Environmental Management System

General Requirements

Sedona Inc. dba Sedona Technologies is a software development company that is located in Moline, IL. Most of our consultants, however, are co-located at the customer site. This is the region of boundaries this system encompasses. This policy will align with the EICC Code of Conduct and/or IBM's Supplier Code of Conduct Principles.

Environmental Policy

Sedona Technologies is a consulting company that provides professional and consulting services focused on the development and marketing of intellectual capital, as well as temporary, permanent and outsourced personnel staffing. In addition, Sedona Technologies and its employees will comply with this environmental management system policy, understanding that we are a provider of software and services. As Sedona is not a manufacturing organization, there are no associated governmental regulations, contractual requirements, pollution prevention, substantial energy conservation, or special waste disposal requirements. The major positive impact we can have on the environment is lifestyle actions because Sedona is a consumer of products and resources rather than a manufacturer of such items.

Environmental Aspects

While the scope of Sedona Technologies business model and footprint is on a much smaller scale than global organizations such as IBM, there are mechanisms in place to facilitate cost-effective environmental considerations. 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.

Consumption of Supplies:

• Reduce paper consumption and purchase recycled product when feasible
• Encourage staff to print double sided when printing large or multiple documents
• Encourage staff not to print emails or documents if not needed, rather read and manage electronically

Consumption of Energy:

• Strive to purchase electronic equipment that has the Energy Star rating when cost effective
• Purchase and utilize only low energy light bulbs
• Utilize programmable thermostats to control energy consumption and greenhouse gases
• Utilize technology, our conference call numbers, to reduce scope 1 GHG and limit travel – currently use GoToMeeting

Disposal

• Recycle all paper products produced, to include printed documents, newspapers, packaging materials, and incoming mail, cans, plastics
• Recycle all light bulbs
• Recycle electronic waste

Structure and Responsibility

Sedona Technologies believes that the only way the environmental management system can be successful is to have senior management support of the policies which is why our President has signed our Social and Responsibility Statement that is posted on our website.

Sedona Technologies is leasing our office space and is engaging our landlord in this plan. As a small business entity, Sedona Technologies has limited layers of management including our President and the Director of Sedona Technologies. As such, we have the ability to make corporate mandates with limited ease. As deficiencies or improvements are identified in the EMS Plan, they will be reported and corrected in a timely manner. Quarterly management meetings are utilized to identify performance of the company with regard to the EMS.

Competence, Training, and Awareness

During an annual review of the company policies, awareness training regarding our EMS will be restated and employees will be directed back to the URL to review posted information.

Communications

Sedona Technologies holds quarterly manager meetings which are documented through meeting minutes. Sedona Technologies is a small business that is able to train all employees when changes to the EMS are made. The URL to our EMS is posted in the break area with other company policies.

EMS Documentation

Sedona Technologies outsources several key areas of its EMS. Waste Commission of Scott County Waste is utilized for our e-waste removal, and Midland Recycling removes our other recyclables. These organizations provide the documentation and receipt of what is being disposed which gives Sedona Technologies the ability to measure against our objectives and track our progress.

Control of Documents

Sedona Technologies utilizes its process control policy to manage document versions as well as naming standards on our corporate server. Published EMS policy is available via the company intranet.

Operational Control

All employees at Sedona Technologies location defined in the scope statement will abide by the written policies and procedures of the EMS plan. When Sedona Technologies tasks in support of the EMS, employees will follow the processes to include procurement and recycling.

Emergency Preparedness and Response

If an emergency affects the location within the scope of the EMS, which is outside of the controls of Sedona Technologies, such as hazardous waste spill near the facility controlled by the policy, employees and staff will follow direction from first responders. If it is a local incident, staff and employees will report to 612 Valley View Drive, Moline IL.

Monitoring and Measurement

Sedona Technologies, a software development company, is required to recycle all electronic waste and utilizes the service from Waste Commission of Scott County. They provide a written receipt for tracking purposes.

ISO 14001 Requirements: 4.5.2 Evaluation of Compliance

Sedona Technologies is not ISO 14001 certified, however we adhere to the Illinois Public Act 97-0287, The Electronic Products Recycling and Reuse Act as it relates to the services we provide. A yearly review of the policy and adherence to the policy will be conducted and reported to management and progress posted on the URL.

Control of Records

The directory of company policies to include the EMS utilizes our current document management policies and procedures. The published EMS is available on the company intranet.

Non-conformances, Corrective and Preventive Action

Any non-conformances, corrective and preventive action will be reviewed on a yearly basis and recommendations will be made to management on progress, reporting improvements and adjustments of the EMS. Any improvements will be incorporated into the EMS and posted on the URL.

Internal Audit & Management Review

A yearly review of the policy and adherence to the policy will be conducted and reported to management and progress posted on the URL.