ERM (Environmental Resources Management), an environmental and social consultancy, was asked by GSK to independently review its 2002 environment, health and safety (EHS) report. This is the second EHS performance report for GSK, following the 2001 report of baseline data and programmes, which was also reviewed by ERM.

Specifically we were asked to:

• Check that the information presented is accurate, and that it represents GSK's performance fairly.
• Critically review the scope, balance and interpretation of the information presented.
• Assess the effectiveness of the company's data management processes that have generated the 2002 data.
• Focus in more detail on 'bottom-up' reporting processes, to complement the focus last year on corporate processes for collating site data and calculating corporate performance data.

Activities
Between December 2002 and April 2003 we:

• Reviewed corporate processes for collating and verifying environmental and H&S data, including the use of logic tests to identify anomalies in reported data.
• Visited eight manufacturing and commercial sites for a one-day review, and conducted telephone interviews with both environmental and health and safety professionals at 14 further sites, to review site data monitoring, management and reporting. The sites chosen reflected GSK's global coverage and encompassed the full range of manufacturing and R&D operations, as well as some commercial facilities.
• Undertook a detailed desk-top review and telephone interviews with site personnel to focus specifically on emissions of volatile organic compounds (VOCs) for eight sites that contribute the most to total GSK VOC emissions. This activity was initiated after finding material data errors in VOC data during the site visits, in order to investigate the potential extent of such errors.
• Interviewed Corporate Environment, Health and Safety (CEHS) and Employee Health Management (EHM) personnel in order to review data management systems.
• Reviewed drafts of the 2002 report and discussed our findings with GSK.

Findings - Data Accuracy
In our opinion, the information presented is accurate and statements based on it give a balanced interpretation of GSK's EHS performance. The scope of the report is appropriate to the environmental, health and safety issues of relevance to GSK .

GSK has dedicated considerable effort at corporate and site level to establishing a robust process and web-based tools to collect and report accurate EHS data from all manufacturing and research and development facilities around the world, as well as health and safety data (and limited environmental data) from commercial and office facilities.

During our site visits, data review and focused VOC review, we found material data errors in the reporting of VOC releases to air and post-treatment Chemical Oxygen Demand (COD) in wastewater discharges. GSK took appropriate steps to resolve these errors to ensure accurate reporting in 2002 and amended the 2001 baseline to facilitate performance tracking in 2002 and beyond. We did not encounter material data errors relating to other EHS indicators.

The level and extent of data validation varies at site level. Despite the errors relating specifically to VOC and COD data, in general GSK has improved the effectiveness and efficiency of the corporate internal review process for ensuring the quality of site data, thereby eliminating the majority of errors in site data. Nonetheless, there is scope for further improvement to the corporate review process as well as to site level quality checks of data.

Findings - Data Management and Reporting
Significant improvements have been made in the data collation, management and reporting systems over the last 12 months. In particular, GSK has:

• Improved the definitions, guidance documents and technical instructions given to sites, resulting in greater consistency and accuracy of site reporting.
• Continued to improve the web-based data reporting and management systems tool.
• Collated data from additional commercial and office sites than in previous years.
• Developed additional tools for reviewing and interpreting the collated GSK data.
• Started to audit contract manufacturers and key suppliers against GSK's environmental, health and safety requirements.

The opportunity exists for sites to understand better their contribution towards GSK-wide performance and their roles in achieving group targets. To assist sites with this process, CEHS should provide more focused, timely feedback to sites from the internal data collation and reporting process.

Recommendations
With the development of additional tools to facilitate review of corporate EHS data and progress towards targets, we recommend that GSK focuses on:

• Strengthening sites' understanding of the corporate reporting requirements. In particular, improving key sites understanding of their roles in achieving corporate targets, in part through more focused information from CEHS and consultation with CEHS on prioritizing improvements.
• Further improving quality checking of site data, both by sites before it is submitted and by corporate reviewers after receipt of the data.

Finally, we look forward to seeing the benefits to GSK in 2003 of implementing planned processes for tracking progress towards targets, and, where necessary, reviewing and further developing plans for achieving the corporate EHS targets.

ERM
9th May 2003