Third-Party Evaluation of DuPont’s Corporate Safety, Health and Environment (SHE) Audit Program

2012 Executive Summary

Environmental Resources Management (ERM) conducted an evaluation of DuPont's SHE Audit Program directed by the Corporate SHE and Sustainable Growth Center and implemented by the Company's four Global Regions. ERM evaluated the elements and performance of the Program in order to render an independent opinion about its effectiveness in achieving improved SHE performance throughout the Company. The assessment was conducted between January 2012 and February 2013 and included a review of Program documentation, interviews with Program Managers and staff, selected interviews with site representatives who have been subject to the audits and observation of six audits, two in Asia Pacific, three in the U.S., and one in Europe.

The Program was evaluated against three sets of criteria: (1) external expectations set by organizations with standing in the SHE audit community (e.g., the Board of Environmental, Health and Safety Auditor Certifications (BEAC), the International Organization for Standardization (ISO), and The Auditing Roundtable (TAR)), (2) DuPont’s internal SHE auditing standard, and (3) generally accepted audit practices in comparable companies. ERM reviewed the scope and elements of the Program, the procedures utilized, the resources applied to implement the Program and the degree and quality of management commitment. Based on the information made available to ERM by DuPont, ERM has concluded that DuPont's Program is generally consistent with, and in some cases, exceeds expectations of the established criteria. In our opinion, the Program provides competent, reliable and objective information to management about the status of the Company's SHE compliance programs and performance. Further, DuPont's management is responsive in correcting deficiencies when they are identified by the Program audits.

As shown in Table 1, three of the Program’s elements, top management support, written audit procedures and quality assurance, are quite advanced when compared to practices in other companies. Management commits the resources to assure that 98% of the almost 600 annual competency audits are conducted as scheduled and that over 96% of corrective actions are closed on time. Further, there is a governing corporate standard for the program and many supporting tools, including software that can conduct very sophisticated analyses of the program results and key performance metrics. The Program also receives substantial internal and external oversight and quality assurance reviews annually. And finally, the year 2012 was the seventh consecutive time, in the seventeen years of the annual evaluation, that all elements achieved at least a “fully meets” score.

Notwithstanding these achievements, there are aspects of the Program and audits that could be improved. Management has been informed of these areas in need of improvement and is taking steps to address them. It should be noted that a seventeen year-trend analysis indicates that solid, sustainable performance has been achieved in the past decade.

TABLE 1

Summary of the Program Evaluation

PROGRAM EVALUATION CRITERIA / Partially Meets Expectations / Fully Meets Expectations / Exceeds Expectations
1. Explicit Top Management Support / ü
2. Program and Auditor Independence / ü
3. Appropriate Audit Team Staffing / ü
4. Comprehensive Written Audit Procedures / ü
5. Defined Program Objectives and Scope / ü
6. Adequate Program Resources / ü
7. Audit Frequency Based on Risk / ü
8. Appropriate Audit Process / ü
9. Documentation of Audit Findings / ü
10. Resolution of Corrective Actions / ü
11. Appropriate Quality Assurance Measures / ü