Environmental product compliance
We have rigorous processes and procedures to ensure that our products comply with environmental standards and requirements, and since 2014 we have integrated environmental product compliance into our Supplier Code of Conduct. New suppliers are screened for environmental compliance during the Request for Information or Request for Proposal (RFI/RFP) phase. In addition, we stipulate environmental compliance in contracts, supplier standards and specifications. Approved suppliers are required to provide data into our Product Compliance Database, and are trained in database use and regulatory requirements.
To manage and support these initiatives, we have two cross-functional teams: The Product Compliance Team (PCT) and the Environmental Committee (EC). The Product Compliance Team includes representatives from Procurement, Supply Chain, Quality, Engineering, Environmental Health and Safety (EHS), Finance, Global Product Line Management and other support groups. The Environmental Committee, which oversees the work of the PCT, is made up of managers holding senior positions in Procurement, Global Supply Chain, Engineering, EHS, Quality, Ethics and Business Practices, Legal, Finance, Business Continuity, Global Product Line Management, Enterprise Risk and Internal Audit. In addition to providing guidance, the Environmental Committee authorises the financial and human resources needed, enforces corrective measures both within the company and with our supply chain, and reports potential issues to the Enterprise Risk Management team.
The PCT and EC are tasked with identifying risk associated with non-compliance with regulations, supplier non-response and product types. Risks are evaluated for frequency and severity by the PCT and formally documented as per our product compliance procedures.
We identify and prioritise risks in our supply chain by assessing supplier data. Suppliers considered higher risk are escalated to designated internal teams and management for further evaluation.
Chemical Product Review Team
We also have a team that reviews and approves new chemical products prior to sale, to ensure they meet the safety requirements for Pitney Bowes, have appropriate safety datasheets (SDS) and are properly tracked for regulatory reporting. Over the past three years, the team has been working to transition our SDS to align with the United Nations Globally Harmonised System of Classification and Labelling of Chemicals. The new 16-section SDS and labels will allow our customers and employees to better classify, communicate and understand chemical hazards. They will include easy-to-read pictograms (see examples below) to indicate the specific nature of the associated hazard. Our safety data sheets can be found at the following link: http://pitneybowes.msdss.com.
Environmental Compliance Training
We believe that in order to ensure compliance throughout the company, employees must have awareness and a strong sense of ownership. To that end, we have enhanced our training programme to include online, automated, annual training in addition to in-person training events. This training allows us to reach larger audiences, train new employees in a timely manner, make it more convenient for employees to schedule, track completion rates and ensure attendance. Last year we trained more than 400 employees via the online module.
Regulatory Reporting and Data Management
We have processes and programmes in place to ensure accurate and consistent regulatory reporting. Regulatory report deadlines and requirement summaries are maintained in a Compliance Calendar. This system documents the assignment of responsible individuals, alerts stakeholders to approaching deadlines, stores reports with associated data and provides monthly email notification to management regarding upcoming deadlines, submittal status and completion dates.