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 →The Elm Consulting Group International LLC has released a new revision to the Self Implemented Conflict Minerals Audit Preparation Tool. The update, Revision 1.33, incorporates Minor changes in response to feedback obtained from the late June EICC Extractives Supply Chain Workshop VI in Washington DC; Further clarifications on the OECD framework, its relationship to SICMAP℠ and SEC auditor standards; and Related elements of California Transparency in Supply Chains Act of 2010. Lawrence M. Heim, CPEA, is leading the firm’s conflict minerals services and SICMAP℠ development: In our discussions with various companies and workshop attendees, we obtained feedback on a few minor changes and clarifications to improve the tool. In addition, we decided to incorporate the new California law as there are many similarities between those mandates and the conflict minerals requirements. The video introduction and overview of SICMAP℠ can be viewed here.
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 →. FOR AN UPDATE ON SEC’S DELAY OF THE FINAL RULE, CLICK HERE. As veterans of regulatory research, we are accustomed to spending hours poring over a plethora of governmental regulations, background documents, guidance and other reports. Our work with conflict minerals supply chain traceability and SEC’s regulations has been no different. In addition to having completed such audits, we have read and re-read the proposed SEC regulation and its preamble; the OECD Due Diligence Guidance for Responsible Supply Chains of Materials from Conflict-Affected and High Risk Areas, and the Supplement on Tin, Tantalum and Tungsten; the ISO 19011 standard; comments submitted to the SEC on the proposed regulation (approximately 700 total comments were submitted, of which 433 were standard form letters. Of the remaining 270, approximately 75% provide substantive content); hundreds of relevant media reports, legal advisories and NGO documents; various auditor standards under SEC, including Government Accounting Office Government Accounting Standards GAO-07-731G, AICPA Statements on Standards for Attestation Engagements (SSAEs); and industry commentary and alerts on the topic. Yesterday, we completed an analysis of the 263-page report from the Boston Consulting Group (BCG) titled US Securities and Exchange Commission Organizational Study and ReformMarch 10, 2011 to see what
Read more →Elm is featured in today’s issue of the on-line news source Mashable for our innovative use of the iPad for HSE auditing. The article can be read here. With a reported 30+ million monthly pageviews and an Alexa ranking under 250, Mashable ranks as one of the world’s largest websites. The website has a large following on many social networks. As of February 2011, it has over 2 million Twitter followers and over 425,000 fans on Facebook.
Read more →Join us for an upcoming webinar Friday, February 25 about using the iPad in HSE audits. We will present an overview of our experiences in using the device on actual audits over the past 6 months. Included in the presentation will be a discussion of evaluating its potential use and fit within organizations/existing audit processes; benefits and limitations; and a detailed step-by-step simulation of an audit using Elm’s selected application (smartNotes), including actual screen shots. The hour-long presentation will be followed by an open question and answer period. Click here for a full description. There will be a morning session and an afternoon session. Click here for the afternoon session. We hope you can participate.
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
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