintenance) globally.

By using webinar technology, staff can actively participate in the training sessions, ask questions and discuss topics. The webinars eliminate the need to travel while providing staff worldwide with access to EHS training on a regular basis. Through a formal survey, 100 percent of responders indicated the sessions met or exceeded their expectations and were applicable or useful to their jobs.