APPROACH

Environmental Management Systems Network has developed a systems approach to environmental management. This system consists of a set of tools, procedures, training and expertise which can be used to create programs tailored to meet the resources and objectives of specific companies or to "fine tune" existing programs. While our professionals have been closely involved in the development of ISO 14000 standards on environmental management and are working on implementation and certifications, we recognize that it is not "the answer" for everyone. It may involve significantly more effort and expense than a company wants or needs to undertake -- and may not address a company's immediate concerns. At the same time, a company may want to improve it's environmental management practices while establishing a structure for "easing into" ISO 14001, or it may just want to institute an environmental annual reporting program. Our approach to environmental management outlined in the attached materials is readily adaptable this sliding scale of needs. We can help design and implement an EMS, fine tune an existing EMS, install discrete system elements such as environmental reporting methodology, provide an independent "certification" of whether the system meets certain criteria (EMS or other), help a company "ease into" ISO 14001, or assist with formal third-party registration with the leading international registration agencies. Any of these options can be pursued in a manner that maximizes protection of sensitive information under attorney-client or work product privilege.

Independent Compliance Monitoring and Verification. Our system-based approach is adaptable to a methodology for verifying conformity with specific agreements, commitments and orders arising out of enforcement actions or similar initiatives. EMSNet personnel have supervised verification efforts and state and national multimedia and media-specific consent decrees and compliance orders. Additionally, EMSNet is working with national and state authorities to develop an EMS-based multi-media permitting approach for key facilities in highly scrutinized industry sectors.

Corporate Codes of Conduct and Social Responsibility.
Our professionals' practice has long emphasized skills in identifying developments of strategic interest to our clients. We've been closely following the changing global role of nongovernmental organizations (NGOs) -- which are coming to have an impact, in some contexts, more significant than that of governmental regulation. We have tracked and, at times, helped shape certain of the more significant new movements involving environmental health and safety and the sometimes more fuzzy fields of social accountability. We have worked with clients to develop strategies to anticipate and address concerns arising from these areas, have helped them select the correct path and determine how best to show that they are "doing the right thing." That selection requires a proper fit -- responding to a specific need with an efficient solution. For some, we have installed or refined social accountability systems. For others, we have identified effective ways to document records of achievement and otherwise enhance the company's image in ways consistent with company interests. And, for others, we have developed codes of conduct and established sourcing guidelines. One of the most important current developments -- of particular interest to companies marketing in Europe -- is CEPAA's new SA 8000 standard on Social Accountability. Our involvement in the early development and implementation of that standard may prove useful in responding to the growing consumer demand for assurance of appropriate workplace standards and other commitments of social responsibility. Finally, we are sometimes asked to handle a company's outreach efforts and direct interface with NGOs and we have the contacts and reputation to undertake that role.