Verification Statement
GSK selected ERM (Environmental Resources Management) from a group of qualified companies to serve only as the independent verifier of this report. ERM are not involved in developing our EHS programmes or processes or in correcting any deficiencies that they may uncover in the verification process.
ERM (Environmental Resources Management) was asked by GSK to independently review its 2003 Environment, Health and Safety (EHS) report. This is the third EHS report produced by GSK and verified by ERM. GSK has set EHS improvement targets to be met by 2005, and in our review this year we have focused on progress to date and reviewed GSK's processes for tracking progress against targets.
Objectives
The objectives of our review were to:
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Check that the information presented is accurate, and that it represents GSK's performance fairly;
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Critically review the completeness and relevance of the information presented; and
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Assess the effectiveness of GSK's data management systems.
Activities
Between November 2003 and April 2004, ERM:
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Reviewed GSK's processes for tracking progress against EHS targets.
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Interviewed personnel responsible for data collation, in Corporate Environmental Health and Safety (CEHS), and checked sample data.
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Reviewed data management and reporting, and performance changes, at a cross section of sites. This was done through eight site visits and ten telephone interviews. The sites selected included major contributors to group-wide performance data, from Research & development, Manufacturing and Commercial functions.
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Interviewed corporate representatives to obtain supporting information on programmes described in the 2003 EHS Report.
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Checked that the 2003 EHS report reflects our findings.
Overall Findings
Based on the activities we carried out, we believe that GSK's EHS Report is a fair and balanced representation of GSK's programmes and performance. Subject to the comments set out below, we believe that it covers the key issues that interested parties need to know to inform decision making (i.e. is relevant), does not avoid major issues (i.e. is complete), and that it fairly reflects GSK's EHS management and performance (i.e. is accurate).
Reporting Scope
GSK has broadened the scope of its reporting this year, to address in greater depth issues relating to the impact of its products; particularly the fate of pharmaceuticals in the environment. In addition, GSK has included limited reporting of the EHS performance of contract manufacturers and suppliers (this data was not included within the scope of ERM's review).
In this report, GSK compares EHS performance in 2003 against a 2001 baseline. We feel that GSK needs to describe more clearly the causes for emerging performance trends. Specifically, it needs to explain the extent to which performance trends result from production changes or improvement programmes at manufacturing sites.
Tracking Progress Against Targets
In 2003, GSK established a process for reviewing progress towards group targets. Manufacturing sites revised or renewed their improvement targets for key performance indicators, and took part in divisional meetings to discuss past performance. This process has enabled sites to share good practice on environmental improvement initiatives.
However, GSK has not determined whether achievement of the renewed targets set by their manufacturing sites will ensure that group environmental performance targets for 2005 are met.
Performance Data
Building on improvements made in 2002, GSK has made further significant improvements to data collation, management and reporting systems over the last 12 months. The most notable improvements include:
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A greater focus on material contributors, when checking site environmental data.
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Development of a training programme for site personnel to improve consistency and accuracy of reporting of health and safety data.
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Visits to major sites by the corporate environmental data reviewers, to better understand data and reporting challenges.
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A more detailed review and validation of site performance data by site EHS personnel at the sites, once it has been collated into the group KPIs.
In reviewing corporate databases and the draft EHS report, ERM identified a number of errors in performance data that were material in group terms. The errors resulted from miscalculations in corporate data collation spreadsheets that were newly developed during 2003. They included an error in the summation of energy consumption that had resulted in 4% over-reporting of total global warming potential. GSK resolved these errors to ensure accurate reporting in the 2003 EHS report.
Recommendations
We recommend that GSK:
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Reports more explicitly on the reasons for performance trends, by describing the relative influences of production changes and improvement programmes;
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Assesses whether achievement of the renewed site improvement targets will enable GSK to achieve its 2005 group performance targets; and
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Introduces independent, internal checking of the corporate data collation spreadsheets as a means of quality control
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Provides more interpretation of the performance data reported by contract manufacturers
ERM
April 2004
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