EMS Plan

Introduction



Sedona Inc, dba Sedona Technologies is a technology consulting company providing IT and Engineering services. Throughout this document, Sedona Inc. will be referred to as Sedona Technologies. Sedona Technologies is located in Moline, Illinois. The greater Quad Cities area is the region of boundaries this system encompasses. Most of our consultants, however, are co-located at the customer site. This policy will align with the EICC Code of Conduct and/or IBM's Supplier Code of Conduct Principles.

Sedona Technologies is a consumer of products and resources rather than a manufacturer of such items. In that respect, Sedona Technologies is on the consumer end of the supply chain. Sedona Technologies has broken down the environmental aspect into two different areas, consumption and disposal. The consumption aspect falls into two categories: supplies and energy.

Sedona Technologies is currently in the planning and development stages to put in place an Environmental Management System (EMS). Our EMS plan will align with the Environmental Protection Agency’s guidelines, which are as follows:

Plan: Planning, including identifying environmental aspects and establishing goals

Do: Implementing, including training and operational controls

Check: Checking, including monitoring and corrective action

Act: Reviewing, including progress reviews and acting to make needed changes to the EMS.

Compliance Plan

The following outline demonstrates how Sedona Technologies developing EMS will align with IBM’s stated supplier requirements:

IBM Requirement #1

Define, deploy, and sustain a corporate responsibility and environmental management system that identifies significant aspects of the supplier's intersections with these matters, including those articulated in the Electronic Industry Citizenship Coalition Code of Conduct (EICC) and/or IBM's Supplier Code of Conduct Principles.

Sedona Technologies Compliance: The fulfillment of requirements 2-8 will satisfy the need for an environmental management system. Additionally, Sedona Technologies will post a sustainability statement on our website. The code of conduct requirement will be fulfilled by posting a list of principles similar to IBM’s Supplier Code of Conduct Principles.

IBM Requirement #2

Establish programs (within the management system) to control operations that intersect with these matters and confirm compliance with applicable law, regulation and any particular contractual requirements.

Sedona Technologies Compliance: Sedona Technologies will comply with this requirement through deployment of the EMS and supporting initiatives while being compliant with the law.

IBM Requirement #3

Measure performance associated with supplier's significant environmental aspects where applicable and include at a minimum each of the following aspects common to virtually all businesses:

• Energy conservation
• Scope 1 and scope 2 greenhouse gas emissions
• Waste management and recycling.

Sedona Technologies Compliance: Sedona Technologies will establish an accurate baseline for energy usage in a 12-month period in order to address seasonal trending. The baseline period will be defined as January 2011 to December 2011.

Energy Consumption

• Electric – Kilowatts consumed
• Gas – Therms consumed

Calculate Scope 1 greenhouse gas emissions

• Electric – Calculate CO2 generated from electricity usage
• Gas – Calculate CO2 generated from gas usage

Calculate Scope 2 greenhouse gas emissions

• Electric – Contact utility to determine scope 2 impact
• Gas – Contact utility to determine scope 2 impact

Waste management and Recycling

• Recycling Volume – Amount of recycling material picked up by recycling company will lead to waste volume reduction in tons of trash picked up by the garbage company.

IBM Requirement #4

Set voluntary environmental goals to achieve positive results associated with significant aspects where applicable and include at a minimum one in each of the three aspects:



• Energy conservation
• Scope 2 greenhouse gas emissions
• Waste management and recycling.

Sedona Technologies Compliance: Working off the baseline established in requirement #3, Sedona Technologies will set one goal in each category. The goal measuring period will be 12 months. Progress will be tracked on a quarterly basis (i.e. January 2011 versus January 2012) to account for seasonal variances.

Goals will be determined in conjunction with Sedona Technologies Management, and follow the format below:

Energy Consumption

• Reduce consumption of electricity 1% by 2014

Scope 2 greenhouse gas emissions

• Reduce scope 1 GHG emissions from electricity usage 1% by 2014.

Waste management and recycling

• Increase pounds of recycled material to 3% by 2014.

IBM Requirement #5

Publicly disclose results associated with these voluntary environmental goals and other environmental aspects from the management system, including any regulatory fines or penalties that may have occurred.

Sedona Technologies Compliance: The Sedona Technologies website will be used to publish a mini-sustainability report.

IBM Requirement #6

Train employees who are responsible for performing this work.

Sedona Technologies Compliance: Once the EMS has been established, Sedona Technologies will share the contents and our goals for environmental conservation with all employees who interface with the services we provide to IBM. Employees will be required to review the content and acknowledge that they will support the EMS through actions such as making sure all paper is recycled, trash is minimized, etc.

IBM Requirement #7

Conduct self-assessments and audits as well as management reviews.

Sedona Technologies Compliance: Sedona Technologies will form a committee that meets on a quarterly basis. This committee will review the progress of reduction initiatives against our EMS goals, discuss any need for redirection, etc. The suggested roster for the committee is as follows:

Management Representative
Human Resources Representative
Account Manager
Environmental representative

IBM Requirement #8

Cascade this set of requirements to the supplier's suppliers who perform work that is material to the products, parts and/or services being supplied to IBM.

Sedona Technologies Compliance: Sedona Technologies will publish our EMS Plan and other applicable documents on our website and notify appropriate vendors. Suppliers who perform work that is material to the services provided to IBM, will be encouraged to establish their own EMS programs within their respective organizations.

Timeline

Sedona Technologies EMS Plan is on target to be deployed on or before March 31, 2012.