32 2021 ESG Report Introduction Climate change Appendices Transparency Healthy workforce and communities Responsible supply chain Product impact Training The central EHS team provides new-hire orientation that is customized to roles and responsibilities. It encompasses a comprehensive EHS curriculum that is delivered to business leaders, EHS professionals, and other applicable roles. This orientation includes training on all applicable EHS management information system platforms that allow us to track progress against performance measures. In addition, the central EHS team conducts a training needs assessment that is based on current incident trends, audit results and regulatory requirements. A BD EHS training matrix defines training assignments based on the roles and priorities identified, and training is assigned accordingly. EHS Corporate Standards contain requirements on training frequency and curriculum. Training completion is evaluated as part of the corporate audit program. Upon deployment of new or revised corporate EHS standards, training is an integral part of the process for adherence. The central EHS team deployed People Leaders training in FY 2021 to enhance leadership knowledge, reinforce roles and responsibilities, and drive engagement through all levels of the organization. The central EHS team uses a variety of training mediums, including classroom training, webinars and on-demand compliance training via our company’s online training system. Individual sites are responsible for identifying site-specific EHS training needs and implementing training programs on a variety of EHS topics, taking into consideration the risks that are present and any local regulatory requirements. In FY 2021 a Learning and Development leader joined the central EHS team. This investment strengthens the central team’s capabilities and processes for delivering training and development across BD. EHS training is also provided at a site level, with subjects and frequency determined by job role and local requirements, in addition to requirements set by Corporate EHS Standards. EHS management information systems In FY 2021, we implemented a new EHS management-of-information system across the company. This eliminated multiple instances of the legacy platform, allowing us to establish uniform and efficient processes and reduce cost. The platform was implemented over two phases and allows us to track these items at a site level: • EHS incident management • EHS audits • Risk assessments • C ompliance tracking • W aste management • En vironmental aspects & impacts • P ermits • Inspections EHS sub ject-matter experts from across BD were brought together to configure the new system to meet BD's requirements. All users received training on how to use the platform, and guidance tools are available within it. In addition, we use a platform provided by a third party to manage Safety Data Sheets (SDSs) within our operations. Internal audits We have a global EHS audit program covering all BD manufacturing, R&D, distribution center and major office locations. Audits are typically carried out by a third party and a representative from the central EHS team who leads and monitors audit performance and outcomes. In FY 2020, the BD EHS team implemented a new risk-based audit model that evaluates facilities on three main components: inherent risk, changes and performance. The inherent-risk factors include the type and size of the facility and take into consideration any high-hazard processes 11 . The change factors include new regulations, new processes and changes to site management or EHS personnel. Performance factors include the site’s performance in EHS over the past 12 months, including the outcome of any inspections by relevant authorities. This enabled a more deliberate focus for the selection of sites to be audited during the year. Audits are typically three full days and consist of an opening meeting, a site tour, document examination and finally, a closing meeting. Findings are included in the audit tool, and the site is responsible for ensuring that all actions are closed out. Four different levels of findings are potentially recorded: repeat findings where an issue was raised previously in an audit and deemed to be open again; high-level findings where there is a serious potential environmental or health-and-safety impact; medium-level findings in which there is a systemic issue; and low-level findings in which the issue is administrative or an isolated one-off. Executive summaries from each audit are provided to site management, operational leaders, EHS business team leaders, VP S&EHS, EVP ISC and the CEO. All corrective actions are tracked to closure with follow-up audits carried out approximately six and 12 months later to verify completion. Once findings are verified and closed, the site will be issued a closure confirmation from the central EHS team to document that the findings are effectively closed out. In FY 2022, all findings that remain open after the follow-up audit are tracked on a monthly basis and are communicated to top management and the CEO. As a result of the ongoing pandemic, in FY 2022, the audit team launched a hybrid approach to auditing at several high-hazard facilities. These sites must submit relevant documentation for review in advance of an in-person audit later in the year. This allows us to begin auditing sites despite travel restrictions. With a shift to virtual audits and a transformation of methodologies to address this new platform, we were able to continue to audit facilities to provide an effective level of governance oversight and address new challenges during these unprecedented times. Additionally, the updated closure and extension process provides visibility to leadership and helps all sites document the complete closure of outstanding findings. 11 BD has defined high-hazard processes as those that meet the definition per local regulations of high hazard, or those that exceed 50 percent of the threshold quantity value in a process per OSHA 1910.119, Process Safety Management. Other processes including large boilers, autoclaves, radiation hazards, toxic chemicals, etc., are also defined as high-hazard.