For years, those of us in the environmental/sustainability profession have sought credible ways and metrics for quantifying the economic value of our efforts, activities and programs. A myriad of studies completed dating back to the late 1980s attempt to demonstrate “environmental value”. Most of these studies have shown rather tenuous linkages or used meaningless metrics. Interestingly, most of these studies link to equity markets – i.e., stock prices. Maybe because stock prices grab headlines, are tied to compensation or are the target to which Boards and senior executive generally manage. The problem is that environmental/sustainability matters don’t fit into this model, either because they tend not to be financially material, or they don’t develop economic certainty within the “current quarter” myopia of corporate management, financial markets and analysts. A recent article on the topic was published in The International News. The article includes an interview with Kevin Parker, CEO of Deutsche Asset Management (DeAM) on the subject of how capital markets currently view environmental/sustainability risks. DeAM manages over US$775 billion in assets. With simplicity, clarity and unquestionable credibility from the financial market viewpoint, Parker made key points in the article and interview: Bond markets are poised to punish polluting companies
Read more →Last Friday, the US State Department issued its statement on conflict minerals supply chain traceability. Section 1502 of the Dodd-Frank Act requires that the State Department – in parallel with the SEC – provide guidance on due diligence activities to companies. The Department stated that … it is critical that companies begin now to perform meaningful due diligence with respect to conflict minerals. To this end, companies should begin immediately to structure their supply chain relationships in a responsible and productive manner to encourage legitimate, conflict-free trade, including conflict-free minerals sourced from the DRC and the Great Lakes region. Doing so will facilitate useful disclosures under Section 1502, as well as effective responses to any discovery of benefit to armed groups. The Department specifically endorses the guidance issued by the Organization for Economic Cooperation and Development (OECD) and encourages companies to draw upon this guidance as they establish their due diligence practices. We encourage companies, whether or not they are subject to the Section 1502 disclosure requirement, that are within the supply chain of these minerals to exercise due diligence based on the OECD guidance and framework as a means of responding to requests from subject suppliers and customers. Companies
Read more →It is not uncommon for EHS auditors to be asked (or ask themselves) “If you find a noncompliance during your audit, do you report it to the regulators?” The answer depends on the company and audit program, but a recent news item caught our attention due to a variation on the theme. We have no information other than what is publicly available here, but it appears that an organization managing a voluntary electronic waste management certification program found alleged significant non-conformities at a specific company seeking certification. As a result, the organization declined to issue its certification to that company. So far, so good, but the story doesn’t end there… In its declination letter to the company, the organization states: Further, there is substantial reason to believe that such exports may violate Public Act 095-0959 (Electronic Products Recycling and Reuse Act, recycler requirements) of the State of Illinois, the Federal CRT Rule, (40 CFR Parts 9, 260, 261, 271; Cathode Ray Tubes; Final Rule) as well as the waste importation laws of Hong Kong/China. Further, while it is not our policy to disclose the results of certifying body audits, we can state that the audit only further substantiated all of
Read more →Updated March 2012: See our most recent announcement. The Elm Consulting Group International LLC today announces a groundbreaking cost effective tool to support companies preparing for conflict minerals traceability audits or customer inquiries. The delay in SEC’s final rule triggered many questions from companies about planning and pre-audit preparation. This led us to a solution that is valuable in almost any foreseeable final regulation scope/content and companies planning responses to customer inquiries – yet significantly reduces costs during this period of uncertainty. Elm’s Self-Implemented Conflict Minerals Audit Preparation© (SICMAP℠) is conceptually similar to a self-audit checklist. SICMAP℠ is a spreadsheet tool that maximizes the use of internal company staff for cost reduction and implementation flexibility to develop and review conflict minerals programs in advance of third party auditing. SICMAP℠ focuses on basic program elements equally relevant to companies responding to customer inquiries/procurement requirements and those working to comply with the upcoming SEC regulations on conflict minerals. Successive and more complex tasks – for both program development and audit preparation – are identified based on initial SICMAP℠ findings, lessons learned from working through the SICMAP℠ process, and the final regulatory requirements once they are known. The final rule, when published, will
Read more →On Tuesday May 31, The Elm Consulting Group International LLC will formally announce a major development in our conflict minerals traceability services. Lawrence Heim, Elm Director and leader of the firm’s conflict minerals services: SEC’s delay in promulgating their final conflict minerals rule has resulted in a significant amount of uncertainty within affected companies. Many of these companies are challenged by cost constraints as they seek information, guidance and solutions to yet-unknown compliance standards. Our announcement next week provides a highly cost-effective solution in balancing these challenges. If you would like to receive the announcement and related information directly, send an email to Lheim@elmgroup.com.
Read more →The new issue of iPhoneLife magazine highlights Elm’s use of iPads for environmental, health and safety audits in a short feature. Unfortunately, the article indicates we use them for energy audits, which is not the case. We have contacted the editor to inform them of their error. Interestingly enough, the current issue also reviews various notetaking apps for anyone interested in reading up on the subject.
Read more →A little more that a week ago, Elm received information from two independent sources that SEC was not going to publish the final Conflict Minerals regulations by the statutory deadline of April 15, 2011. Today, this was confirmed by information on SEC’s website. At this time, SEC’s anticipated date range for the final rules is August to December 2011. Although the delay extends the uncertainty of specifically what the requirements will entail, it provides impacted companies a much-needed expanded window of opportunity to plan basic program elements and begin specific communications with suppliers and customers. One key element of compliance that won’t change is the complexity of structuring a supply chain-oriented audit program. We have written on this matter several times in the past and continue to counsel clients to begin this planning as soon as possible, and defer any auditing until this has been carefully considered. Some of our earlier comments on the risks of moving forward in the absence of planning are perhaps even more relevant given the rule’s delay: Companies directly regulated by SEC. Audits conducted “pre-rule” risk being non-compliant with the final SEC requirements. Early adopters may be faced with paying for audits a second time
Read more →The Elm Consulting Group International LLC, a specialty health, safety, environmental and sustainability (HSES) management consulting firm, is pleased to announce the addition of Joseph B. Cotier, CPEA as a Director of the firm beginning January 3, 2011. “Joe brings 22 years experience in HSE auditing excellence and client focus to our team” said Patrick Doyle, Elm’s founder and Managing Director. “He is a perfect complement to the firm.” “I have known Joe personally and professionally for close to 20 years and know first hand about his expertise and exemplary qualifications. We are very excited to have him become a part of Elm” said Robert Bray, Elm Co-Founder and Managing Director. Cotier said, “I am happy to be a part of Elm and look forward to continuing to have a positive impact on the HSE auditing field – driving innovation both in the US and across the globe.” Joseph B. Cotier, CPEA, has completed more than 350 EHS audits and management systems consulting projects in more than 35 states and 20 countries. He has experience in a wide range of industries including petroleum refining and chemical manufacturing, electric utilities, breweries and consumer and pharmaceutical products manufacturing. Mr. Cotier is an
Read more →We recently announced our trial of and results from using an iPad for EHS auditing. These articles were intentionally short and provided summary information. We were subsequently contacted by the Editor of EHS Journal to provide a more detailed article for their respected publication. That article is now available. We invite you to read it.
Read more →The Elm Group International, LLC is accepting entries for a drawing to win an environmental compliance audit priced at $1.00 fixed rate for labor fees. The contest winner gets 5 consecutive days of one Elm staff member’s time to conduct an environmental compliance audit in the U.S – for $1.00 in labor cost. The rules and limitations (posted in the entry form) set forth the details of this offer. Patrick Doyle, founder of Elm: “Elm has been financially successful ever since its founding in 2003. Even in the midst of the worst global economic collapse since the 1930s, Elm posted record revenues in 2009. In light of that, we wanted to have some fun in 2010. Part of that was investing in new technology such as the iPad, which proved to be very successful in the field. This give-away is another opportunity for us to have fun, while also providing real benefit to the winner.” “There is a bit of a thrill in this for us,” said Lawrence Heim of Elm’s Georgia operations. “We certainly don’t know what type of company or site will win and I have no idea where I will be traveling to for this assignment.” “I
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