Verification Statements

Assessment of GRI G3 Application Level

Haley & Aldrich has completed an independent, third party review of the Bristol-Myers Squibb Web-based Sustainability Report as of November 16, 2006 against the Global Reporting Initiative G3 Sustainability Reporting Guidelines Version 3.0. The purpose of this assurance engagement was to ascertain whether Bristol-Myers Squibb fulfilled the reporting requirements of 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 Bristol-Myers Squibb Web-based Sustainability Report, as of November 16, 2006, 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 (44k PDF).

Assessment of the Information Collection System

Haley & Aldrich has completed an independent third-party assessment of Bristol-Myers Squibb Company’s progress in addressing findings from a 2005 assessment of the BMS (2003) Sustainability Report. Haley & Aldrich staff reviewed findings from the assessment, conducted interviews of key program management personnel, and examined supporting documents to develop this progress summary.

Overall, BMS continues to show strong corporate efforts to ensure that sustainability reporting is transparent and effective. These efforts represent their commitment to identify and understand material social, environmental and economic performance and impacts, and to ensure the efforts are complete and responsive. In fact, the company’s core values – as embodied in the Bristol-Myers Squibb Pledge – center on sustaining and improving the lives of people throughout the world.

A copy of the letter detailing the results of this assessment is available here (230k PDF).

Assessment of the Corporate EHS Evaluation Program

Clayton Group Services (Clayton) was requested by Bristol-Myers Squibb Company (BMS), as described in Corporate EHS Evaluation Technical Standard (ADM-018), to verify that the BMS EHS Evaluation process 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. Clayton’s 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 field observation of the EHS Evaluation Process.

In Clayton’s opinion, BMS’s EHS Evaluation Program is designed and implemented in a manner that is consistent with the provisions of ADM-018 and general industry standards of performance, and exhibits several exemplary practices relative to general industry and pharmaceutical audit practices. Furthermore, the Evaluation Program is taken seriously within the company and is a key element of BMS’ overall corporate governance process.

Our opinion is based on the following:

Close Adherence to ADM-018: The lead evaluators and members of the team embrace the process of conducting evaluations with each step well planned and executed in accordance with internal standards. Facility personnel commented that the process is consistently implemented.
Program Clarity: Significant efforts have been made by BMS EHS Evaluation Program Management to clearly communicate the structure of the evaluation process, to define the purpose and scope of the program, and to share the tools developed for conducting evaluations. As a consequence, the Evaluation Program is well understood and accepted within the company.
Emphasis on the Quality and Competency of Resources: The technical competency and the open style of the lead evaluators in discussing and evaluating compliance practices are valued by facility EHS personnel and considered a real strength of the program. Furthermore, 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. The emphasis on the quality and competency of resources is an exemplary practice.
In-depth Review of Compliance Programs: BMS allocates an appropriate number of resources to conduct EHS evaluations so as to develop a detailed portrait of facility compliance performance. Moreover, the facilities perceive the Evaluation Process as one of the drivers of compliance within the company because of the importance placed on verification and action plan follow-up. The focus on compliance through the allocation of appropriate team resources coupled with the detailed review of facility EHS programs is an exemplary practice.
Focus on the Approval, Verification, and Closure of Action Plan: The approval, verification, and closure of action plans by Evaluation Program staff are unique aspects of the overall Evaluation Process. The approval processes ensures that the corrective actions reflect the issues identified during evaluations; the process for verification prior to closure of the action plans helps ensure long-term sustainability of EHS compliance improvements. The focus on action plans is an exemplary practice.

We also made three recommendations that expand upon the value-added features of the Evaluation Program. These include expanding the audit opinion in the evaluation reports, moderating the audit schedule to help ensure continued performance of the several features of the program that are highly valued by BMS management and facility personnel, and extending the process for sharing best practices within the company.

Clayton Group Services
January 2005

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