Third-Party Evaluation

Environmental Resources Management (ERM) conducted an evaluation of DuPont's SHE Audit Program directed by the Corporate SHE Excellence Center and implemented by the Company's four Global Regions.  ERM evaluated the elements and performance of the Program in order to render an independent opinion about its effectiveness in achieving improved SHE performance throughout the Company.  The assessment was conducted between January 2007 and January 2008 and included a review of Program documentation, interviews with Program Managers and staff, selected interviews with site representatives who have been subject to the audits and observation of four audits, two in the U.S. and two in Europe.

The Program was evaluated against three sets of criteria: (1) external expectations set by organizations with standing in the SHE audit community (e.g., U.S. EPA, ISO, and The Auditing Roundtable), (2) DuPont’s internal SHE auditing standard, and (3) generally accepted audit practices in comparable companies.  ERM reviewed the scope and elements of the Program, the procedures utilized, the resources applied to implement the Program and the degree and quality of management commitment.  Based on the information made available to ERM by DuPont, ERM has concluded that DuPont's Program is generally consistent with, and in some cases, exceeds expectations of the established criteria.  In our opinion, the Program provides competent, reliable and objective information to management about the status of the Company's SHE compliance programs and performance.  Further, DuPont's management is responsive in correcting deficiencies when they are identified by the Program audits.

As shown in Table 1, one of the Program’s elements, quality assurance, is quite advanced when compared to practices in other companies.  Of particular note is that the Program receives substantial internal and external oversight annually.  Moreover, the year 2007 was the second consecutive time, in the twelve years of the annual evaluation, that all elements achieved at least a “fully meets” score.  Notwithstanding this achievement, there are aspects of the Program and audits that could be improved.  Management has been informed of these areas in need of improvement and is taking steps to address them.  It should be noted that a twelve year-trend analysis indicates that solid, sustainable performance has been achieved in the past seven years.